Middle States Commission on Higher Education 3624 Market Street, Philadelphia, PA 19104-2680 Phone: 267-284-5000 Fax: 215-662-5501 www.msche.org Middle States Commission on Higher Education Verification of Compliance with Accreditation-Relevant Federal Regulations (Institutional Report Template) The Middle States Commission on Higher Education, as a federally recognized accreditor, is obligated to ensure that its candidate and member institutions comply with accreditation-relevant federal regulations. This document is focused on the Commission s verification of institutional compliance in four areas: 1. Student identity verification in distance and correspondence education 2. Transfer of credit policies and articulation agreements 3. Title IV program responsibilities 4. Assignment of credit hours In the event that one or more of these regulations do not apply to an institution, that institution shall indicate that fact in the compliance document. Otherwise, all accredited and candidate institutions should respond with regard to each of the areas. These areas may also be reviewed as part of the self-study or periodic review process, especially as they relate to the MSCHE Standards. Please note that as additional guidance is received from the U.S. Department of Education, these guidelines may be modified. NOTE: The template should be used to submit documentation as noted. The information boxes expand as information is inserted. Appendices must be bookmarked in the document. Save the file as a PDF to upload to the MyCHE portal. MSCHE Verification of Compliance, Institutional Report 1
The following report provides a review of institutional materials submitted by (NAME OF INSTITUTION) to document compliance with accreditation-relevant federal regulations. This report provides verification to the Commission of institutional compliance in the following areas: 1. Student identity verification in distance and correspondence education 2. Transfer of credit policies and articulation agreements 3. Title IV program responsibilities 4. Assignment of credit hours Student Identity Verification in Distance and Correspondence Education In accordance with 34 CFR 602.17(g), the Commission must verify that institutions have effective procedures in place to ensure that the students who register in a distance or correspondence education course are the same students who participate in and complete the course, and receive the academic credit. Institutions must provide the following documentation: 1. Written description of the method(s) used to ensure student identity verification in distance or correspondence education courses. Include information related to the Learning Management System (LMS) and integration with college-wide systems. Students are assigned a unique username and password that provide access to our OLMS from anywhere in the world with a web browser. They are verified using various personal data that is on file with the university. Students then login with these credentials once verified and maintain an authenticated session through their browser, providing access to their course content. Baruch College complies with the methods directed by the City University of New York to confirm student identify verification for distance education courses. Baruch College does not offer correspondence courses. The majority of online courses taught at Baruch College feature in-person examinations; members of the faculty are encouraged to verify the identities of their students via College-issued id card. Most distance education courses at Baruch are hybrid courses, which require a significant amount of interactivity via both online activities and face-toface meetings. In both online and hybrid courses students are writing extensively, which provides faculty members with ample opportunities to learn and engage with the voices, personalities, capabilities, and prior knowledge of their students. This familiarity helps faculty members identify assignments and assessments that are outside patterns that students have previously established. All faculty at Baruch College are expected to feature a statement on academic integrity on their syllabi, and faculty teaching online and hybrid courses are asked also to include on their syllabi a guide to learning and assessment in these instructional modes. Faculty members are able to have students submit written assignments to Turnitin.com for assessments of their work s originality. MSCHE Verification of Compliance, Institutional Report 2
2. Written procedure(s) regarding the protection of student privacy in the implementation of such methods. Include information related to the Family Education and Privacy Rights Act (FERPA) and student record access and process for resetting student passwords. Student record privacy for distance education as well as traditional courses is overseen by Baruch s FERPA and Blackboard policy. http://www.baruch.cuny.edu/bctc/blackboard/student/index.htm and hhttp://www.baruch.cuny.edu/registrar/ferpafaq.htm and https://mypassword.baruch.cuny.edu/ 3. Written procedure(s) for notifying students about any projected additional charges associated with student identity verification such as proctoring fees. Baruch College does not levy additional charges pertaining to student identity verification. 