May 4, 2012 VIA EMAIL Vice President of Compliance IEC ...

May 4, 2012

VIA EMAIL (corvind@)

Mr. Don Corvin Vice President of Compliance IEC International Corporation United Education Institute 3563 Phillips Highway, Building C, Suite 300 Jacksonville, FL 32207

Dear Mr. Corvin:

Re: Reaccreditation Deferred; Interim Report Reviewed;

Institutional Show Cause Continued; Program Approvals Withdrawn ?11 programs;

Teach-out Plan required(Medical Assisting); Limited Enrollments-4 programs Interim Report Required ACCET ID #0170

At its April 2012 meeting, the Accrediting Commission of the Accrediting Council for Continuing Education & Training (ACCET) considered the application for reaccreditation of United Education Institute with its main campus in Jacksonville, Florida, and branch campuses in Morrow, Georgia, San Marcos, California and Stockton, California, the on-site visit team reports (visits conducted January 23-26, 2012 and February 13-16, 2012), and the institution's responses to those reports, dated March 9, 2012 and March 30, 2012. The Commission further reviewed the institution's interim report submitted in response to the December 22, 2011 Commission action letter resulting from a prior interim report directive, dated September 2, 2011, resulting from a Quality Assurance Unannounced Visit team report (visit conducted at the Jacksonville main campus on March 3, 2011). The December 22, 2011 letter directed the institution to provide: 1) Acknowledgement of the implementation of the Program Approval Withdrawals for the 12 programs at specified locations and a narrative update on the progress of the implementation of the revised corporate placement verification process and any other efforts made to improve placement rates, both in terms of reliable accuracy and of absolute numbers of employed graduates. The institution was instructed that to regain eventual approval to enroll, the institution must demonstrate significant progress towards increasing the placement rates in these programs, in addition to providing detailed supporting documentation to evidence that the market area can sustain the level of graduates the institution is producing; 2) Updated completion and placement data for all programs at all campuses for calendar year 2010 and the period January 1 ? October 31, 2011, performed by UEI's Corporate Verification Department employing the same auditing methodology as used by Weworski & Associates for the placement audit previously conducted. The scope of this placement audit was to include the preparation and submission of: a) updated Documents 28.1 ? Completion and Placement Statistics; b) full supporting documentation substantiating each reported start, completion, waiver, and placement in accordance with verification requirements for the various categories of training-related employment, as published in ACCET Document 28, for all placements and waivers documented

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since July 1, 2011; and c) a corresponding list for each Document 28.1 identifying, by monthly cohort, the name of each student included on the form, along with the student's cumulative grade point average, and overall attendance rate utilizing the On-site Sampling Verification: Completion, Placement, and Academic Data form; and 3) A teach-out plan, in accordance with ACCET Document 32 ? Teach-out/Closure Policy, for each program for each campus, as approval for the majority of programs across all campuses was withdrawn. Upon review of the interim report, received March 26, 2012 (with additional updates emailed on March 29, 2012), the Commission determined that while items one and three noted above were satisfactorily addressed, the completion and placement statistics for the majority of the programs offered are still well below ACCET standards. As a result of its review of both the team report responses and the interim report, the Commission voted to defer consideration are review cycle and to extend the institution's accredited status pending further review at its August 2012 meeting, defer final branch approval of the Stockton campus, and continue the Institutional Show Cause status due to seriously below-benchmark completion and placement rates.

While the institution provided a detailed response illustrating the implementation of its placement tracking practices, the effectiveness of this newly developed process has yet be demonstrated, and must be evidenced in practice over time. The institution's current placement results indicate a clear and serious failure to fulfill the institution's vocational training mission consistent with its obligations to its students and the requirements for maintaining compliance with ACCET standards for accreditation. The Commission noted the serious risk faced by students represented by the institution's severely substandard completion and placement statistics for calendar year 2010, statistics that will not likely improve at this late date. Further, while the updated statistics for January ? October, 2011 show some improvement, the majority of programs are still far below benchmark. Therefore, the Commission voted to continue the withdrawal of program approvals for the purpose of prohibiting new enrollments for all programs in the show cause range (11 of the institution's 15 programs across three campuses) as outlined in the chart below. It is further noted that the Commission was particularly concerned about the severely low placement rates (and extremely high enrollment rates) for the Medical Assisting program across the three campuses with eligible graduates, and that vote to continue withdrawal of approval for the program offers serious doubts of any possible future reinstatement at the three campuses listed below.

