September 8, 2016 BY CERTIFIED MAIL Mark Milioni, President Baptist Bible College 628 E. Kearney St. Springfield, MO 65803-3426 Dear President Milioni: This letter is formal notification of action taken by the Higher Learning Commission ( HLC or the Commission ) Board of Trustees ( the Board ) concerning Baptist Bible College ( the College or the institution ). During its teleconference meeting on August 31, 2016, the Board placed Baptist Bible College on Probation because the College is out of compliance with the Criteria for Accreditation and the Core Components identified in the Board s findings as outlined below. This action is effective as of the date the action was taken. In taking this action, the Board considered materials from the most recent comprehensive evaluation, including but not limited to: the Assurance Argument the College submitted, the report from the comprehensive evaluation team, the report of the Institutional Actions Council (IAC) Hearing Committee, and institutional responses to these reports including the most recent response filed by the institution on August 5, 2016.. The Board required that Baptist Bible College submit an Assurance Filing no later than November 1, 2017, or at least six weeks prior to the comprehensive evaluation, providing evidence that the institution has ameliorated the findings of non-compliance identified in this action that resulted in the imposition of Probation and the findings of Met with Concerns, and providing evidence that the College meets the Criteria for Accreditation, the Core Components, Federal Compliance Requirements, and the Assumed Practices. Included in this report should be evidence of the following: Core Component 4.A: all program reviews with assessment scheduled through 2017 have been completed along with a schedule of future program reviews beginning in 2018; Core Component 4.A: the institution clearly differentiates instruction and learning outcomes for dual-listed undergraduate and graduate courses, according to HLC policy; Core Component 4.A: assessment/curriculum committees are active as documented by a purpose statement and committee minutes; Core Component 4.B: sufficient faculty and staff are in place to fully implement assessment at all levels; Core Component 4.C: the institution has defined goals for student retention, persistence, and completion that are benchmarked with targets; Core Component 4.C: processes and methodologies for collecting, analyzing, and utilizing information on student retention, persistence, and completion of programs reflect good practice;
Mark Milioni, September 8, 2016 2 Core Component 5.A: there are clear definitions for enrollment management aligned with good practice in higher education and consistency of data; Core Component 5.C: the strategic plan has been updated to include action plans and budgetary implications and results for initiatives slated for 2017; and Core Component 5.C: an internal communication plan has been implemented and evaluated. The College will host a comprehensive evaluation no later than December 2017 to determine whether or not the College has ameliorated the findings of non-compliance that led to the imposition of Probation and whether or not the College meets the Criteria for Accreditation, and to make a recommendation about whether to remove Probation or take other action. The Board will review the documents associated with the evaluation at its June 2018 meeting to determine whether the College has ameliorated the findings of non-compliance and has demonstrated that it is now in compliance with all Criteria for Accreditation and thus whether Probation shall be removed, or if the College has not ameliorated the findings of noncompliance and demonstrated compliance with the Criteria for Accreditation, whether accreditation should be withdrawn. The Board based its action on the following findings made with regard to the College: The College is out of compliance with Criterion Three, Core Component 3.C, the institution has the faculty and staff needed for effective, high-quality programs and student services, for the following reasons: The College lacks the faculty needed for effective, high-quality programs and student support as required by this Core Component because it lacks sufficient faculty to carry out all of the duties of faculty including oversight of the curriculum, setting expectations for student performance, and involvement in assessment of student learning; while a plan for faculty evaluation was developed in 2011, it has not been implemented; and While the College has begun converting some part-time faculty members to full-time and hiring additional faculty members, it has not yet demonstrated that there are sufficient additional faculty members to assure that these non-teaching duties of faculty members are being regularly and competently completed. The College is out of compliance with Criterion Three, Core Component 3.D, the institution provides support for student learning and effective teaching, for the following reasons: Only one part-time faculty member was increased to full-time since the team s visit, even after it became clear the College was seriously under-staffed, and the IAC Hearing Committee remained concerned about the adequacy of current faculty staffing and the ability of the faculty to incorporate increased responsibilities for student advising with the current practice of faculty overloads; the IAC Hearing Committee heard no evidence to support the verbal commitment to increase the number of faculty owing to the constrained finances of the institution; and While the College has recently accelerated plans to hire additional faculty members, it has not yet demonstrated that it now has sufficient faculty to provide appropriate support for student learning and effective teaching. The College is out of compliance with Criterion Four, Core Component 4.A, the institution