4. Written procedure(s) indicating the office(s) responsible for the consistent application of student identity verification procedures. The Baruch College Computing and Technology Center (BCTC) and the City University of New York s Office of Computing and Information Services (CIS) are principally responsible for student verification procedures pertaining to distance education courses. Transfer of Credit Policies and Articulation Agreements In accordance with 34 CFR 602.24(e), the Commission must confirm that an institution has transfer of credit policies that: (1) are publicly disclosed in accordance with section 668.43(a)(11); and (2) include a statement of criteria established by the institution regarding the transfer of credit earned at another institution of higher education. Section 668.43(a)(11) states: (a) Institutional information that the institution must make readily available to enrolled and prospective students under this subpart includes, but is not limited to- (11) A description of the transfer of credit policies established by the institution which must include a statement of the institution s current transfer of credit policies that includes, at a minimum (i) Any established criteria the institution uses regarding the transfer of credit earned at another institution; and (ii) A list of institutions with which the institution has established an articulation agreement. In addition, the Commission must confirm that any articulation agreements with other educational institutions are readily available to current and prospective students. Institutions must provide the following documentation: MSCHE Verification of Compliance, Institutional Report 3
1. Written policies and procedures for making decisions about the transfer of credits earned at other institutions, including all modes of delivery. Undergraduate Evaluation of Transfer Courses The Transfer Center at Baruch College processes credit evaluations for all newly admitted transfer students prior to attending their required new student orientation program. Academic records are evaluated for transfer course equivalencies after a student has been admitted and has reserved their seat in the upcoming class, by submitting a $100 commitment deposit. The records are then reviewed on a course-by-course basis to determine course equivalencies. Every effort is made to accept the maximum number of credits possible. Credit evaluations are provided to the students during their orientation program. Transfer of Credit Policy: In general, credits earned by taking college-level courses from other regionally accredited colleges and universities will transfer, provided that the courses are similar in scope and content to those offered for credit at Baruch College. Credits will be granted for courses with a grade of "C" or better ("D-" or better at CUNY institutions). The Transfer Center collects academic department evaluations for non-cuny schools and records them in a database. CUNY to CUNY course equivalencies are maintained in the TIPPS (Transfer Information and Program Planning System) database and can be found on the CUNY website. Students who are awarded elective credits have the ability to petition to have the course reviewed for an actual course equivalent at Baruch. If the student believes the course may fulfill a major, minor, pre-requisite or general education course requirement, they can obtain a course equivalency. In order to obtain a course equivalency, the student submits a course description or syllabus from the previous institution to the appropriate academic department. The departmental advisor will determine if the course has a Baruch College equivalent or if it can be used to satisfy a general education requirement. This process is handled internally by the Transfer Center. The following courses do not transfer: ESL/Remedial/Developmental courses; Freshman Orientation/experience courses; military training; secretarial/office technology courses; hospitality management; courses used to satisfy high school graduation requirements, among others. Credit Given by Exam: Credits and course exemptions are given to students who present a satisfactory score of 4 or 5 on the College Board's Advanced Placement program. An official score report must be sent from the College Board to the Admissions Office for an evaluation. For the exams and scores recognized by Baruch College, please see attachment: AP Equivalency Sheet. Baruch College recognizes and awards credit for International Baccalaureate higher-level (HL) exams with scores of 5 or better for yearlong courses (No credit will be given for Standard Level Exams). Official IB and AP scores must be sent to the Office of Admissions. Updated official college transcripts, which include courses taken via the CUNY College Now program, should also be sent to: Baruch College MSCHE Verification of Compliance, Institutional Report 4
Transfer Center Office of Undergraduate Admissions One Baruch Way, Box H-0725 New York, NY 10010 Pathways Curriculum: As of fall 2013, Pathways, the CUNY-wide general education set of requirements, was implemented. It is designed to facilitate transfer of general education courses throughout the CUNY system, particularly for CUNY community college students to senior colleges within the system. Pathways is comprised of three elements. The Common Core is 30 credits of courses that meet a common set of learning outcomes in a number of broad areas of learning. The Flexible Common Core is a set of six courses students select from five different subject areas. And the College Option is a set of 6-12 additional credits that individual senior colleges designate. At the same time that Pathways was being designed, CUNY colleges were required to identify Gateway courses into common majors throughout the system. Students who take these courses at one CUNY college have their credits automatically transferred to their equivalents at the receiving college. The Transfer Center takes the following into account when evaluating transfer credits for students transferring from another CUNY college: Courses that fulfill a Required Common Core requirement at any CUNY college will transfer for Required Common Core credit at any other CUNY college. Courses that fulfill a Flexible Common Core requirement at any CUNY college will transfer for Flexible Common Core credit at any other CUNY college. Courses that fulfill a College Option requirement at any CUNY college