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Historically, recognition by USDE was used as a hallmark of quality service, and quality indicators were the primary criteria to be met to achieve that recognition. With new regulations for the Higher Education Act of 1992, gatekeeping activities related to the monitoring of federal funds became primary criteria. Although it was necessary for NAACLS to carefully document policies and procedures for USDE, recognition came on the basis of serving as the institutional accreditor for a small number of hospital certificate programs. Because of this connection to Title IV eligibility, we were required to monitor numerous new issues for NAACLS accredited programs such as default rates, minimum program length, etc. as well as to carry out unannounced site visits. While NAACLS received full recognition, there were still many requirements that needed to be transformed into Essentials before the next application for recognition in the year 2000 and new policies and procedures to be implemented in order for us to be in full compliance. External benefit to NAACLS of recognition by USDE in 1993 was largely intangible. We knew that CEOs of academic institutions sometimes relied on their previous understanding of how recognition came about and they assumed an assurance of quality based upon it. Some still believe it to be a mark of quality of the accrediting body to have the federal stamp of approval. Other CEOs object strongly to federal interference in the educational arena. They consider the stamp of approval to be valueless. Nevertheless, because NAACLS was a new ‘ independent' on the block at the time, recognition appeared to the Board of Directors to be a positive step forward. Further, by gaining recognition, hospital programs could continue to participate in student loan deferment if they elected to do so and as they had done under CAHEA. The internal benefit to NAACLS centered on the improvement of our own self-assessment process. A general review of NAACLS policies and procedures was carried out using the USDE criteria for compliance as standards. For example, requirements were added for programs to include financial and personal as well as academic guidance for students. Some new procedures were required, among them that nomination and election procedures for the Board of Directors be changed to reflect more autonomy from sponsoring organizations. Observation by USDE staff of a NAACLS site visit and their participation in a Board meeting served to verify that the established NAACLS policies and procedures were appropriate. Between 1992 and 1999, the complexities and uncertainties related to USDE requirements for recognition increased. At the same time, the decreasing value of recognition versus the increasing cost to maintain that recognition was questioned by other national accrediting agencies as well as by the NAACLS Board of Directors. With the cost of meeting recognition requirements increasing and numbers of programs declining, we worked to maintain quality services while keeping program fees steady. The decline in programs was increasingly a hospital phenomenon. In 1993, 43 percent of NAACLS programs were in hospitals. By 1999 there were about 25 percent in hospitals, mostly at the CLS/MT level. At that level, 132 programs closed between 1990 and 1998, a 31.4 percent decline. To a 1999 NAACLS survey, 20 program directors responded that they sometimes, but not regularly, had students for whom they were deferring loans from Title IV funds. Many programs had already given up on the extensive paperwork related to funding eligibility. As noted by one hospital program director, the ability to defer loans required her to complete a 39- page government form. Other accrediting agencies with hospital based programs faced the same issue. In 1997, CAAHEP made the decision not to re-apply for USDE recognition based upon the small number of programs that were involved in Title IV and the high cost to the agency of maintaining recognition. These and many other factors were carefully considered by the NAACLS Board of Directors before and during the October meeting in Chicago. Factors included required changes to Essentials, required changes to policies and procedures, as well as the increasing costs incurred by NAACLS in order to be in compliance. After full discussion, the Board voted not to apply for continuing recognition when the period of recognition ends in 2001. Programs that now rely on NAACLS as the institutional accreditor for purposes of federal funding and wish to continue their eligibility to do so will have until summer of 2001 to find alternative routes. We have already been in contact with staff at USDE for information about alternate routes so that we may assist program directors in the future. The Board will continue to seek national recognition by the non-governmental recognition body, the Council on Higher Education Accreditation (CHEA). NAACLS actively participates in CHEA activities that support the aim of quality assurance through voluntary self-regulation. We encourage comments and suggestions for change as we work toward better ways to serve accredited and approved programs.
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