!! 2227 Franklin St., Denver, CO 80205 americanpathways.edu American Pathways University COMMENTS Regarding the Basis for the Adverse Accreditation Decision December 28, 2017 American Pathways University understands that ACCSC adverse accreditation decision is based on an evaluation that APU did not demonstrate and document compliance with certain standards of accreditation in the view of the Commission, which is its province. We appreciate the opportunity to comment. Our summary format comments will include appropriate references to demonstration and documentation since Dr. Michale S. McComis letter informing APU of the Commission s decision often also makes such references as the Grounds for Denial of Initial Accreditation. We thank the Site Team for the following comments by the team leader during the exit interview. Thank you all for your hospitality and for your honesty in your responses. We felt like everyone was available to give us the information that you did have. We are grateful for that and for the materials presented. We would commend you on the population you are trying to serve. We feel very strongly it is an underserved population, so hats off to you for doing that in your approach, in your mission. It s something that we feel very strongly about. The other thing we would want to commend the school for is the student surveys. They were very positive. You got very, very high marks from your student base. That s another great thing to be able to say about your school. The student survey results are as follows: During the on- site evaluation, the team surveyed 26% of the enrolled student body and found 100% of those surveyed indicated they felt good about their decisions to attend the school and 100% would recommend the school to a friend. In addition, the following represent the summary student satisfaction in each major area from the survey: Admissions, 97%; Financial aid, 100%; Academic progress, 100%; Student services, 97%; Faculty, 100%; Library/Learning Resources System, 81%; Facility, 100%; Training equipment, 100%. While we respect the Commission s decision, we also believe that the full body of APU s required ACCSC submissions and the required site visit Resource Room documents, when considered together as a whole, produced sufficient demonstration and documentation to
2 warrant a different result. As such, the site visit Resource Room included almost 400 textbooks and library learning resource materials, 255 course syllabi and 2 school catalogs as required. Submissions prior to the site visit involved over 3250 pages, including: 1) the Initial Applications I and II, 2) the Self Evaluation Report (SER, i.e., Self Study), 3) two APU responses to the Site Team Summary Report (Responses 1.0 and 2.0), and 4) over 1500 pages of exhibits and documentation. We believe these demonstrate and document APU s improvement under ACCSC tutelage and compliance with accreditation standards. Apparently, ACCSC agrees that APU s programs are in compliance with about 97.6% of ACCSC standards. Of course 100% compliance is required. As for the remaining 2.4%, some appear to be a failure to utilize an ACCSC form as opposed to other forms of presenting data, reporting, or making submissions, which APU did not realize was an ACCSC Accreditation Standard for accreditation. As for the remaining issues, APU summarizes below its submissions and specifies locations of its submissions relative to ACCSC s Standards of Accreditation and the ten- point grounds for denial of initial accreditation as set forth in a letter dated December 14, 2017 from Dr. Michale S. McComis, ACCSC Executive Director. 1. Student Achievement Outcomes. Comment: APU agrees with the Commission that student achievement outcomes must be assessed and that is why APU voluntarily engaged an independent third party (Mr. Patrick J. Knapp) to verify the Graduation and Employment of APU alumni and the results were reported in the SER (i.e., Self Study), even though APU s application pre- dated such requirements according to ACCSC Standards of Accreditation. The 17- page Third Party G&E Report was accompanied by the following third party s certification letter describing how the survey was conducted:
3 The exhibits referenced in the above letter are: Exhibit A: ACCSC Guidelines for Employment Classification; Exhibit D: Graduation Rate Data for Each Program; and Exhibit E: Employment Rate Data for Each Program. While APU was not obligated to provide ACCSC Graduation & Employment Charts ( G&E Chart) because our application pre- dated the Standards of Accreditation regarding this matter, we nonetheless did so for all of its A.A., B.A., and M.A. programs (nine charts total), not just in the SER (Self Evaluation Report, i.e., Self Study) and not just for the 48 month Business program (ACCSC McComis Letter of 12-14- 17, p. 3). APU s certificate programs, while always being part of its curriculum as described in the Academic Catalog, were not included in our Application and the SER because we understood from the orientation workshop that while they would not be considered by ACCSC for accreditation a school could nonetheless offer such programs. During the Site Visit, two of ACCSC staff, who were also Site Team members, suggested that APU should expand the certificate programs and offer them for non- credit in order to serve those potential students in its service area who needed an opportunity to develop academic confidence and demonstrated college- level competence as a bridge to application and acceptance into one of APU s 14 degree programs. We followed this advice by expanding the number of certificate programs in parallel with APU s 9 degrees (i.e., 4 A.A., 4 B.A., and 1 M.A.). APU s Academic Catalog was revised accordingly and included in APU s Response 1.0. Demonstration: The Third Party Report demonstrates APU s graduation rates at 80% and employment rates at 100%. Examination of the three submissions of this report to ACCSC, as documented below, demonstrates no statistical discrepancies, nor with ACCSC G&E Charts mentioned above and documented below. Documentation: 1. The full 17- page Third Party G&E Report, including survey data was included in the SER Attachment A14.Third Party G&E Report (pp. 675-690). The full Report was also included in the first Response 1.0, Appendix Documentation 11, Third- Party G&E Survey of APU Alumni (pp. 191-207) and in the second Response 2.0, Documentation, Third- Party G&E Survey of APU Alumni (pp. 276-292), both as voluntary exhibits (exemplars) not required by ACCSC standards that applied to APU s application at the time. Also included in Response 2.0 on pages 293-295 is a chart of the results of the Third- Party s survey of all APU alumni as updated December 1, 2015. 2. The ACCSC G&E Charts were included in the SER, Attachment A13.G&E Program Charts, pp. 666-674. 3. The revised non- credit certificate program was provided to ACCSC via Response 1.0 as follows: Appendix: Documentation #15.Certificate Track Programs, p. 294 and Appendix: Documentation #27.APU Catalog (January 15, 2017 Edition), pp. 367-510 and pp. 419-420 (Catalog pp. 53-54). 2. Graduation and Employment Disclosure. Comment: APU agrees with the Commission that career information relative to APU s programs and graduation and employment data should be available to students and the public. That is why we have provided on the home page of the school s website (americanpathways.edu) a link to a page on Career Opportunities At- A- Glance that
4 provides information on APU s 9 degrees and 14 vocational specializations and the ABOUT US menu has a link to a page on Graduates and Placement that provides information on APU s graduation rate and endeavors to place its graduates. The reliability of our data and disclosures is verified in two ways: 1) a third party G&E survey as discussed above in section #1; and 2) APU s Alumni Office tracts graduate employment and/or graduate school studies via survey results for the first 90 days, first post- graduation year, and fifth post- graduation year. Demonstration: The Third Party G&E Report demonstrates APU s graduation rates at 80% and employment rates at 100%. These results are also corroborated by APU s alumni survey data. The APU website (americanpathways.edu) discloses graduation rates. Documentation: 1. The Third Party G&E Report is found as follows: 1) SER Attachment A14.Third Party G&E Report (pp. 675-690); 2) Response 1.0, Appendix Documentation 11, Third- Party G&E Survey of APU Alumni (pp. 191-207); 3) Response 2.0, Documentation, Third- Party G&E Survey of APU Alumni (pp. 276-292); and 4) Response 2.0 on pages 293-295 is a chart of the results of the Third- Party s survey of all APU alumni as of December 1, 2015. 