will transfer for College Option credit at any other CUNY college. Courses that are designated as "Gateway" courses into a major will transfer for major credit at any other CUNY college that offers the major. Requirements for Students who Already Hold Degrees Students who have earned a Bachelor s, Associate in Arts, or Associate in Sciences degree from an accredited and recognized institution of higher education and who transfer to a CUNY college (whether from a CUNY or non-cuny institution) will be deemed to have automatically fulfilled the Common Core requirements for a CUNY degree. Students with AAS degrees (whether from CUNY or non - CUNY institutions) who transfer to a CUNY bachelor s degree program will need to complete any areas of the Common Core that they did not complete when obtaining their AAS degree, and they must also complete six College Option credits Students who have earned a Bachelor s degree from an institution that is accredited and recognized by a regional accrediting U.S. agency who transfer to a CUNY baccalaureate college will be deemed to have automatically fulfilled the College Option as well as the Common Core. Students from international universities with degrees that are equivalent to a MSCHE Verification of Compliance, Institutional Report 5
baccalaureate degree as determined by CUNY will be deemed to have automatically fulfilled the College Option as well as the Common Core. If CUNY colleges have questions about a particular institution s standing, they may consult with the Office of Academic Affairs. Students with associate degrees (two-year degrees) of any type from foreign institutions must have their credits evaluated on a case by case basis, as two-year degrees are highly variable across countries. 2. Public disclosure of the policy for transfer of credit. Document the URL and the catalog location of this information; include other publications, if available. Transfer Students Guide: http://www.baruch.cuny.edu/advisement/docs/transferorientationguidebook.pdf Transfer Credit Evaluations: http://www.baruch.cuny.edu/transfer/admissions/transfer_credit_evaluation/ Pathways At Baruch: http://www.baruch.cuny.edu/genedreqs/pathwaysatbaruch/ Pathways Guidelines: http://www.cuny.edu/academics/initiatives/pathways/about/policies/guidelines_5_24_13_final_updated_4_1_14.pdf E-Permit Policies: http://www.cuny.edu/academics/initiatives/pathways/about/policies/epermit_policies_12_10_13_final.pdf Baruch College Bulletin: http://www.baruch.cuny.edu/bulletin Outgoing Permit Student Information: http://www.baruch.cuny.edu/registrar/documents/outgoingpermitapplication.pdf 3. Procedures that indicate the office(s) responsible for the final determination of the acceptance or denial of transfer credit. When evaluating undergraduate courses for transfer credit, the respective academic departments are responsible, ultimately, for the determination of how transfer credits are awarded for each course. The Transfer Center is responsible for collecting these evaluations and posting the credits to the student s transcript in CUNYfirst (CUNY s student information system). The Registrar s Office is responsible for posting e-permit course credit to the student s transcript in CUNYfirst. MSCHE Verification of Compliance, Institutional Report 6
4. A published and accessible list of institutions with which the institution has established an articulation agreement. Document the URL and publication location of this information. School of Public Affairs Articulation Agreements: http://www.baruch.cuny.edu/spa/admissions-and-advisement/academic-advisement/ Title IV Program Responsibilities In accordance with 34 CFR 602.16(a)(1)(x), the Commission must review the institution s record of compliance with its Title IV program responsibilities to determine if that record suggests the institution may not be in compliance with Commission standards and requirements. The Commission is particularly interested in reviewing significant deficiencies and material weaknesses that have been identified and any corrective action plans that have been developed to address those deficiencies and material weaknesses. Institutions must provide the following documentation: 1. Formal documentation from the U.S. Department of Education regarding the institution s cohort default rate for the three most recent years. Provide the most recent three-year rates and/or two-year rates supplied by the U.S. Department of Education. Downloaded today, October 15, 2014 from: https://www.nslds.ed.gov/nslds_sa/defaultmanagement/cohortdetail.cfm?sno=0&ope_id=007273 MSCHE Verification of Compliance, Institutional Report 7
2. Reports on compliance from U.S. Department of Education in regard to the cohort default rate. Bernard Baruch College has had no correspondence with the U.S. Department of Education regarding the college s default rate. The College s default rates are well below the threshold that requires such correspondence. 3. External audits of federal programs (A-133) for the past three years. Include the complete single audit report (A-133) for the most recent three years as an appendix, even if included in other documentation. See Appendix: External Audits FY2011-FY2013 4. Relevant correspondence from U.S. Department of Education such as program reviews and any actions to limit, suspend, or terminate the institution s eligibility to participate in Title IV. Include institutional responses, if applicable. See 2 above. Assignment of Credit Hours In accordance with 34 CFR 602.24(f), the Commission must conduct an effective review and evaluation of the reliability and accuracy of the institution s assignment of credit hours. Specifically, the Commission must review the institution s policies and procedures for determining the credit hours awarded as well as the application of the institution s policies and procedures to its programs and coursework, and make a reasonable determination of whether the institution s assignment of credit hours conforms to commonly accepted practice in higher education. Institutions must provide the follow documentation: 1. Written policies and procedures for credit hour assignment covering all types of courses, disciplines, programs, degree levels, formats, and modalities of instruction. Include each policy that documents the assignment of credit hours specific to the types noted above. Specify the location of the policy in the catalog and website. The following should be clearly indicated: o Academic period ( e.g.,15 weeks plus one week exam over two semesters) MSCHE Verification of Compliance, Institutional Report 8
