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August 2006 Call For Comment

  Comment Form  

Please click one of the available document format links below to download the full text of the "Call For Comment August 2006". After reviewing the proposals, you may return to this page to submit your response in the "Call For Comment Response Form" for the proposed changes. Please submit your responses no later than October 27, 2006.

Call For Comment August 2006
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The following is a brief description and summary of the proposed changes to NACCAS' Standards and
Criteria
, Rules of Practice and Procedure, By-Laws, and policies. For each proposed change, a column is provided for you to indicate whether you agree or disagree with the proposed changes. A space for written comments is provided at the bottom of the response form. If you have any questions about the Commission's proposals or the "Call for Comment" process, please feel free to contact Christopher Walck at the NACCAS office.

Call For Comment Response Form
Proposal#:
  Description/Summary  
Vote

         

06-17E: Amendment to Part 5 of the
Rules of Practice and Procedure

Rationale for the Proposal: Placement rates on those students who graduate within a calendar year will give a school sufficient time to obtain documentation to show the graduate has become licensed and placed before the annual report is due.

This proposal will go into effect starting with the 2005-2006
Annual Report due on November 30, 2006.

 

Proposed new Placement rate formula

Where:
G=same as G in the completion rate formula;
GG = All students who graduated in the calendar year of the report, no matter when they were scheduled to graduate.
J=number from G GG who had jobs in the field for which trained; and

Formula:
U=Exceptions1
G=placement rate
(GG-U) = placment rate

1 Acceptable exceptions are:

  • Deceased
  • Disabled
  • Called for Military Service
  • Continuing in higher education
  • Studied under a student visa
  Agree
Disagree
Comments Attached
         
         

06-18: Proposed Amendments to Part 5 of the Rules of Practice and Procedure

Rationale for the Proposal:
NACCAS outcome formulas have been under recent review by the
United States Department of Education. By removing the formulas from the Rules of Practice and Procedures, we will be able to accommodate changes requested by the United States
Department of Education in a timely manner.

Note: Additional amendments to Part 5 are proposed under 06-19.

 

Proposed Wording:

PART 5--ANNUAL REPORTS AND SPECIAL REPORTS

Section 5.0 Annual Report...

(a) - No change

(b) ...

The information each NACCAS-accredited institution provides on the annual report submitted to NACCAS is used to calculate outcome rates for the institution. The formulas used to calculate rates are shown in subclause (d) below the annual report worksheet on NACCAS' Web Site.

(c) - No change

(d) The formulas that will be used to calculate completion, placement, and licensure rates, are as follows:

Completion rate formula: Where S=students scheduled to graduate during the report year;2

G = students from Group S who did graduate; and Formula: G ÷ S = Completion rate

Licensure rate formula

Where T = graduates, no matter what year they graduated, who sat for the first time, during the report year, for the final portion of the examination by the end of the report year

Formula: L ÷ T = Licensure Rate.

Placement rate formula

Where:
G = All students who graduated in the calendar year of the report, no matter when they were scheduled to graduate.
J = number from G who had jobs in the field for which trained; and

Formula: J ÷ G = Placement Rate.

(e)(d) If the Plan for Improvement is inadequate, the Executive Director and/or Commission may order additional information or actions by the institution, including a special onsite visit to provide technical assistance for institutions preparing and/or implementing a plan for improvement or to evaluate the effectiveness of a plan and its implementation.

[The rest of this Part remains unchanged.]

2 For short programs that are not eligible for Federal student financial assistance, an institution need not include in the cohort of "students scheduled to graduate" students who are merely auditing the program (for personal enrichment).

  Agree
Disagree
Comments Attached
         
         

06-19: Proposed Amendments to Part 5 of the Rules of Practice and Procedure

Rationale for the Proposal : NACCAS' current procedure for institutions with Low Outcomes requires institutions to prepare
and implement a Plan for Improvement. Under the current policy,
an institution's plan would not be implemented or evaluated until
the second year following the year of low income.

For example if an institution has a low outcome for 2005, it is not reported until 2006 and the plan for improvement is implemented in 2007. It is already too late for the plan of improvement to affect 2006. The purpose of the proposed monitoring procedure
is to benefit those students who graduated, in terms of licensure
and placement support, and to implement improvement plans more quickly for the benefit of currently enrolled students.

We are suggesting a year of monitoring, following a year of low outcome in order to allow the institution to implement the Plan for Improvement.

 

Proposed Wording:

PART 5--ANNUAL REPORTS AND SPECIAL REPORTS

Section 5.0 Annual Report

(a) Every year, each school holding accreditation status, or status as an applicant for initial accreditation3 shall submit an Annual Report on forms and in the manner required by the Commission. The report and required documents must be received in the NACCAS office no later than the due date. Failure to submit a complete Annual Report by the date may result in the withdrawal of the school's accreditation and in late fees as determined in Appendix #2 of these Rules.

(b) NACCAS shall verify information provided on the annual reports using various methods which shall include, but not be limited to,

(1) Verification during on-site evaluations,

(2) Verification of institutions which are being monitored for low outcomes a
random sample of at least 10% of the reports each year, and

(3) Direct contact with students, employers and licensing agencies.

