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were mentioned in those two series were members of your group, Mr. Fowler, and how many have since had their accreditation removed. Would you submit that for the record?

Mr. FOWLER. Yes.

Senator PELL. Would you do the same, Mr. Goddard?

Mr. GODDARD. I can answer that question now.

There would be insufficient time at this point to conclude the investigations, and to withdraw accreditation from any of them.

We try our best to be fair, to exercise due process, and while the investigations are underway, and have been active, there has been insufficient time for final action by the commission.

Mr. EHRLICH. Mr. Chairman, both of these agencies investigate every complaint, whether it comes from a Member of Congress, the Office of Education, State Department of Education, a consumer group, because as part of their accrediting process each of these agencies are requested for information.

In addition, not only do we investigate, but if there are any problems there, the results of it are reported back to the accrediting

agency.

There are things under investigation, but in connection with the due process that we are required to give, and should give to the schools, I just feel that we would be glad to give you any information, but for purposes of the record I would feel that we would like to observe our due process procedures.

Senator PELL. I have put in the record already the two series of articles, and I would like to also put into the record with regard to each institution something along the lines of what action is being taken, what your findings were. I think it should be of interest.

Now, you have to follow your counsel. We are not subpenaing this information. But I think it should be in the public domain. I do not want to be liable for a damage suit.

But if it appears in the proceedings of the committee, is that not exempted from a suit?

Mr. WEXLER. NO.

Mr. EHRLICH. I am sure if I work with your counsel, we will be able to work this out, some arrangement to get the kind of information you desire.

Senator PELL. I would like to ask Mr. Fulton if he would do the same thing concerning Andover.

Mr. FULTON. Yes.

Senator PELL. If you would furnish the same information.

I think that concludes this particular phase of these hearings. If there are any other questions, they will be submitted. The record will be left open for a while, in order to give you adequate time to prepare your responses. I would say several weeks. I think you will need some time to get this specific information. I would think 4 weeks would be more than adequate.

Normally we only say 2 weeks. I realize it is a little complicated. I thank you all. I thank you for your frankness.

[The prepared statements of Mr. Goddard and Mr. Fowler and other information subsequently supplied for the record follow:]

September 12, 1974

STATEMENT OF

WILLIAM A. GODDARD

BEFORE THE

SUBCOMMITTEE ON EDUCATION

OF THE

SENATE LABOR AND PUBLIC WELFARE COMMITTEE

My name is William A. Goddard. I am the Executive Director of the National Association of Trade and Technical Schools (NATTS). NATTS is a voluntary non-profit organization of accredited private residence schools offering job-oriented specialty training in trade and technical occupations. The membership of NATTS includes both proprietary and non-profit schools. Although all member schools must be accredited, an accredited school need not apply for membership.

The Accrediting Commission of NATTS is the accrediting agency listed by the United States Office of Education as the nationally recognized accrediting agency in the trade and technical school field and is the only accrediting agency so listed by the United States Office of Education.

The broad purpose of NATTS is to establish and maintain sound educational standards and ethical business practices for its member schools, which schools complement, rather than compete with, tax supported facilities.

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I will be available for questioning and will be pleased to answer, to the best of my ability, any questions this Committee may have relating to the trade and technical school field.

However, it is the primary aim of this statement to acqua int the Committee with the role of trade and technical schools in our educational system and to explain the nature of the accreditation

process.

Several studies have been made of vocational schools, including trade and technical schools, which furnish substantial information concerning the role of trade and technical schools.

The author is on the

In 1969, a fairly exhaustive study was published by A. Harvey Belitsky entitled "Private Vocational Schools and Their Students: Limited Objectives, Unlimited Opportunities." staff of the W. E. Upjohn Institute for Employment Research and the study was financed over a 15 month period by the Ford Foundation.

In June, 1970, the author published a condensed version of his studies in this field, at the invitation of the Bureau of Higher Education, Office of Education, U. S. Department of Health,

Education and Welfare.

References herein to Belitsky's studies are directed to the

June, 1970, condensed report.

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The author, at the outset, states (p. 1):

"The expected advances in the use of private vocational schools are grounded in the demonstrated capacity of the schools to motivate and train students with various needs and interests for specific occupational objectives."

The author estimates that there are 3,000 trade and technical schools with 835,710 students. He points out that the enrollment in each individual school is small as compared to other types of schools, for the following reasons (p. 4):

"One explanation for the small size of most of
these schools is related to the importance assigned
to practical, problem-solving aspects in the courses.
It follows that only a short period of time is spent
in large classrooms, and the costs of adequate space
and machinery in shop and laboratory settings neces-
sarily limit the size of a school building and its
staff. Second, the schools are widely distributed
geographically often either located in cities with
less than 100,000 persons or situated within sections
of a large metropolitan area. A third reason is
that the trade and technical schools (the primary
focus of attention in this study) tend to train for
single or related occupations. Nevertheless,
collectively, the large number of highly special-
ized trade and technical schools offer the greatest
diversity of courses.

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He points out that the variety of occupational courses found

in private trade and technical schools reflects the "unique ability" of these schools to respond to the training needs of many industries

and professions; and that about 230 different occupational courses were offered in the more than 500 trade and technical schools

examined in his study.

As for instruction in these schools, he found that it is

highly specialized, with a view to the final employment objective; that the schools maintain close but informal contacts with employers; that course content is readily modified to reflect pertinent changes that are reported to school officials by employers; that decisions to add improved facilities can also be made rapidly; and that this differs from the delays often encountered by public schools and colleges that must seek approval from school boards or legislatures. He further points out that training is provided in a job

simulated setting; that visual aids and operative equipment are typically more important than textbooks; that classroom or lecture instruction is usually followed immediately by supplementary training in the school shop or laboratory to demonstrate the practical application of the theoretical concepts; that most schools arrange student visits to plants and offices; and that modest home assignments are required because only those theoretical concepts which are relevant to the performance of a job are taught.

As for instructors' roles, he found that each instructor must be critically evaluated, since the referrals by former students account for a substantial percentage of the student body; that the schools are convinced that creditable teaching performances can be ensured by making teaching capability the main criterion for reward

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