No enrollments Campus/Program

Jacksonville Computer Systems Tech. Jacksonville Dental Assistant Jacksonville Medical Assistant Jacksonville Med. Billing & Ins. Coding

January ? October 2011 Completion Statistics 64.04% (89 net starts/57 completions) 62.38% (101 net starts/63 completions) 57.94% (340 net starts/63 completions) 68.18% (110 net starts/75 completions)

January ? October 2011 Placement Statistics 36.54% (52 eligible/19 placed) 25.93% (54 eligible/14 placed) 26.14% (176 eligible /46 placed) 31.43% (70 eligible/22 placed)

Morrow

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Dental Assistant Morrow Medical Assistant Morrow Med. Billing & Ins. Coding

67.04% (267 net starts/167 completions) 54.79% (449 net starts/246 completions) 64.71% (153 net starts/99 completions)

42.96% (142 eligible/61 placed) 42.31% (208 eligible/88 placed) 38.55% (83 eligible/32 placed)

San Marcos Business Office Admin (5) San Marcos Dental Assistant San Marcos Medical Assistant San Marcos Med. Billing & Ins. Coding

50% (2 net starts/1completions) 78.82% (201 eligible/160 completions) 79.41% (544 eligible/431 completions) 80.22% (182 eligible/145 completions)

100% (1 eligible/1 placed) 50.74% (136 net starts/69 placed) 28.34% (378 net starts/106 placed) 37.09% (124 net starts/46 placed)

Accordingly, the institution is prohibited from enrolling new students in all programs noted above, except those students with a signed enrollment agreement executed prior to the December 22, 2011 Commission action letter. Additionally, the Commission voted to limit the number of enrollments allowed in the remaining four programs at the following specified sites, not to exceed 30 new enrollments in Jacksonville, 40 new enrollments in Morrow, and 20 new enrollments in San Marcos.

Limited Enrollments Campus/Program

Jacksonville Business Office Admin Jacksonville Computer Security Admin

January ? October 2012 Completion Statistics

January ? October 2012 Placement Statistics

57.5% (80 net starts/ 46 completions) 70.59% (43 eligible/24 place)

58.14% (43 net starts/ 25 completions) 57.14% (21 eligible/12 placed)

Morrow Business Office Admin

63.77% (138 net starts/88 completions) 72.31% (65 eligible/47 placed)

San Marcos Computer Systems Tech

81.4% (43 net starts/35 completions) 72.41% (29 eligible/21 placed)

While the institution's responses to the team reports and its interim report adequately addressed a few of the weaknesses raised in the on-site team reports, the following issues are in need of further clarification and/or resolution relative to ACCET standards, policies, and procedures:

1. Standard I-A, Mission Statement (Jacksonville, Morrow, San Marcos); Standard I-B, Goals (Jacksonville, Morrow); Standard VIII-E, Completion and Placement (Jacksonville, Morrow, San Marcos)

The team report indicated that a review of the completion and placement statistics did not reflect an accomplishment of the institution's mission, are contrary to the intended institutional goals, and are not representative of the asserted operational connection to the mission statement. Nor do the institutional goals reflect the institution's current placement and career services

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objectives. The team noted that while all programs have shown a slight improvement in placement rates, all programs were still below benchmark at the time of the visits.

The institution indicated in its response that it has created a plan from the corporate level down to support career services in placement verification and tracking to assure compliance with ACCET Document 28 ? Completion and Placement Policy. The verification process occurs independently from the placement process and is executed by persons reporting to the corporate compliance division and not to the campus staff. The institution further provided a detailed outline of this plan along with newly added support and verification positions, as well as an update of its current progress towards meeting ACCET benchmarks in all programs; however, the institution has fallen seriously short of meeting its responsibility to those students reflected in its failure to meet the required benchmarks for the programs illustrated in the charts above.

