National Coordinating Center Accreditation Workgroup Report to

National Coordinating Center Accreditation Workgroup Report to the National Advisory Committee on Institutional Quality and Integrity February 23, 2017

Report on Model Accreditation Standards for Higher Education Programs for Students with Intellectual Disability: A Path to Education, Employment, and Community Living Presented on behalf of the Accreditation Workgroup by: Stephanie Smith Lee, Accreditation Workgroup Chair Meg Grigal, Ph. D. Senior Research Fellow, UMASS Boston Principal Investigator, Think College National Coordinating Center

Presentation Overview Background on inclusive higher education Higher Education Opportunity Act of 2008 provisions Purpose, role and membership of Accreditation Workgroup Review key aspects of Accreditation Report Next steps for new workgroup Discussion

Definition of intellectual disability (Higher Education Opportunities Act, 2008) “A student— ‘‘(A) with intellectual disability or a cognitive impairment, characterized by significant limitations in— ‘‘(i) intellectual and cognitive functioning; and ‘‘(ii) adaptive behavior as expressed in conceptual, social, and practical adaptive skills; and ‘‘(B) who is currently, or was formerly, eligible for a free appropriate public education under the Individuals with Disabilities Education Act."

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Need for Inclusive Higher Education for Students with Intellectual Disabilities (ID) Historically bleak education, employment, and community outcomes People with ID are typically: Unemployed or working in subminimum wage jobs in sheltered workshops Living with aging parents and little productive work or activities. Prior to 2008, few higher education programs for students with ID No federal financial aid or federally-funded technical assistance, and no model programs.

Higher Education Opportunity Act of 2008 (HEOA) Provisions Related to Students with Intellectual Disability (ID) Model Demonstration Programs: Transition and Postsecondary Programs for Students with Intellectual Disability (TPSIDs) authorized to enable institutions of higher education (IHEs) to create or expand high-quality inclusive programs for students with ID. National Coordinating Center (NCC): Authorized to provide technical assistance, coordination between and evaluation of TPSID projects, and create recommended model standards for programs through an Accreditation Workgroup. Federal Student Aid: Eligibility for Pell grants, Federal Supplemental Educational Opportunity Grants and Work-Study jobs.

Model Demo (TPSID) Funding In FY2010, US ED awarded 10.5 million to 27 IHEs for first year of five-year TPSID grants. TPSID grants at 52 college and university campuses located in 23 states. NCC cooperative agreement awarded to Think College at UMASS Boston. In FY 2015, 9.8 million awarded to 25 IHEs in 19 states to implement additional TPSID projects. NCC awarded to Think College at UMASS Boston.

National Coordinating Center Evaluation Activities The NCC 5-year evaluation of the 2245 students served by the 57 IHEs hosting TPSID programs reflected positive outcomes in inclusive class enrollment, credentials attainment, and employment during and after participation.

2010-2015 TPSID Outcomes 2,245 students attended programs at 58 campuses implementing 27 model demonstration grants There were over 23,000 enrollments into courses Overall, 45% of all course enrollments across the 5 years of data collection were in typical college classes 846 students worked in a paid job while also attending the program Nearly 1,500 students (68%) participated in pre-employment career development activities, e.g. internships, service learning Over 1,000 students earned a credential upon exiting (Grigal, Hart, Smith, Domin, & Weir, 2016

Financial Aid Access Students with ID must: Have exited high school Meet the HEOA definition of “intellectual disability” Be enrolled in a comprehensive transition and postsecondary program for students with intellectual disability (CTP) Fill out the FAFSA and demonstrate financial need. https://studentaid.ed.gov/sa/eligibility/intellectual-disabilities

Comprehensive Transition and Postsecondary Program (CTP) A degree, certificate, or non-degree program: Designed to support students with ID who are seeking to continue academic, career and technical, and independent living instruction at an institution of higher education Must meet the CTP definition in HEOA (minimum 50% inclusion, advisory structure, etc.) Approved through a process administered by the US ED Office of Federal Student Aid (FSA)-- a US ED requirement not in HEOA.

Why model program accreditation standards? Model accreditation standards will: Provide guidelines and benchmarks for colleges and universities on how to develop and improve programs. Validate programs within IHEs. Give students and their families an assurance of quality. Promote higher education access and resulting competitive integrated employment and community living.

Questions? Who the students are? Alphabet soup of acronyms? Department of Education role? Why this innovation is important? Other?

HEOA Accreditation Workgroup Requirements: National Coordinating Center must: J) convene a workgroup to develop and recommend model criteria, standards, and components of such programs as described in subparagraph (E), that are appropriate for the development of accreditation standards, which workgroup shall include— (i) an expert in higher education; (ii) an expert in special education; (iii) a disability organization that represents students with intellectual disabilities; (iv) a representative from the National Advisory Committee on Institutional Quality and Integrity; and (v) a representative of a regional or national accreditation agency or association. 20 U.S.C. §1140q(b)(5)

HEOA Requirements: Role of workgroup (E) develop recommendations for the necessary components of such programs, such as— (i) academic, vocational, social, and independent living skills; (ii) evaluation of student progress; (iii) program administration and evaluation; (iv) student eligibility; and (v) issues regarding the equivalency of a student’s participation in such programs to semester, trimester, quarter, credit, or clock hours at an institution of higher education, as the case may be;

HEOA Requirements: Report (6) REPORT.—Not later than five years after the date of the establishment of the coordinating center under this subsection, the coordinating center shall report to the Secretary, the authorizing committees, and the National Advisory Committee on Institutional Quality and Integrity on the recommendations of the workgroup described in paragraph (5)(J).