2. The APU website (americanpathways.edu) disclosures are found as follows: 1) home page Career Opportunities At- A- Glance and 2) home page menu ABOUT US: Graduates and Placement. 3. The APU Alumni Office survey and data is found as follows: 1) SER Exhibit E7.Assessment Handbook: Post- Graduate & Activity Report, pp. 1718-1721 and APU Alumni Survey, pp. 1729-31; 2) Response 1.0: Appendix: Documentation: APU Alumni Office Graduate and Employment Record; and 3) Response 2.0: Documentation: Alumni Survey, pp. 311-320; 3. Admissions Requirements. Comment: APU agrees with the Commission that admission requirements are important and at a minimum a high school diploma is required. That is why, in order to address findings of the Site Team Report related to student matriculation, APU s Academic Catalog was revised and APU wrote a Department Director s Manual (with checklists for student admissions requirements, advisement, program progress, good standing, and graduation requirements) and tasked its five School Deans to contact all enrolled students in their departments in order to complete the checklists and bring their files up- to- date and suspend students whose files could not be completed according to APU policies, including a high school transcript. The results were summarized in both of APU s Responses. Demonstration: These improvements and student file updates were included in APU s Responses 1.0 and 2.0. The APU Academic Catalog that was included in APU s Response 1.0 included this statement and chart on page 85 under the heading Admission Requirements to Undergraduate and Graduate Programs : The application process is an opportunity to introduce yourself to APU so we may evaluate your potential for academic success to achieve personal and professional goals, character growth, and seriousness and dedication of purpose. A High school transcript, GED, or college transcript is required for admission. College entrance assessment instruments
5 (e.g., SAT, ACT, GRE), essays, recommendations, activities, work experience, and interviews may be used to evaluate applicant s placement and ability to benefit. Students must apply for admission and complete a Student File as follows prior to enrollment in classes. University Entrance Requirements Special Student Enrollment* Certificate Programs Associate of Arts Program Bachelor of Arts Program Master of Arts Program 1. Student Information Form X 2. University Application Form and Fee X X X X 3. Reference Letter (APU Alliance member, X X X X employer, or teacher) 4. Personal Narrative Essay (according to APU X guidelines) 5. Official High School Transcript (2.0 GPA X X X minimum) or GED 6. B.A. Transcript (2.5 GPA minimum) X 7. Official Transfer Credit Transcripts (if any) X X X 8. Proof of Income X X X X 9. Enrollment Agreement X X X X X 10. Student Matriculation Survey X X X X X 11. Complete Admissions Checklist Interview X X X X (with APU advisor) 12. University Acceptance Letter X X X X Documentation: Department Directors Manual, Response 1.0 (pp. 153-166) and Response 2.0 (pp. 335-384). 4. Enrollment Agreement. Comment: APU agrees with the Commission that an enrollment agreement should include financial matters and policies, including educational costs, tuition changes, and refund. That is why, while APU student enrollment policies are found in the Catalog and Student Handbook, we have added policy statements to the Enrollment Agreement (EA) regarding tuition, fee changes and refunds. These additions were included in APU s Response 2.0. Demonstration: An exemplar was provided by APU in the SER and following the site visit a revised ACCSC checklist and EA exemplar that meets all concerns of the Site Team s Summary (e.g., tuition changes and refund policies) was provided by APU in Response 2.0 (pp. 321-322). Documentation: SER A5.Attachment Enrollment Agreement, p. 436-537 and APU Response 2.0 Documentation Enrollment Agreement, p. 321-322. 5. Degree Programs. Comment: APU agrees with the Commission that didactic contact hours should be 15 per credit and supervised lab contact hours should be 45 per credit. That is why this is
