by Christopher C. Walck, Associate Chief Executive Officer/Director of Accreditation

Criterion 7 has several different facets to it, since the Criterion addresses the specific elements that must be included in a school's contract, the implementation of the contract, as well as ensuring that a completely executed copy is maintained by the school. The criterion states:

7. The school prepares for each student admitted an enrollment agreement in the language in which the program will be taught. The enrollment agreement must comply with the NACCAS Enrollment Agreement Requirements, and a copy of the agreement must be provided to the student or legal guardian if the student is a dependent minor. The agreement gives complete information on the total cost of the program. A copy of the completed enrollment agreement is maintained by the school.

The most frequently cited aspect of Criterion 7 deals with elements of NACCAS' Enrollment Requirements that are missing from a school's contract. Prior to August of 2004, schools would receive a limitation in the Team Report if any elements were missing and had not been resolved by the day of the on-site evaluation. The Commission, however, adopted a policy at its May 2003 meeting, whereby the NACCAS staff would review a school's compliance with NACCAS' Enrollment Agreement and Catalog Requirements separately from the on-site evaluation process. Any areas of non-compliance with these two documents are addressed through written correspondence between the NACCAS office and the school until all issues have been resolved.

Suggestions to Ensure Compliance

• When completing the cross-referencing of your contract with NACCAS' requirements have one of your staff review the document to ensure that each requirement is clearly addressed in the contract.
  
• Prior to making any changes to your contract, please send a copy to NACCAS for review.
  
• For items such as NACCAS' refund policy or student's right to privacy, you need to double check to make sure you have included all required elements of the policy. If you have a state mandated policy, please ensure that all elements of the state's policy are clearly stated.

The second issue that causes a school to receive a limitation under Criterion 7 is if contracts are not completely executed. A school is required to provide each student who enrolls with a completely executed contract. The only exception to this rule is if the student is enrolled under a training agreement with a government agency, school district, or other entity. What does “completely executed” mean? A student is required to receive a contract that contains no blank spaces, and when changes are made to the contract they are initialed by both parties.

Suggestions to Ensure Compliance

• Have two staff members review every contract to ensure that it has been completed fully.
  
• Draft a policy for staff members as to how to complete or make changes to a contract.
  
• If the school uses an addendum to the contract to make any changes to a currently enrolled student, please ensure that the addendum is signed and dated by both parties so that the changes have been agreed to by all individuals.

The third and final issue addresses the need to maintain a copy of each student's fully executed contract and any addendum.

Suggestions for Ensuring Compliance

• Pick once or twice a year to complete a student file audit to ensure that not only a fully executed contract is maintained, but that any other required documents are on file as well. This procedure will help to ensure your compliance with any state, federal, and accreditation requirements.

We hope this article has given you some ideas as to how to come into, or remain, in compliance with the requirements of Standard IV, Criterion 7. If you need any further clarification, please contact the NACCAS Accreditation Department for assistance.