o Recommended instructional time (e.g., three 50-minute sessions or two 75-minute session per week) o Recommended out-of-class time requirements (e.g., twice in-class time) Baruch College follows the State of New York s Department of Education procedures for assigning credit hours to courses. From Chapter II Regulations of the Commissioner; New York State department of Education 50.1.O Semester hour means a credit, point, or other unit granted for the satisfactory completion of a course which requires at least 15 hours (of 50 minutes each) of instruction and at least 30 hours of supplementary assignments, except as otherwise provided pursuant to section 52.2(c)(4) of this Subchapter. This basic measure shall be adjusted proportionately to translate the value of other academic calendars and formats of study in relation to the credit granted for study during the two semesters that comprise an academic year. http://www.highered.nysed.gov/ocue/aipr/part50.htm 2. Evidence that the institution s credit hour policies and procedures are applied consistently across the full range of institutional offerings. If the institution is required to obtain approval from the relevant State Department of Education, compliance with this requirement should be documented. Other evidence must include: o documentation from recent academic program reviews; o new course or program approvals; o documentation for registration software/systems that ensure a consistent schedule of courses based on the credit hour assignment; o academic calendars and/or schedules, and course matrices; and o documentation of adherence to credit hour requirements, consistent with federal regulations, from a system, or disciplinary organization; etc. Baruch College uses a series of scheduling grids that are designed to guarantee courses meet for the required number of hours. These grids are calculated for our length of term MSCHE Verification of Compliance, Institutional Report 9
and relevant for across all academic programs and student levels. Our new student information system, PeopleSoft, allows us to build a bell schedule that automatically populates the meetings times using the section code from our scheduling grid. 3. A description and evidence of the processes used by the institution to review periodically the application of its policies and procedures for credit hour assignment. Indicate the individual(s) and/or entities responsible for the final review and approval. Our curriculum is the province of the faculty. It begins with discussions within disciplines: every department has its own curriculum committee, which makes recommendations to the department. If the recommendations are approved, they are brought to the school s curriculum committee, which includes representatives from each department and from the offices of the dean, provost, registrar, and academic advisement, as well as from the other schools. The process for each school then continues to include consideration by the entire faculty of the school, and, if approved, review by the Provost s Office and inclusion in a report to the CUNY Chancellor for consideration by the CUNY Board of Trustees. Only with this final approval are curriculum changes accepted officially. At all of these levels, discussions are substantive and include review of credit hour to contact hour requirements. Faculty members critically examine new proposals with an eye toward topicality, relevance, scholarly rigor, and pedagogical integrity. Before forwarding proposals to the Chancellor s office, the Provost s office may request changes from the perspective of College-wide coherence and consistency. Finally, the Director of Program Review, Articulation, and Transfer at the CUNY Office of Academic Affairs sometimes requests clarification before submission to the CUNY Board, or returns proposals for reasons either substantive or procedural, sometimes with reference to guidelines of the New York State Education Department (NYSED). More sweeping or structural changes that affect educational offerings, such as new programs, departments, and majors, must, after extensive review within the CUNY system, be approved by the NYSED. One again, throughout the forgoing process, credit hour requirements are reviewed and verified. 4. A list of the courses and programs that do not adhere to the federal definition of credit hour or its equivalent as specified in the MSCHE Credit Hour Policy (e.g., online or hybrid, laboratory, studio, clinical, internship, independent study, and accelerated format) and evidence that such variations in credit hour assignment conform to commonly accepted practice in higher education. MSCHE Verification of Compliance, Institutional Report 10
o Each course or program that does not adhere to the federal definition should be specified and supporting evidence that it conforms to commonly accepted practice should be provided using the criteria described above in Item 2. Baruch College has no courses or programs that do not observe the federal definition of credit hour or its equivalent as indicated in the MSCHE Credit Hour Policy. MSCHE Verification of Compliance, Institutional Report 11