Release of the 2018 Draft Staff Report
Statement from Michelle Edwards, President of ACICS on the Release of the 2018 Draft Staff Report
As per the normal course with review of any Initial Petition, the Department expected ACICS to respond to the draft report observations by supplying additional information to demonstrate compliance with regulatory criteria. That is why a Department representative stated publicly that the draft was pre-decisional and an incomplete analysis. ACICS was working to supply the necessary additional information when the process was halted per an April 2018 Order of Secretary DeVos. Thus, ACICS never had the opportunity to complete its response to the Draft Staff Report and submit additional information that would demonstrate full compliance in the context of the Initial Petition.
Moreover, it is important to note that the Draft Staff Report contains numerous flaws. For example:
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Staff requested an explanation as to why ACICS allowed waiver of international students in placement rate calculations and asked for more information as to how ACICS schools calculate placement rates for foreign students. However, foreign student visa status prohibits international students from working in the United States in most cases;
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Staff alleged deficient evidence of consideration of placement and licensing rate data by ACICS staff when the Campus Accountability Reports submitted by ACICS (and explained to Department staff during their in person visit of the agency) showed clear evidence of a process for review of that data in school evaluations;
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Staff improperly undercut the value of the public and academic experience among ACICS leadership, staff and volunteers where there was any affiliation past or current with ACICS accredited schools. There is no legal basis for rejecting the value of public and academic experience based on past or current affiliation with the agency under review; and
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Staff rejected the wide acceptance of ACICS as an accrediting agency despite its years of functioning as a recognized agency and acceptance of its accrediting decision by states, licensing boards, associations, practitioners, employers, and even the courts, as well as the continued occupational licensing of ACICS school graduates. The new high bar the Department staff set for wide acceptance was amorphous and unreasonable.
We provided additional materials that, we believe, clearly demonstrate our compliance with recognition standards. Based on the current continued recognition process underway, we look forward to the Department completing its review in an efficient and constructive manner.”