Mark Milioni, September 8, 2016 3 demonstrates responsibility for the quality of its educational programs, for the following reason: The College has not demonstrated responsibility for its programs as required by this Core Component because the institution has not implemented a process of regular program review, differentiated adequately between undergraduate and graduate instruction in dual-listed courses, or implemented a faculty governance structure that includes assessment or curriculum committees. The College is out of compliance with Criterion Four, Core Component 4.B, the institution demonstrates a commitment to educational achievement and improvement through ongoing assessment of student learning, for the following reasons: The College has not demonstrated a commitment to assessment of student learning as required by this Core Component because the institution lacks sufficient faculty and staff to fully implement program review or assessment of student learning at all levels, throughout the institution; and While the College has recently initiated a new College Participatory Governance Plan with multiple committees to begin to address oversight of the curriculum, program review and related challenges, the institution has not yet documented the new structure's effectiveness in implementing program review and related challenges. The College is out of compliance with Criterion Five, Core Component 5.A, the institution s resource base supports its current educational programs and its plans for maintaining and strengthening their quality in the future, for the following reasons: The College has not demonstrated that it has the financial resources to support its programs and its plans for maintaining and strengthening their quality nor has it demonstrated appropriate financial practices in this regard because: o It regularly represents its financial circumstances with inconsistencies in data (e.g., 2014 and 2015 enrollment data); o Its ability to manage its finances effectively has been challenged in recent audited financial statements that question whether the College is a going concern; this has been accompanied by numerous warnings of not meeting expected Financial Indicators; o It has revised its business processes and overall budgeting, but this still does not include major constituencies or stakeholders across campus, nor does it result in a consistent balanced budget over time; o It has refinanced a long-standing outstanding loan at a lower interest rate, but the financial savings are inadequate to offset the serious financial needs and operational demands of the institution; The College also has not demonstrated that it has the appropriate physical and campus resources as required by this Core Component because several of its campus buildings have been closed to consolidate usage owing to a smaller student census and to save financial resources needed to address upkeep and structural concerns; and While these and other measures undertaken by the College indicate that the College is attentive to this issue, the institution s financial resources remain unstable until it develops a more stable long-term approach to institutional finances and advancement.
Mark Milioni, September 8, 2016 4 The College is out of compliance with Criterion Five, Core Component 5.B, the institution s governance and administrative structures promote effective leadership and support collaborative processes that enable the institution to fulfill its mission, for the following reasons: The College has not demonstrated practices consistent with effective governance and administrative structures as required by this Core Component because: o It does not possess explicit policies or processes that specifically make it possible for broad participation in campus-wide planning that leads to decision making in strategic planning, budgeting, and curricula; o It has not developed a strategic plan that includes action plans and budgetary implications, as well as expected desired results for initiatives slated for 2017; in addition, improvements in communication need to be implemented and evaluated; and o It does not have a trustee handbook for the Board, a faculty senate, or an academic curriculum committee; consequently, the College does not have common or consistent policies or procedures appropriate for effective shared college governance. The College is out of compliance with Criterion Five, Core Component 5.C, the institution engages in systematic and integrated planning, for the following reasons: The College is not engaging in a regular and effective process of planning as required by this Core Component because: o A strategic planning committee was established in March 2015 and, given the struggle for institutional stability and operating resources, no actionable plans have been formulated or ratified by the College s stakeholders; o Because program review and academic assessment policies and procedures do not exist, no data from these essential core functions are available to inform the strategic planning committee; and o No Campus Facilities Master Plan exists; rather, the Director of Facilities keeps a prioritized list of needs, more as a form of crisis management than planning; and While the new College Participatory Governance Plan with multiple committees will be working on planning and improvement, this approach has not yet demonstrated that the institution has solved the problems regarding planning and improvement. The College is out of compliance with Criterion Five, Core Component 5.D, the institution works systematically to improve its performance, for the following reasons: The College has not demonstrated that it works systematically to improve its performance because: o it has not executed a realistic, rational, and proactive strategic plan; it cannot therefore base financial or academic judgments upon a set of defined priorities; o it does not gather or analyze data conventionally, making it difficult for it to make objective data-based decisions that would improve its outcomes; and o it is limited in its ability to utilize data for institutional effectiveness given current vacancies in staff with skills in this area, and the current strategic plan needs to be implemented in ways that allow its outcomes to be tracked, measured, and analyzed.