While encouraged by these efforts and the expected future benefit to its current enrollees, it is of little consolation not the prior graduates. Therefore, the institution must provide a narrative update on these issues, to include demonstrating its aggressive efforts toward progress made to improve completion and placement rate at all campuses, with the provision of updated Document 28.1s ? Completion and Placement Statistics for all programs at all campuses (including Stockton) for calendar year 2011, as well January ? February 2012, performed by UEI's Corporate Verification Department. The scope of this placement audit must include the preparation and submission of: 1) updated Documents 28.1 ? Completion and Placement Statistics; 2) full supporting documentation substantiating each reported start, completion, waiver, and placement in accordance with verification requirements for the various categories of training-related employment as published in ACCET Document 28 for all placements and waivers documented since July 1, 2011; and 3) a corresponding list for each Document 28.1 identifying, by monthly cohort, the name of each student included on the form, along with the student's cumulative grade point average, and overall attendance rate utilizing the attached On-site Sampling Verification: Completion, Placement, and Academic Data form for each Scheduled to Graduate (column 3) cohort on the respective 28.1s to be submitted with your response.

Further, the institution must provide a complete list of all students, by program and campus, enrolled after the date of this letter in those programs for which approval has not been removed, to include a narrative update on their progress towards completion of their respective programs.

Additionally, the institution must provide an updated teach-out plan for its Medical Assisting programs at the Jacksonville, Morrow, and San Marcos campuses following the guidelines of ACCET Document 32 ? Teach-out/Closure Policy to include a narrative update on the implementation of that plan.

2. Standard V-B, Externship/Internship (Jacksonville, and Morrow)

The team report indicated that the externship coordinators do not have a background in the medical field to qualify them for assessing the suitability of medical offices for externship

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experiences. In addition, the team was concerned that the externship coordinators do not visit the externship sites at least once while students are present to ensure that students are placed in an appropriate setting and to maintain a positive relationship between the institution and the site. The externship coordinators conduct an eight-hour Career Readiness Workshop to prepare students for the externship and job search. This workshop is considered as part of the externship, and the institution deducts these hours from the externship.

Although the institution has developed policies and procedures for the externship component of its four programs, the institution does not have a clearly defined syllabus on file that describes the externship course in customary syllabus format. The generic syllabus was not program-specific with regard to course description and course objectives.

The institution indicated in its response that it utilizes the weekly externship timesheet verification form along with weekly phone contact and periodic visits to extern sites as validation of student success and employer satisfaction. The externship site supervisor must complete an evaluation of student performance based upon criteria specific to the program.

Further, a new Career Readiness process has been implemented in which training occurs entirely during the didactic portion of the program. Students now receive training on professionalism, portfolio development, and job readiness skills throughout the program instead of using designated externship hours to fulfill these objectives. The institution has also updated all syllabi to include program specific course descriptions and objectives.

The institution indicated that each new site is visited during the first externship and, at minimum, annually afterwards.

Therefore, the institution must provide a narrative update on this issue, including a justification as to why an annual site visit is sufficient in determining the ongoing quality of an externship site. Educationally sound practice suggests that a closer connection to internship locations may enhance the learning experience for existing students (supporting higher completion rates) and raise the opportunity for employment opportunities for graduates (supporting increased placement rates).

Further, the institution is requested to provide a sample of no less than 20 completed weekly externship timesheets, including supervisor evaluations of student performance.

A copy of this report, including the attached interim report cover sheet, must be emailed to interimreports@ no later than June 29, 2012.

As a reminder, please be advised that late submission and receipt of documents and reports are subject to significant late fees in accordance with Commission policy. These fees are outlined in ACCET Document 10, which can be found at .

Neither deferral of reaccreditation or withdrawal of program approval are adverse actions and they are explained in ACCET Document 11 ? Policies and Practices of the Accrediting Commission, which is available on our website at . In accordance with Commission policy, no substantive changes including, but not limited to, new programs or major program revisions, new

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