AUGUST 2007 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 2007 ". 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 December 31, 2007.

Call For Comment August 2007 * Document Formats
1.		commentaugust2007.pdf	Requires Acrobat Reader

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 Mary Bird at the NACCAS office.

Call For Comment Response Form

Academic/Instructor Accrediting Agency Official Federal Government Official NACCAS Evaluator Other Practitioner School Owner/Administrator State Government Official Student

*Reference#:

Proposal#:	Description/Summary	Vote
07-01: Amendment to Standard III, Criterion 3 Rationale:  A separation of Criterion 3 into two separate criterion will make the requirements clearer to institutions and what they have to provide to demonstrate compliance.  In some instances, there is no documentation to demonstrate compliance, therefore on-site evaluators may only be able to determine compliance through observation or an assurance.	Proposed Wording: Standard III, Criterion 3 Becomes Criteria 3 and 5, as follows: D/A/O 3.      The school's administrative staff provides evidence, through documentation of attendance at training sessions and conferences, and in other appropriate ways, that they have knowledge of applicable federal, state, and local statutes and regulations governing the operations of the school.  The school complies with the NACCAS Rules of Practice and Procedure and other NACCAS accreditation requirements. . . . D/A/O 5. The school complies with the NACCAS Rules of Practice and Procedure	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07- 02:   Revise Standard III, Criterion 9 and Renumber it as Criterion 4 Rationale:  By moving the Criterion to immediately follow revised Criterion 3, there is a clearer flow from one criterion to the next.	Proposed Wording: A         94.      In the event that concerns are raised about a school's compliance with applicable federal, state or local laws and regulations, the school can demonstrates that the reasons for such concerns do not represent a lack of educational quality. or a violation of NACCAS' accreditation requirements.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-03: Amend Standard III, Criterion 4 and Renumber it as Criterion 6 Rationale:  The changes would clarify the intent of the Criterion.	Proposed Wording: D   46. A school that participates in any student financial assistance program must demonstrate, at a minimum, that: a.   It The school has a designated staff person who is capable of, and responsible for, administering and/or supervising administration of all the student financial assistance programs in which the school participates; b.   It The school has a current, signed participation agreement with the source of the program, if applicable; c.   It The school submits any audits required by the program in accordance with the participation agreement and/or the regulations applicable to the program; d.   If participating in federal loan programs, it the school maintains an official cohort default rate below the threshold established by the U.S. Department of Education. for termination from the program. This requirement shall be waived by the Commission if the school submits documentation which shows that: 1.  The number of students in default represented by the official default rate were fewer than 15% of all students enrolled at the institution for the period of time covered by the official default rate; or  (move to NACCAS' Guidelines for Responding to Visit Reports) 2.. The dollar amount of the defaults covered by the official default rate is less than 20% of all financial assistance received from the program by students attending the institution during the period covered by the official default rate; or  (move to NACCAS' Guidelines for Responding to Visit Reports) 3.  5% or fewer of the institutions students who were enrolled on at least a half-time basis during the most recently completed fiscal year received any other student loan from the same source; or  (move to NACCAS' Guidelines for Responding to Visit Reports) 4.   Two-thirds or more of the institutions students, during the most recently completed fiscal year were individuals from disadvantaged economic backgrounds (based on the Pell grant index for zero family contribution) and the institution has complied with NACCAS outcomes standards for the two most recent years for which annual reports were required to be submitted to NACCAS.  (move to NACCAS' Guidelines for Responding to Visit Reports) Standard III, Criterion 5 becomes Criterion 7 Standard III, Criterion 6 becomes Criterion 8	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-04:  Amend Standard III, Criterion 7 and Renumber it as Criterion 9 Rationale:  The changes would clarify the intent of the criterion.	Proposed Wording: D     79.  The school follows policies that a.   Guarantee each student (or parent or guardian if the student is a dependent minor) access to that student's records; b.   Require written consent from the student or guardian for release of records in response to each third party request unless otherwise required by law; c.   Before publishing and/or selling "directory information" for either the student or guardian, such as the name, address, and phone number(s), and email address (es) of student, date and place of birth, major field of study, dates of attendance, degrees and awards received, date of graduation, previous school attended, and/or date of graduation from previous school, allow the student or guardian to deny authority to publish one or more of these items; d.   Provide and permit access to student andother school records as required for any accreditation process initiated by the institution or by the National Accrediting Commission of Cosmetology Arts and Sciences, or in response to a directive of the Commission.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-05:  Amend Standard III, Criterion 10 and Renumber it as Criterion 11 Rationale:  All institutions must monitor the unofficial withdrawal of students, however not all institutions are required to take attendance. The proposed changes clarify the Commissions intent.	Proposed Wording: D  1011.  If a school uses credits or competencies to measure academic programs, and the school elects to have a Student Attendance Policy, it must be applied uniformly and fairly.  A school recording student attendance in clock hours gives appropriate attendance credit for all hours attended.  