6 the standard that all APU degree program courses must meet. Below is a summary of didactic and supervised lab contact hours for APU s 14 degree programs based on ACCSC Degree Program Outline Chart and APU Course Syllabi: A.A. Programs Didactic Hours Supervised Lab Hours B.A. Programs Didactic Hours Supervised Lab Hours Business 915 0 Business 1830-1740 0-135 Human Svcs 915 0 Human Svcs 1560 405 Management 915 0 Management 1830 0 Ministry 915 0 Ministry 1830-1740 0-135 Pro Dvlpmt 915 0 Pro Dvlpmt 1830 0 Psychology 915 0 Psychology 1830-1650 0-270 M.A. Program Didactic Hours Supervised Lab M.A. Program Didactic Hours Supervised Lab Ex Leadership 530 15 Pro Educator 530 15 We would conclude this section with a few comments regarding the quality control of our courses and course descriptions and syllabi. All courses and syllabi have been developed with extensive environmental scanning and consultation with experts, academicians, and vocational practitioners. Moreover, the process was supervised by our Vice President for Academic Affairs, a PhD with over 40 years of higher education and accreditation experience. Prior to coming to APU he had taught a myriad of college and graduate level courses, served as the Chief Academic Officer and President of a regionally accredited university, and was a curriculum developer and consultant of undergraduate, graduate, and continuing vocational education. He has authored a large number of course textbooks. Demonstration: ACCSC degree Program Outline forms were completed for all APU degree programs and available to ACCSC via the SER. These forms specified all program courses with didactic and supervised laboratory hours and are summarized in the APU Catalog. The Site Team was provided for its inspection in the site visit Resource Room nine three- ring notebooks of course syllabi: one notebook for each of APU s six A.A. and B.A. degree programs courses, one for the M.A. program courses, one for General Education courses, and one for elective courses, for a total of 255 courses. Each of the course syllabi utilize the same template as guided by the ACCSC Degree Program Outline Chart and summarized as follows: Course Schedule and Assignments* (See Note 5 to determine number of contact hours per class session) Explanatory notes for this Course Schedule and Assignments: (check if externship: and proceed to #6) 1. Orientation Class (OC): Mandatory attendance in order to enroll in the course. Students must give to the professor their email course registration confirmation in order to be added to the course roster and receive course credit. 2. Didactic Information: Essential factual information, including critical thinking & problem solving, is acquired from the professor & textbooks. Thirty-six minutes (60%) of a class hour are for delivery & acquisition of information. 3. Praxis Consideration: In-class application of must-know information. Twenty-four minutes (40%) of a class hour are used to discuss & apply didactic information to real-life/career situations, case studies, practical exercises, etc. 4. Class Preparation: Additional outside work is assigned based on 2 outside work hours of preparation for every classroom contact hour with the instructor. 5. Classroom Contact Hours: Each course credit requires 15 contact hours between professor and student. Use this formula to determine length of each class session: (credits x 15) number of class sessions = class session length. 6. Externship Contact Hours: Each externship credit requires 45 contact hours of on site experience. Use this formula to determine number of hours required for each externship: credits x 45 = externship minimum length. Use Didactic Information for externship topics and Praxis Consideration for hands-on externship experiences, and use the separate form titled Student Externship Syllabus and Report to plan, supervise, and assess a student s externship.
