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evaluation aimed at determining whether or not educational institutions or programs are operating at basic levels of quality. The procedures of these accrediting commissions and associations usually involve five basic steps. (1) Establishment of educational standards in collaboration with educational institutions and other appropriate constituencies; (2) Conduct of institutional or program self-study by applicants for accreditation under the guidance of the accrediting body; (3) On-site evaluation by a team of peers, selected by the accrediting body, in order to determine first-hand if the institution's objectives and the accrediting body's standards are being met; (4) Publication of the accredited status of those institutions or programs which are determined by the accrediting body to have met its standards; and (5) Periodic reevaluation of accredited institutions or programs to determine whether or not they continue to meet the established standards.

The nongovernmental accrediting agencies fall into two major categories-institutional and specialized.

Institutional accreditation is conducted by agencies, such as the commissions of the six regional accrediting associations.

For example, the Southern Association of Colleges and Schools maintain four accrediting commissions-one for elementary schools, one for secondary schools, one for vocational schools, and one for degree-granting collegiate institutions.

Specialized accreditation is conferred by a number of organizations which are national in scope, rather than regional, and each of which represent a specialized area, such as architecture, business, law, medicine, or teacher education.

A primary purpose of specialized accreditation is to protect the public against professional or occupational incompetence.

Although the Office of Education has dealt with accrediting agencies throughout much of its history, it was not until the enactment of the Veterans' Readjustment Assistance Act of 1952-Public Law 82-550-that the U.S. Commissioner of Education was required, for the first time, to publish a list of nationally recognized accrediting agencies and associations which he determined to be reliable authority as to the quality of training offered by an educational institution.

By 1972, the Commissioner's list of recognized accrediting agencies had grown from 28 agencies to 47, and by May of this year, 61 agencies were listed. Some 10 additional accrediting agencies are in varying stages of petitioning the Commissioner for recognition and listing.

Senator PELL. Excuse me. How many accrediting agencies did you say there are now?

Mr. HERRELL. There are 61 presently and 10 that are in varying stages of petitioning for recognition.

Senator PELL. All on the same level of recognition by HEW? Mr. HERRELL. All on the same level of recognition by HEW, yes. On August 20, 1974, revised criteria for "Nationally Recognized Accrediting Agencies and Associations," and criteria for "Recognition of State Approval Agencies for Public Postsecondary Vocational Education," were published in the Federal Register.

We believe that the new criteria significantly enhanced our ability to encourage improvement in the accreditation process, particularly in the areas of responsiveness to the public interest and protection of the student.

But we also realize that we are in a period of evolving policy development. Accordingly, we will be monitoring the effectiveness of the new criteria closely, and we will publish revisions which address immediately apparent shortcomings in the criteria no later than June 30, 1975. Of course, our longer-range policy review will continue well after that date.

It is noteworthy that these revised criteria place increased emphasis upon accrediting agencies' responsibility to the public interest and their reliability of operations.

Whereas the various versions of the criteria for "Nationally Recognized Accrediting Agencies and Associations" have been the Office of Education's instrument for directly supporting constructive change in the area of accreditation as it relates to the eligibility process, the Office of Education has funded or supported a number of projects over the past 6 years designed to improve indirectly the effectiveness of the eligibility determination process.

These are listed in my complete statement for the record.

Those accrediting agencies requesting recognition by the Commissioner of Education undergo intensive review by the Office of Education Accreditation and Institutional Eligibility Staff and by the Commissioner's Advisory Committee on Accreditation and Institutional Eligibility, in order to determine whether or not they comply with the criteria for nationally recognized accrediting agencies and associations.

The Advisory Committee performs a key role in the process of recognizing accrediting agencies and associations for the purpose of determining institutional or program eligibility for Federal funding programs. The committee was established by the Secretary of Health, Education, and Welfare in 1968, and was subsequently chartered under the Federal Advisory Committee Act, Public Law 92-463. It is composed of 15 members from various segments of the secondary and postsecondary education community, student/youth population, State departments of education, professional associations, and the general public.

The committee is advisory to the Secretary of Health, Education, and Welfare, and the Commissioner of Education.

Specific functions of the committee are enumerated in my prepared statement.

I turn now to several key observations about the dynamics of the present system, gleaned from the Office of Education's years of experience in monitoring the eligibility mechanism I have described above. These observations are offered in the spirit of enlisting your continued support for the improvement of the system.