The information each NACCAS-accredited institution provides on the annual report submitted to NACCAS is used to calculate outcome rate for the institution.

(c) Institutions with one or more outcomes (completion, placement, licensure) below NACCAS' minimum threshold, based on the annual reports due most recently, shall be required to comply with one of two options: The "low outcomes directive" (see sub-section (d) or monitoring (see sub-section (e)).

(d) Low Outcomes Directive: The Executive Director of NACCAS shall order any accredited institution with a completion, licensure or certification, or placement rate below NACCAS' minimum Standard that it

(1) Attend an Accreditation Workshop and Outcomes Work Group within six months of availability,

(2) Prepare, submit, and implement a plan for improvement within (4) weeks after attending the workshop, and

(3) Demonstrate compliance with the Standard within the timelines established in Section 8.18 of the Rules of Practice and Procedure.

(e) Monitoring4:

(1) The school owner or designated representative must complete a workshop made available following the date the annual report on which a low outcomes was based, was due;

(2) The institution must submit a plan to improve the low outcome(s);

(3) the institution must submit monitoring reports, on forms provided by NACCAS. The monitoring reports shall cover the outcomes cohorts for the year following the year on which the low outcomes was based5; and

(4) The institution must participate in a study to verify the accuracy of its annual reporting in the following year6.

(5) An institution may not be on monitoring for a low rate in the same area for two consecutive years.

(f) If the Plan for Improvement is inadequate, the Executive Director and/or Commission may order additional information or actions by the institution, including a special onsite visit to provide technical assistance for institutions preparing and/or implementing a plan for improvement or to evaluate the effectiveness of a plan and its implementation.

[The remainder of this Part is unchanged.]

3 Applicants for initial accreditation must submit their first annual report to NACCAS in the year in which they apply for initial accreditation. The report shall be for the previous year.

4 This option will be available to schools starting with the 2005-2006 annual report which is due November 30, 2006,

5 Example: If an institution has a low placement rate based on the 2005 cohort, the monitoring report will be for the 2006 cohort.

6 Example: If as school had a low licensure rate based on the 2005-2006 annual report and chose the monitoring option, it would have to be in the 2006-2007 annual report verification study.

  Agree
Disagree
Comments Attached
         
         

06-20: Proposed Amendments to Section 5.1 and 6.6 of NACCAS' Rules of
Practice and Procedure

Rationale for the Proposal: The Commission monitors an institution that has a pending process with a state or federal government agency under Part 6 of the Rules, and determines whether or not the institution is out of compliance with an accreditation requirement. therefore, the only special report needed under Part 5, is a report on the final outcome of the government process.

 

Proposed Wording :

5.1(a)...(9) Any final determination, in accordance with requirements of the United States Department of Education, that the institution is not meeting the Department's requirements; [Note: The Commission will monitor schools under section 6.6.]

Change section 6.6(b) by eliminating the last sentence, as follows:

Section 6.6(b) Information received from the U.S. Department of Education or other government agencies indicating a school's failure to comply with its Title IV responsibilities shall follow the complaint procedure, but will be classified as a government action in any notifications to the school and government agencies. NACCAS no longer is required to acknowledge receipt of this information or report to the Department when a process has been initiated based on the information.

  Agree
Disagree
Comments Attached
         
         

06-21: Proposed Amendment to Section 2.2 of the NACCAS Rules
of Practice and Procedure

Rationale for the Proposal: Through the re-recognition process, the U.S. Department of Education determined that the Commission had delegated authority in its Executive Director that was not consistent with recognition requirements. Therefore, the Commission, and not the Executive Director, must grant candidate status because it could be considered an accreditation status.

 

Proposed Wording:

Section 2.2 Grant of Candidate Status

(a) Candidate status shall be granted by the Commission Executive Director of NACCAS if the application is complete and demonstrates the applicant meets institutional eligibility requirements, and the required sustaining fee has been paid.

(b) A denial of candidate status is appealable to the full Commission pursuant to Part 9 of these Rules.

  Agree
Disagree
Comments Attached
         
         

06-22: Amendment to Article VIII of the By-laws

Rationale for the Proposal: Every year new people are elected to the Commission and experienced Commissioners complete their terms. It is important for the Commission to maintain continuity in its relationships with the U.S. Department of Education and its
compliance with recognition requirements.

Current Section IV would become Section V.

 

Proposed Wording for this Amendment to the By-Laws:

Article VIII - DUTIES OF COMMITTEES

New Section IV: The Commission shall have a standing Committee on Re-Recognition including at least two former Commissioners, if available who, while members of the NACCAS Board of Commissioners, served on a Committee on Re-Recognition, to make recommendations to the full Commission on issues related to recognition by the Secretary of Education.

Current Section IV would become Section V.

  Agree
Disagree
Comments Attached
         
         
    Please include comments on the effectiveness of the new side-by-side comparison format or any suggestions to improve the comment process.
     
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