For the purpose of determining unofficial withdrawals, schools that take attendance must monitor attendance at least monthly.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-06:  Amend Standard IV, Criterion 1 and Renumber it as  Criterion 3 Rationale:  By re-ordering the criteria and making minor revisions to the wording, it will clarify the intent of the standard.	Proposed Wording: D 13.  Before accepting an applicant for admission, the school provides the applicant with either a copy of the school catalog. that meets NACCAS catalog guidelines or documentation that the student has received through the schools website,  The catalog may be a printed copy, web-based, or in any other media format.  The catalog must be in the language in which the program will be taught and meet information specified in the NACCAS Catalog Requirements.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-07: Revise Standard IV, Criterion 2 Rationale:  The Commission believes that it is redundant using the word admitted because the word student already implies that the person has been enrolled in school.	Proposed Wording: D  2.    The school's admission policies require that each admitted student meet one of the following: a.   Have a high school diploma, or its equivalent, or a certificate of attainment (only applicable for non-Title IV recipients); or b.   Be above the age of compulsory school attendance in the state in which the school is located and fulfill criteria for admission as a student who has the ability to benefit from the training, according to the NACCAS Ability to Benefit Policy; or c.   If enrolled under a training agreement with a government agency, school district, and/or other entity, meet the admission requirements set out in the training agreement and/or applicable state licensing or certification regulations.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-08:  Amend Standard IV, Criterion 6 and Renumber it as Criterion 4 Rationale:  By reordering Criterion 6 as Criterion 4, the criteria will more closely follow the proper progression of the Standard, as well as clarify that pre-enrollment information is to be provided to applicants.	Proposed Wording: D 64.  Before enrollment each student applicant is provided with current written information, that is available through handouts or the schools website printed copy, web-based, or any other media format, in the language in which the course program will be taught, that accurately describes: a.   Completion rates for students in the school; b.   Pass/fail rates of school graduates on certification or licensing examinations (if either is required to practice); c.   Placement rates of the school's graduates; d.   Compensation a successful graduate may reasonably expect; e.   The physical demands of practicing the profession; f.    Safety requirements for the profession; g.   Certification or licensing requirements for the jurisdiction in which the school is located, or for which it is preparing graduates.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-09: Amend Standard IV, Criterion 7 and Renumber it as Criterion 5 Rationale:  The proposed wording will more clearly state the intent of the Commission and, the reordering of the criteria will more closely follow the proper progression of the Standard.	Proposed Wording: D 75.  The school prepares for each student admitted an enrollment agreement for each applicant in the language in which the program will be taught.  The enrollment agreement must comply with the NACCAS Enrollment Agreement Requirements., and a 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.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-10:  Proposal to Allow the Use of Either Term: Counseling or Advising Rationale: The terms counsel and advise and other terms derived from them are used synonymously.	Proposed Wording: Under Standard V Student Support Services, and other standards and policies, NACCAS shall not cite an institution that uses the term counsel or its derivatives rather than advise or its derivatives.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-11:  Amend and Reorganize Standard IX Rationale. Constituents at the Community Call for Comment noted that NACCAS Standard IX is confusing because of the order in which the criteria are listed.  Therefore, the Commission is proposing to re-order the Criteria, as well as amend the terminology used for progress reports to report cards for clock hour programs. The Commission is also proposing to amend Criterion 6 by eliminating wording in that is already included in the policy.	Proposed Wording: Standard IX.  Evaluation of Students The school uses systematic student evaluation to assist student learning and to demonstrate satisfactory student achievement before a certificate of completion is awarded. IX-1 No change IX-2 No change IX-3 Renumber as Criterion 6 IX-4 Becomes Criterion 3 and is amended as follows: Instructors must be available to discuss the students progress.  Each student must be apprised of his progress status and have the opportunity to review the information throughout the program, at a minimum as follows: A program measured in competencies:  Each student has a document which is attested to by the appropriate school employee upon demonstration of the competencies in theory, in practical work, and in other requirements for each unit of instruction. Program measured in credit hours:  Each student is provided with a written report at the end of each term.  The reports evaluate the students performance in theory and practical work, and informs the student of the number of credits earned. Program measured in clock hours:  Each student is provided with at least two written progress report cards during programs that are 150 hours in length or longer, and at least one progress report card during programs of less than 150 hours.  The reports evaluate the students performance in theory, in practical work, and, if a school elects or is required to take attendance, the students attendance progress may be included in the progress report cards. IX-5 No change. IX-6 Old Criterion 3 becomes Criterion 6 with some changes, as follows:  The school records student progress evaluations according to the requirements of the NACCAS Policy on Satisfactory Academic Progress.  The school has established a minimum acceptable level of academic progress of at least the equivalent of a 70% grade point average or project completion rate.