A09R0003 - U.S. Department of Education’s Recognition and ...

U.S. Department of Education Office of Inspector General

U.S. Department of Education's Recognition and Oversight of Accrediting Agencies

June 27, 2018 ED-OIG/A09R0003

NOTICE

Statements that managerial practices need improvements, as well as other conclusions and recommendations in this report, represent the opinions of the Office of Inspector General. The appropriate Department of Education officials will determine what corrective actions should be taken.

In accordance with Freedom of Information Act (Title 5, United States Code, Section 552), reports that the Office of Inspector General issues are available to members of the press and general public to the extent information they contain is not subject to exemptions in the Act.

UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF INSPECTOR GENERAL

Audit Services

June 27, 2018

TO: FROM: SUBJECT:

Frank Brogan Delegated the Duties of Assistant Secretary for Postsecondary Education Office of Postsecondary Education

Bryon S. Gordon /s/ Assistant Inspector General for Audit

Final Audit Report, "U.S. Department of Education's Recognition and Oversight of Accrediting Agencies," Control Number ED-OIG/A09R0003

Attached is the subject final audit report that covers the results of our review of the U.S. Department of Education's (Department) recognition and oversight of accrediting agencies. We have provided an electronic copy to your audit liaison officers. We considered your comments on the findings and recommendations in our draft report.

Department policy requires that you develop a final corrective action plan within 30 days of the issuance of this report. The corrective action plan should set forth the specific action items and targeted completion dates necessary to implement final corrective actions on the findings and recommendations contained in this final audit report. Corrective actions that your office proposes and implements will be monitored and tracked through the Department's Audit Accountability and Resolution Tracking System.

In accordance with the Inspector General Act of 1978, as amended, the Office of Inspector General is required to report to Congress twice a year on the audits that remain unresolved after 6 months from the date of issuance.

We appreciate your cooperation during this review. If you have any questions, please contact Mr. Raymond Hendren, Regional Inspector General for Audit, Sacramento Audit Region, at (916) 9302399 or ray.hendren@.

Attachments

400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510 Promoting the efficiency, effectiveness, and integrity of the Department's programs and operations.

Table of Contents

Results in Brief .................................................................................................................... 1 Introduction ........................................................................................................................ 4 Finding 1. OPE Needs to Correct Weaknesses In Its Agency Recognition Petition Review Process ................................................................................................................................ 8 Finding 2. OPE Needs to Improve Oversight of High-Risk Agencies During the Recognition Period................................................................................................................................ 16 Appendix A. Scope and Methodology............................................................................... 19 Appendix B. Acronyms and Abbreviations........................................................................ 27 Appendix C. OPE Comments ............................................................................................. 29

Results in Brief

What We Did

The objectives of our audit were to assess (1) whether the U.S. Department of Education's (Department) process for recognizing accrediting agencies ensured that agencies met the Federal recognition criteria and (2) the extent that the Department monitored agencies during the period of recognition. The Department grants recognition to an accrediting agency (agency) for a period not to exceed 5 years (recognition period), if the Secretary of Education (or designee) recognizes the agency as a reliable authority regarding the quality of education or training offered by the schools or programs it accredits. The Accreditation Group within the Department's Office of Postsecondary Education (OPE) is responsible for reviewing agency petitions for recognition and monitoring agencies during the recognition period. In this report, we refer to OPE's monitoring during the recognition period, which comprises all oversight activities performed outside of the recognition petition review process, as "postrecognition oversight." Our audit covered OPE's procedures for evaluating an agency's qualifications at the time an agency petitions for recognition (initial or renewal) and OPE's post-recognition oversight of agencies. We also reviewed OPE's evaluations of five petitioning agencies (one initial petition and four renewal petitions), as well as any postrecognition oversight that OPE performed for these agencies. Our review covered January 2013 through June 2017.

What We Found

As of June 2017, OPE had a formal process for reviewing agency petitions for recognition that incorporated the petition review procedures required under Title 34, Code of Federal Regulations, Section 602.32 (34 C.F.R. ? 602.32).1 OPE maintained documentation supporting analysts' conclusions regarding agency compliance with recognition criteria for the five agency petitions we reviewed, but OPE's process did not provide reasonable assurance that the Department recognized only agencies meeting Federal recognition criteria. Specifically, we identified several weaknesses related to OPE's agency petition review process.

1 Required procedures under 34 C.F.R. ? 602.32 include analyzing an agency's recognition petition, submitting a written draft analysis to the agency identifying areas of noncompliance, soliciting feedback from the agency, and submitting a written final analysis of the agency (which includes a recognition recommendation) to the senior Department official for a recognition decision. All regulatory citations are from the 34 C.F.R. volume dated July 1, 2016.

U.S. Department of Education

Office of Inspector General

ED-OIG/A09R0003

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? OPE does not have adequate controls over the school information that agencies use as evidence to demonstrate that they have appropriate accreditation standards and effective mechanisms for evaluating school compliance with those standards before reaching an accreditation decision.

o OPE typically allows petitioning agencies to select the specific schools used as evidence of compliance. This can lead to an agency providing documentation for only the best examples of its school oversight activities ("cherry-picking"), which may not be indicative of the quality of the agency's actions for other schools it accredits.

o OPE allows petitioning agencies, regardless of their size, to submit supporting documentation for as few as two schools. Agencies of significantly different sizes may submit supporting documentation for the same number of schools, a number that may not be sufficient to demonstrate that an agency consistently applies and enforces its accreditation standards.

? OPE does not have written policies and procedures to guide analysts through the review of agency recognition petitions, which can and has led to inconsistencies across agency reviews and among OPE analysts regarding the number of schools and amount of documentation that is deemed necessary to demonstrate compliance with Federal recognition requirements.

We found that OPE's post-recognition oversight is not adequate to ensure agencies consistently and effectively carry out their responsibilities. OPE does not have an adequate plan for the post-recognition oversight of agencies and does not regularly perform reviews of high-risk agencies during the recognition period. OPE takes a reactive approach to post-recognition oversight and performs oversight activities for an agency only if it is alerted that compliance or other issues may exist at that agency. This could result in no oversight for some agencies, including newly recognized or higher risk agencies, for up to 5 years. In addition, OPE's oversight approach may not identify significant agency issues soon enough to mitigate or prevent potential harm to accredited schools, students, or taxpayers.

What We Recommend We recommend that the Assistant Secretary for OPE--

? Require the OPE Accreditation Group to use risk-based procedures and readily available information to identify which and how many schools each petitioning agency must use to demonstrate that it consistently applies and enforces its accreditation standards and otherwise complies with Federal recognition criteria.

U.S. Department of Education

Office of Inspector General

ED-OIG/A09R0003

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