Accreditation has been written into Federal legislation as a quality control device in order to help insure the Government's investment in postsecondary education and, even more importantly, as a means of aiding students and others in identifying institutions and programs deemed to be educationally worthy.

We must constantly bear in mind, however, that the accrediting agencies are private, independent, voluntary agencies having discrete, albeit laudable, purposes which do not always coincide neatly with the objectives inherent in Federal aid to education.

Accrediting agencies are committed philosophically to stimulation of institutional or programmatic uplift through a traditional pattern of expert peer review. They do not view themselves, nor do they function, as regulatory bodies. They have no legal authority to require compliance; they work instead by persuasion to maintain understanding and acceptance of their role and function by their constituents and the general public.

All accrediting agencies are limited in funds and staffing, and rely heavily on volunteer labor from member organizations. All are now deeply aware of, and some have already experienced, a marked vulnerability to litigation, which they are ill-prepared to engage in successfully.

One aspect of the Office of Education's relationship with accrediting agencies involves the processing of complaints against accredited schools and schools which are eligible for participation in federally funded programs of assistance to postsecondary education.

Complaints about schools-whether accredited or nonaccreditedare directed to the Accreditation and Institutional Eligibility Staff from many sources.

These include parents, consumer organizations, students, USOE regional offices, other divisions within OE, other Federal and State agencies, the Congress, and the White House.

These complaints include such matters as misrepresentation by salesmen, inadequate or late refunds of tuition, poor quality of instruction or equipment, and enrollment of persons incapable of benefiting from the instruction.

Although the Office of Education is not empowered to exercise direct control over educational institutions, it does seek to determine, in the case of accredited schools, whether or not a possible violation of the accrediting agency's standards has occurred in such complaint

cases.

The staff reviews each complaint and, if an accredited school is involved, directs a copy of the complaint to the appropriate accrediting agency with a request that the agency review the matter and report its findings to the staff.

The staff, in turn, reviews the report of the accrediting agency and informs the complainant of the agency's findings.

Although the staff usually directs complaints against accredited schools to the appropriate agency for investigation, the staff may, at times, correspond directly with schools regarding alleged educational malpractice.

Such was the case in connection with a series of articles dealing with proprietary vocational schools which recently appeared in the Boston Globe.

Senator PELL. I am glad you brought them up. I shall insert them in the record at this point.

41-997 O-75-4

[The articles referred to follow:]

[From the Boston Evening Globe, Mar. 25, 1974]

MANY CAREER SCHOOLS TURN EDUCATION INTO A FAST-BUCK INDUSTRY

Vocational education has evolved into a $2.5 billion annual business in the United States largely through the use of high-pressure salesmen, questionable advertising and the failure of government regulation at all levels, a four-month investigation by the Globe Spotlight Team has found.

And the principal victims appear to be young veterans-up in the air about their future but with lots of GI benefit money to spend-and underprivileged youths, frequently from minority neighborhoods in big cities.

Private vocational schools are an important part of this country's postsecondary education needs. And many have excellent programs, successfully mixing profit and education without cutting corners to stay out of the red. However, the career-training field has been cornered by a profitmaking school industry which is dominated by a fast-buck mentality that sees students as dollar signs.

This highly profitable, publicly subsidized market has exploded in the past five years; spawning a plethora of unscrupulous correspondence and resident "career" schools that take the money and ignore the student.

While stacks of studies cite the urgent need for training highly skilled young workers for the nation's technical industries, many private vocational schools are simply bilking students instead of preparing them for such jobs.

And although the Federal government spends billions to underwrite short, career-oriented courses for youths not going to college, it has been a demonstrable failure in regulating the quality of the education being offered.

The Globe investigation has found the industry to be marked by overzealous management which pushes commissioned salesmen to enroll generally unqualified students in courses of dubious value. Many students do not finish and many others wind up in debt with no marketable skill.

Some schools concentrate sales drives in poor inner-city sections where success is peddled on an instalment plan.

Members of the Spotlight Team posing as prospective students and interviewing hundreds of students, salesmen and executives, found the private correspondence and resident trade schools surveyed to be selling expensive, virtually worthless courses.

These schools purport to teach everything from computer programming to upholstery, from truck driving to law, from home building to jet-engine repair. They cost anywhere from a few hundred to several thousand dollars.