Mark Milioni, September 8, 2016 5 The College meets Criterion Two, Core Component 2.C, the governing board is sufficiently autonomous to make decisions in the best interest of the institution and to assure its integrity but with concerns for the following reasons: The Board of the College has not demonstrated that it functions autonomously from its denomination; and The College website is not regularly and appropriately updated to list the current board membership. The College meets Criterion Four, Core Component 4.C, the institution demonstrates a commitment to educational improvement through ongoing attention to retention, persistence, and completion rates, but with concerns for the following reasons: The College lacks consistency in its definition, reporting, and utilization of data; the administrative hierarchy does not understand that the data it has are insufficient to use for effective planning, has not provided direction to increase the professional qualifications of staff in this regard, and has not demanded the collection and analysis of accurate data to use in planning; and The College has annual goals for student retention, persistence, and completion, but these goals are not benchmarked with targets beyond those that show incremental growth for the next academic year and the annual goals are not part of a larger enrollment management plan and strategy, neither of which has been established by the College. At its June 2016 meeting, the Board approved informing Baptist Bible College that the Board had identified areas where the College is not in compliance with the Criteria for Accreditation and that the Board intended to place the University on Probation, but provided the University thirty days to submit any additional information prior to taking action. The College s August 2016 response indicated that, although the College appears to understand the issues related to its compliance with the Criteria for Accreditation and to be taking steps to remedy them, it is not in compliance with the Criteria for Accreditation until such time as the plans have been fully implemented and have demonstrated evidence of success in resolving the issues HLC has identified. The Board action resulted in changes to the affiliation of the College. These changes are reflected on the Institutional Status and Requirements Report. Some of the information on that document, such as the dates of the last and next comprehensive evaluation visits, will be posted to the HLC website. At this time, the Commission will reassign Baptist Bible College from its liaison, Dr. Jeffrey Rosen, to Dr. Anthea Sweeney. If you have any questions or concerns about the information in this letter, please contact Dr. Sweeney. Please be assured that Dr. Sweeney will work with Dr. Rosen to create a smooth transition. Information about the sanction is provided to members of the public and to other constituents in several ways. HLC policy INST.G.10.010, Management of Commission Information, anticipates that HLC will release action letters related to the imposition of a sanction to members of the public. HLC will do so by posting this action letter to its website. Also, the enclosed Public Disclosure Notice will be posted to HLC s website not more than 24 hours after this letter is sent to you.
Mark Milioni, September 8, 2016 6 In addition, HLC policy COMM.A.10.010, Commission Public Notices and Statements, requires that HLC prepare a summary of actions to be sent to appropriate state and federal agencies and accrediting associations and published on its website. The summary will include the HLC Board action regarding the College. HLC will simultaneously inform the U.S. Department of Education of the sanction by copy of this letter. HLC policy INST.E.20.010, Probation, subsection Disclosure of Probation Actions, requires that an institution inform its constituencies, including Board members, administrators, faculty, staff, students, prospective students, and any other constituencies about the sanction and how to contact HLC for further information. The policy also requires that an institution on Probation disclose this status whenever it refers to its HLC accreditation. HLC will monitor these disclosures to ensure they are accurate and in keeping with HLC policy. I ask that you copy Dr. Sweeney on emails or other communications regarding the sanction and provide her with a link to information on your website and samples of related disclosures. If you have questions about any of the information in this letter, please contact Dr. Sweeney. On behalf of the Board of Trustees, I thank you and your associates for your cooperation. Sincerely, Barbara Gellman-Danley President Enclosure: Public Disclosure Notice cc: Chair of the Board of Trustees, Baptist Bible College Gregory Christopher, Vice President of Academic Affairs, Baptist Bible College Anthea Sweeney, Vice President for Accreditation Relations, Higher Learning Commission Jeffrey Rosen, Vice President for Accreditation Relations and Director of the Open Pathway, Higher Learning Commission Karen L. Peterson Solinski, Executive Vice President for Legal and Governmental Affairs, Higher Learning Commission Herman Bounds, Accreditation and State Liaison, Office of Postsecondary Education, U.S. Department of Education