Report on Model Accreditation Standards for Higher Education Programs for Students with Intellectual Disability http:// Available: www.thinkcollege.net/images/ stories/acc%20accrediation %20report F.pdf

Workgroup Preparation 15 workgroup members w/ diverse expertise as required by HEOA Quarterly meetings commenced March 2012 Sought Expert Consultation from US DOE provided background on FSA CTP approval process the role of NACIQI Researched accreditation issues relating to programs for students with ID Analyzed relationship of model standards to existing laws and regulations

Alignment with ED Accreditation Regulations Workgroup followed the recommendation of experts to align the model standards to the U.S. Department of Education (US ED) accreditation regulations http://www2.ed.gov/ admins/finaid/accred/index.html Decision made to draft standards for each of the areas covered by US ED accreditation regs: mission; student achievement; curriculum; faculty; facility, equipment & supply; administrative and fiscal capacity; student services; length and structure of program of study; student complaints; program development; and planning and review.

Developing Draft Model Standards Draft standards were developed and compared to: U.S. Department of Education accreditation regulations Commission on English Language Programs Accreditation (CEA) regulations(http ://cea-accredit.org/about-cea/standards) Think College Standards of Quality, Indicators and Benchmarks ( http://www.thinkcollege.net/resources-database/item/t-110/1542) Comprehensive Transition Program (CTP) laws and regulations, and the FSA approval process

Public Input Sought Comprehensive plan developed for seeking public input. Key questions: Are the standards clear? Should anything be changed? Have we missed anything? Do they reflect an acceptable level of quality? What should be included in the accompanying guidance?

Methods of Public Input Public input sought from array of stakeholders through various methods. Presentations and input sessions at 8 national conferences, TPSID Project Directors meetings, and on webinars. Feedback was obtained from 705 people. Survey questions on each standard and space for specific suggestions. The 207 respondents from across the country included parents of students with ID, college students, K-12 professionals, higher education professionals, and others. Public comment received from 912 people.

Public Input Results The draft standards were generally considered clear and sufficient. Wording changes suggested to enhance clarity, and several revisions suggested. Recommendations were given for a guidance document to accompany the standards. Recommended to include sections of HEOA law and regulations and the definition of “competitive integrated employment” from the Workforce Innovation and Opportunity Act (WIOA). (This was done.) Many families expressed strong opinions about the standards, especially the importance of inclusion, family engagement, the need for advice and individual support for students in a variety of areas (such as academics, career and work, campus life, housing, etc.), and family involvement in a program advisory committee.

Response to Public Input and Finalizing the Standards A comprehensive document summarized public input. Workgroup used this document to consider all public input, finalize the standards, and develop recommendations for the discussion sections, guidance, and next steps. Input from subject matter experts was also sought and considered. Model standards were developed in each of the areas covered in the US ED accreditation regulations. Standards are in the report along with discussion, guidance, and next steps.

Next Steps: Plans for New Workgroup Think College has again been awarded the US ED grant to be the National Coordinating Center and a new Workgroup has begun work. (Still need NACIQI and an accrediting agency representative.) The new Workgroup will: Transmit the report as required to the Secretary of Education, Congressional committees, and NACIQI. Broadly disseminate the report through presentations at conferences, meetings, and the Think College website Conduct outreach to accrediting agencies to share the report and ascertain interest in accreditation of CTP programs. Develop a technical guidance document to support implementation of the model accreditation standards.

Next Steps: Plans for New Workgroup Develop and implement a plan to work with the field on guidance and a protocol for implementing the standards (field testing). Research and consider feasibility of creating a new accrediting agency. Update recommendations for the model standards if needed due to working with the field, public input, or changes to the Higher Education Act or other relevant laws that could impact the standards, such as WIOA or IDEA.

Recommendations to the Dept. of Education Consider the role of the FSA approval process for CTPs, if any, once program accreditation is implemented. Guidance to school districts, comprehensive transition programs, and families about the determination of “intellectual disability” with respect to admissions, and financial aid under HEOA. While included in the HEOA Title IV regulations, there is some confusion about these issues. Support collaboration with and channels of communication among accreditation agencies and the Workgroup. Fund the development and dissemination of resources and strategies to use in assessing student progress in traditional courses. Such resources and strategies are needed to determine student progress in all areas (academic, career or technical, and independent living).

Next Steps for Specific Standards Develop guidance regarding situations in which staff work for an outside entity, such as a non-profit organization or school systems. Further research on the impact of student status on access to facilities and on participation in services, social and recreational activities, and how the accreditation process affects this issue, and best-practice guidelines. Develop guidance for advisory group membership, roles, and responsibilities, including the meaningful engagement of parents and students with intellectual disability. Develop informational materials and strategies to support the development of fiscal sustainability plans.

Next Steps for Specific Standards Address what period of time should be considered “reasonable” to retain records related to eligibility for federal student aid and admissions. Develop recommendations about academic and nonacademic advising important to students, and options for how such advising should be provided and by whom. Seek clarification on the role of guardianship with respect to the Family Educational Rights and Privacy Act (FERPA).

Challenges Challenges to moving forward include encouraging one or more accrediting agencies to use the standards. No one “logical” program accreditor for CTPs has been identified, since CTPs are located in various places within an institution of higher education, such as: general education or special education departments the disability services office continuing education University Center for Excellence in Developmental Disability (UCEDD), etc. Some experts have recommended starting a new agency to accredit these programs. However, that is potentially an expensive and complex process.

Discussion and Questions Questions about Workgroup role, report, etc.? Recommendations? Contact us: [email protected] [email protected]

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