One expert a fiscal consultant to several proprietary schools, estimates that more than half the 10,000 profit-making schools in the country are "predatory," and a high Federal official concedes there is unchecked "widespread victimization" of students.

The need for technical training is attracting many large corporations who are selling education like toothpaste through slick advertising campaigns.

Commissioned salesmen, competing for prizes and cash bonuses, are frequently using Federal funding programs, designed to aid veterans and the needy, as selling tools to sign up anyone willing to pay for schools with phony placement service and astronomical dropout rates.

In Massachusetts, one private vocational institute uses a standard sales slogan that refers to the students as "asses in the classes," and other proprietary schools in the state use phrases like "hit the dummy market."

Today's instalment in the Globe Spotlight Team's series on private vocational education deals with ITT Tech, the largest technical training school in Massachusetts, which is owned by the International Telephone and Telegraph Corp. See Page 32.

[From the Boston Evening Globe, Mar. 25. 1974]

ITT TECH WATCHES PROFIT, PUTS QUALITY TRAINING IN BACK Row

A Boston institute, owned by the giant International Telephone and Telegraph Corp. (ITT), has become the largest private trade school in Massachusetts

while using misleading advertising and a highly deceptive sales force and flouting state education and consumer laws.

Although it heralds its courses as the doorway to financial success, the school, ITT Technical Institute, has a demonstrably dismal record of training students for careers in their field of study.

Located on Commonwealth Avenue, Brighton, ITT Tech has been offering about a dozen technical, automotive and health assistant courses for six years to the growing number of young people seeking a career alternative to four years in college.

The acid test of such vocational training is how many students finish the school's courses and how many are placed in related jobs.

However, statistics provided The Globe and the state Education Department show that about seven out of ten students who enroll at the school drop out and only half of those who graduate are placed in jobs. By contrast, comparable public nonprofit institutions show a 90-95 percent success rate in graduation and job placement.

ITT Tech, like the multibillion dollar corporation behind it, is understandably in business to make money. However, it appears its pursuit of profits is often to the detriment of quality education.

The high $2000 cost for the one-year courses has translated educational services into a $15 million enterprise for the company.

But there is little semblance of academe at ITT Tech. Few of its 30 teachers hold bachelor degrees, its library is meager, classrooms dirty and in some cases ill equipped. Moreover, the highest paid employees at the school are not the instructors who teach the 1000 students, but the salesmen who convince them to enroll.

With the school's operation geared to making a profit, quality instruction has been consigned to the back row. With an accountant's cold, clinical eye, courses pay off or are cut loose.

The head of the company's education division is in fact an accountant and not an educator. Richard A. McClintock recently described his past corporate duties succinctly: "I count beans." Now he counts students-and ITT Tech is out to enroll as many as possible.

"As far as I can see, they'll sign up anyone," one instructor told The Globe. "As long as you have the deposit, they'll take you no matter what your qualifications or capacities are."

Persons interested in an ITT Tech course are referred to as "sales leads" until they sign up.

Faculty resentment over the signing of unqualified students at the school reached a peak last year when one instructor threatened to quit unless he was allowed to interview every prospective student signed for his class before the semester began.

Student resentment is also evident. A list of grievances was presented by some students to administrators last summer complaining of dirty halls and classrooms, broken equipment in labs, filth in the cafeteria, and defective air conditioning and ventilation at the school, which promotes itself as a million-dollar facility with modern equipment and conveniences.

No action was taken on the grievances, according to the students, and the school official they presented them to, Dr. Julius Batalis, now principal of Athol High School, refused to talk to The Globe.

Students said they had not demonstrated publicly against the physical and educational conditions at the school because the ITT Corporation could retaliate by revoking the low-interest federally-insured loans it obtains for the students to pay tuitions. School officials say such fears are groundless.

A four-month investigation by the Globe Spotlight Team into the quality of education offered by the 100 licensed profit-making training schools in Massachusetts, included research into the operation of ITT Tech. It found:

ITT Tech has one of the highest student default rates for federally-insured loans of any school in Massachusetts.

ITT Tech conducted a concerted drive to enroll students from numerous ghetto neighborhoods in Boston last November using phony telegrams that the Better Business Bureau had previously warned the school were "unfair," "deceptive" and against state and Federal laws.

The school's massive promotional campaign includes television and newspaper ads which have been used before being submitted as required by law to the state Education Department. When some of the ITT ads were brought to the state's attention by The Globe, they were found to be questionable.

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