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-12:  Add a Footnote to Section 4.11 of the Rules of Practice and Procedure Rationale:  Branch campuses have the same anniversary date as their main campuses.  A branch campus is required to be under the same ownership and financial structure as its main campus and provides the same administrative services as its main campus.  Areas of non-compliance with NACCAS standards at a main campus or its branch(es) reflects on the main and branch together.  Because a main campus and its branch(es) have concurrent anniversary dates, if a shorter period of accreditation is granted to one,  the other related campus would also have its period of accreditation shortened accordingly.  The proposed footnote would clarify the Commissions intent.	Proposed Wording: Section 4.11 . . . (g)  Renewal of Accreditation.  The anniversary date of a branch campus and its main campus shall coincide. ^1 ^1 If a branch or main campus  is granted a shorter period of accreditation, the main and all branches will have the same shortened period of accreditation.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-13:    Proposal Add a footnote to Section 4.20 of the Rules of Practice and Procedure Rationale:  The 18-month business plan should cover the period after an institution no longer has access to federal aid.  The Commission needs to have information on which to base a determination of whether or not the institution has the resources necessary to continue to comply with NACCAS standards for a quality education.	Proposed Wording: Section 4.20          Change in Participation in Federal Student Financial Assistance Programs Established under Title IV of the Higher Education Act of 1965, as Amended (a)  The accreditation granted by NACCAS allows institutions to apply for participation in federal student financial assistance programs. (b)  Within 30 days of ending Title IV participation:  An institution that withdraws or is terminated from participation in Federal student financial assistance programs established under Title IV of the Higher Education Act of 1965, must submit an application for change in the purpose of its accreditation, within 30 days of the change. This application must be accompanied by an eighteen-month business plan ^1, in accordance with NACCAS requirements (see Appendix #11B), indicating how the institution will sustain programs and operations which meet NACCAS accreditation standards.  ^1 The 18-month business plan for schools that cease T-IV participation covers the 18 months from: a. the date on which the schools withdrawal from Title IV is effective, or b. the date on which the schools termination from T-IV by the USDE went into effect.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-14:     Proposal to Replace the Low Outcomes Directives Process with Low Outcomes Monitoring Rationale:  With Low Outcomes Monitoring institutions begin to receive technical assistance in time to help them improve information gathering on graduate, placement, and licensure information. Under monitoring, institutions receive an analysis of their procedures and forms before they submit the Plan for Improvement, so suggestions for improving procedures and forms may be incorporated into the Plan. If adopted this change would go into effect:  For institutions with low outcomes based on the 2006 Annual Report due  November 30, 2007.	Proposed Wording: PART 5 ANNUAL REPORTS AND SPECIAL REPORTS Sub-Part A Annual Reports Section 5.0      Annual Report (a)  Every year, each school holding accreditation status, or status as an applicant for initial accreditation^1 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 due 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.  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 the annual report worksheet on NACCAS Web Site. (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)).  (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 four (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)(d)  Monitoring^2: (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 outcome was based^3; and (4)  The institution must participate in a study to verify the accuracy of its annual reporting in the following year^4. (5)  An institution may not be on monitoring for a low rate in the same area for two consecutive years. (f) (e)  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 on-site 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.  ^1An applicant for initial accreditation must submit its first annual report to NACCAS with its application for initial accreditation. ^2Example: If an institution has a low placement rate based on the 2005 cohort, the monitoring report will be for the 2006 cohort. ^3Example: If a school had a low licensure rate based on the 2005-2006 annual report,  it would have to be in the 2006-2007 annual report verification study.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-15:  Add an option for action on Complaints to Section 6.5 of the Rules of Practice and Procedure Rationale:  At times, the Commission receives comments in the form of a complaint that do not allege any violation of accreditation requirements or  include insufficient information for the Commission to determine whether or not any possible violation is being alleged.  Despite the Commissions procedure to request additional information from the complainant, the record may still be insufficient to constitute a complaint.	Proposed Wording: Section 6.5  Taking Action on a Complaint Upon expiration of time limits for submission of the schools response or for submitting additional information which was requested, the designated committee or the Commission shall take one or more of the actions authorized in Part 8 of these Rules.  In addition, they may take one of the following actions: (a)   Determine that the information received is insufficient to constitute a complaint. (a)(b)  Encourage an informal resolution or settlement of the dispute. (b)(c)   Declare the complaint resolved. (c)(d)  Refuse to process any complaint which appears has been determined to be known (1)  Frivolous or groundless, (2) Brought vexatiously, (3)  Brought wantonly or for oppressive reasons, or (4)        Which is submitted anonymously.	Agree Disagree

Comments:

Proposal#:	Description/Summary	Vote
07-16: Increase in Fees and Remove the Schedule of Fees from the