7 TOPICS, ISSUES, QUESTIONS ASSIGNMENTS No. Didactic Information 2 Textbooks Praxis Consideration 3 1 (OC 1 ) Pre-course test Course Introduction Student Responsibilities (See Addendum) Intro to textbook and learning materials 2 3 4 5 6 7 8 9 10 11 12 Course Review Review exercise 13 Final Test All Assignments Due Documentation: 1) The didactic and supervised lab hours of all 14 of APU s degree programs are found in the SER Attachments A.7.1- A.7.14 Program Outlines, pp. 545-604, for the A.A. (6), B.A. (6), and M.A. (2) that document the total hours as summarized in the #5 Comment section above; and 2) Response 1.0 (p. 105) and APU Catalog (p. 88 at Response 1.0, p. 454); 3) site visit Resource Room: 266 Course Syllabi for all APU programs and courses. A more comprehensive and in- depth presentation of APU s degree programs is found in the SER: Attachment: A15.Degree Applications (14), pp. 692-1179 and SER: Exhibit E15.Occupation Specialist (Appendix A), pp. 1898-2111. 6. Student Grade Reports. Comment: APU agrees with the Commission that students must be informed of their academic performance and satisfactory progress according to a degree plan. That is why course grade reports are required to be submitted to the Registrar s office within one week after the last day of a course, upon which they are entered into the student s database record and on the student s official transcript. Then during the month before the next term, the Dean or his designee of the school (Allied Health, Business, Management, Ministry, and Professional Studies) in which the student is seeking to earn a degree will sit with the student to work through three checklists (Course Advisement, Academic Progress, and Good Standing). It is during this appointment that the student will learn and review with the advisor his grades for the previous term and determine which courses to register for in the next term. Demonstration: Exemplars of APU s Course Roster and Grade Report form and APU s official transcript were provided to ACCSC and the Site Team. Since the site visit APU has developed a 43- page Department Directors Manual that provides policies and procedures for the school Deans and this was made available to ACCSC in APU s Responses. The Manual includes ten checklists, 5 of which are used by the Deans or their designee to guide their students from application to graduation. Three of these are mentioned in the comments section for reviewing with students their grades. We believe this personal approach is most beneficial for a student s educational success and completion of his/her degree plan within 150% of the standard time.
8 Documentation: Response 2.0: Documentation: 1) Department Directors Manual, pp. 335-377, including Course Roster and Grade Report form at 363-365; 2) APU Official Transcript at p. 165; and 3) Degree Plan exemplar at pp. 264-268. 7. Student Probation and Termination Policies. Comment: APU agrees with the Commission that probation and termination policies must be published in the school catalog. That is why such policies relative to academic performance and classroom deportment have always been included in APU s Academic Catalog and available to students and the public. Accordingly, APU s probation and termination policies are part of the student good standing section of the Catalog and stated as follows: Student Good Standing [that] involves various expectations along the continuum of a student s association with the University. These involve, but are not limited to, the student s application, entrance & placement, matriculation, financial accounts, financial aid, academic, graduation, and personal deportment. A student is in good standing if the minimum expectations are maintained. A student may be placed on probation when the minimum expectations or standards are not met and appeals or remedial activities are pending. A student may be disciplined, suspended, or expelled [i.e., terminated] for substantial or persistent substandard performance. A student may also be placed on probation or dismissed for violations of classroom decorum protocols (Catalog, p. 92) In addition, we have added a section to the catalog that applies these policies to APU s six student classifications (Catalog, p. 86). Demonstration: The pages in the Catalog and Student Handbook, available during the site visit, that state the student probation and termination policies (quoted above) were provided on the ACCSC Catalog Checklist form Item 19 at APU Catalog page 92, Student Good Standing Policies, as well as statements in the Student Handbook (pp. 124-137). Documentation: Such policies were stated in the APU Catalog exhibit of the SER that was examined by the site team and of the first Response. In the second Response 2.0 (p. 149) APU acknowledged the possibility of a further need for clarification to avoid any potential confusion as expressed by the Site Team Report. The APU Catalog was revised to include a student classification and suspension chart (p. 86) of the policy (p. 92) and was posted on the website (amiericanpathways.edu) and available to the public July 1, 2017. Notice of this revision was available to ACCSC via APU Response 2.0 Documentation Catalog Checklist, p. 232-324. 8. Faculty Work Experience. Comment: APU agrees with the Commission that real world work experience is vital for faculty in order to equip graduates for the world of work (one component of APU s outcomes triad the other two being introducing students to the world of ideas and preparing alumni for a life well lived). That is why APU has sought faculty that meet the ACCSC standard of 3-4 years of work experience in their teaching field. The faculty was recruited by APU s Vice President for Academic Affairs who kept a faculty employment journal of his first- hand verifiable knowledge over an extended period of time (beginning 40 years ago at other institutions and from 2001 to present at APU) of each and every APU faculty hire prior to and during their APU employment appointment,
9 both in terms of their teaching experience and real world field work experience. This is memorialized, not only in the journal but also in his professional personnel work files, compiled over his entire professional career as an higher education administrator. Such files are domiciled at the APU Office of Academic Affairs. In other words, the VPAA has been his own best faculty referral service because he has in his journal and faculty files 40 years of notations, certifications, and references for each APU faculty, including field work experience and college level teaching history. Demonstration: Drawing from the VPAA faculty personnel files at the APU Office of Academic Affairs and corroborating interviews, a review and an analysis was conducted for each faculty, including academic credentials (terminal transcripts) and real world work experience in their teaching field, as part of APU s self study evaluation and preparation for writing the SER. The results were included in the SER. Documentation: 1) SER: Faculty Qualifications: the academic credentials chart on pp. 241-242 and field work experience chart on pp. 244-253 provide summaries of faculty qualifications (academic credentials and field work experience); and 2) SER Exhibits: E9.Personnel Reports, pp. 2113-222 utilize ACCSC s format to provide specific in- depth academic and field work experience qualifications for each APU faculty. 9. Learning Resources. Comment: APU agrees with the Commission that appropriate and accessible learning materials are essential for students to learn. That is why APU has joined the Colorado Libraries Collaborate (CLC). It is essentially a consortium of 39 academic libraries of Colorado colleges and universities, such as the University of Colorado, with an aggregate of over 15,000,000 volumes. Students of member schools may access any of these volumes via the internet 24/7. The schools are listed alphabetically and APU is the second listing. APU s academic library contribution to the CLC is 5,642 academic volumes. Demonstration: APU s Program Learning Materials are listed in the SER and includes 386 textbooks. Most of these volumes were available to the site team in the Resource Room during the site visit, including 40 APU Press textbooks written by APU s faculty. Documentation: The complete list of APU authorized learning materials according to programs is in the SER: Attachments: A23.Learning Materials, pp. 1201-1217. Also see Response 2.0, p. 121 for an analysis of the academic fields of APU s 40 textbooks that are written by Faculty and are a part of APU s Colorado Libraries Collaborate repository of 5,642 volumes. ACCSC Substantive Standards: Standards of Accreditation, Section II (A) (7) (a) and (e) recognizes the use of a library consortia and interlibrary loan agreements, such as APU s membership in the Colorado Libraries Collaborate as a learning resource system, as follows: a learning resource system includes all materials that support a student s educational experience and enhance a school s educational program SUCH AS libraries; texts; electronic resources; learning resource laboratories and centers; LIBRARY CONSORTIA and interlibrary loan agreements; computers; internet access; research databases; and other similar resources and equipment. The learning resource system can be centralized or decentralized in organization but resources must be easily and readily accessible to students and faculty during and beyond classroom hours, regardless of location or means of delivery. (Capital letters and bold print are added for emphasis.)
10 10. Catalog Publication. Comment: APU agrees with the Commission that the school Catalog should include all of the items on ACCSC Catalog Checklist. That is why all such catalog checklist items have been included in APU s Academic Catalog from the date of APU s attendance of the orientation workshop and initial application during June 2013. The only exceptions are Checklist item numbers 31 and 32, which APU understands do not apply to any of APU s programs according to definitions provided by ACCSC Standards of Accreditation. Demonstration: From time- to- time the Catalog is updated and the latest version and ACCSC Catalog Checklist have been provided to the Commission, e.g., SER: Exhibit: E1.2015 Catalog, pp. 634-765 and SER: Attachment: A6.Catalog Checklist, pp. 439-440. Documentation: Catalog checklists are found in Response 1.0, pp. 352-353 and Response 2.0, pp. 323-324. Corresponding revised Academic Catalog is found in Response 1.0: Appendix: Documentation 27.APU Catalog (January 15, 2017 Edition), pp. 367-510.