June 2023

From the President

Donald A. Balasa, JD, MBA

2022-2023 CAAHEP President

Department of Education Proposed Rule Would Increase Disclosure Requirements for Programs in Professions Requiring Licensing or Certification

The United States Department of Education (USDE) published a May 19, 2023, Notice of Proposed Rulemaking (NPRM) in the Federal Register that would increase disclosure requirements for schools that have programs in fields for which graduates are required to be licensed or certified by state law. These new requirements, if finalized by the USDE, would have to be met by schools to continue to have their students receive financial assistance under Title IV of the Higher Education Act (HEA). Thus, these proposed changes by the USDE are of importance for the Commission on Accreditation of Allied Health Education Programs (CAAHEP), its committees on accreditation and their accredited programs, sponsoring organizations, and other communities of interest.

(The gainful employment proposals contained in this NPRM will not be discussed in this article.)

Programs in Licensed or Certified Professions/Occupations

In this Notice of Proposed Rulemaking, the Department of Education reiterated its long-standing concern that some academic programs in licensed professions do not qualify their graduates to become licensed. The classic example is a student enrolling unknowingly in a program that is not programmatically accredited (even though the school is institutionally accredited) and who is not eligible for licensing upon completion of the unaccredited program.

The USDE is proposing that the following new section of the Title IV regulations be added to provide greater protection for prospective and enrolled students:

From a Public Member Point of View

Pauletta Brown Bracy, PhD

Former CAAHEP Public Member Commissioner

As I reflect on the varied roles I have had in the imperative arena of accreditation over the years, I attest one of the most professionally rewarding ones has been that of a public member on the Board of Directors for the Commission on Accreditation of Allied Health Education Programs (CAAHEP). Before joining the Board, my work involved serving in leadership and consultant roles in the National Council for the Accreditation of Teacher Education (NCATE) and as a member of site visit teams for the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC). At my institution, North Carolina Central University, where I am a professor of library science, I also hold the position of Director of University Accreditation in which I have responsibility for leading the university’s institutional accreditation efforts and coordinating programmatic accreditation among the various disciplines/departments.  

When I was appointed to the Board, I had a slight sense of how the position fit into the governance of CAAHEP and was inspired to explore the literature to gain a broader perspective. In this brief essay, I will provide context about the vital role of the public member and conclude with my personal experiences.

In 1992, through the reauthorization of the Higher Education Act (HEA), Congress enacted new requirements for accreditors including a process of review and approval for accreditors and a mandate that governance boards include “public members”, individuals identified to bring a consumer perspective to the Board. According to Ben Miller, formerly of the Center for American Progress (CAP), this new development intended to “bring more independent and public voices to the commissions that have the ultimate say on which institutions can obtain accreditation and thus access federal financial aid. The public commissioner role also aimed to provide an outside perspective from that of other commission members, who by and large came from institutions overseen by the accreditor. This role was designed to identify issues that individuals with backgrounds exclusively in higher education might miss and to ensure that the accreditation system would not entirely be based on educators policing one another. “ (Miller 2).

In an analysis of public membership on boards by CAP in 2019, researchers found “that of the 69 public commissioners on accrediting commissions as of January 2019, 22 have backgrounds that are more closely aligned with institutions than with the general public.” 

https://www.americanprogress.org/article/bolstering-public-voice-accreditation/ (Miller 6). Herein lies the dilemma for accreditors. Which is of greater importance – the experience of current or retired members of the higher education community or the independent observations proffered by those outside of the profession (represented by the accreditor)?   

The federal requirements state that at least one-seventh of a board represent the public. Additionally, it delineates who cannot be a public member: an employee, member of the board, a consultant to an institution or program that either is accredited or preaccredited by the agency or has applied for such; a member of any trade association or membership organization relate to the agency; and a spouse, parent, child or sibling of an individual identified in this definition. Miller recommends strengthening the definition by preventing newly retired administrators or professors from holding public commissioner positions for at least 10 years; stopping individuals who previously represented schools on commissions from serving as public commissioners; and addressing broader conflicts of interests. (Miller 12).

Earlier this year, the Council on Higher Education Accreditation released a report on public members with a focus on their selection, training, and utilization on both programmatic and institutional accrediting agency boards. ( https://www.chea.org/public-member-survey). Findings included

• Public members are central to the work of institutional and programmatic accreditation.
• The most prevalent way of recruitment for both institutional and programmatic accreditors is “Word of Mouth”.
• Public members bring balance to the boards by providing outside perspective and subject matter expertise.
• The value of public members is protecting the public interest through integrity of process, impartiality, and fidelity to standards. 
• Institutional and programmatic accreditors alike noted that, given the complexity of accreditation.
• training to build understanding of context, processes, and relationships is essential for public
• members’ contributions to be realized. (CHEA 4-5).

The survey acknowledged the ongoing challenge of recruiting public members which is an imposing reality in the midst of calls for greater numbers of public members, particularly outside of academia. Aware of the ongoing discussions about the challenges of not only finding public members but appointing “authentic public members” and in spite of my background, I was intentional in my commitment to serve as an “authentic” one. However, admittedly my prior experience shortened the onboarding process for me. And that was a fortuitous asset.

Typically, public members are wholly immersed in the processes, procedures, and policies of the accrediting organizations. I was involved in strategic planning and program review. I realized a compatibility of my discipline skills with those of an applicant organization and worked with the organization to attain membership. In addition, I raised the matter of a lack of diversity among the member organizations and stronger accountability for it in standards. At the same time, I was an observer, a consumer, an advocate. Navigating these blended roles led me to conclude that perhaps the most profound and personal value for me as a public member was the benefit of my healthcare. The new knowledge attained through my involvement with CAAHEP is immeasurable and each visit with a healthcare provider includes a review of educational preparation for his/her position. 

For all that I contributed to the organization as a public member, the return on the investment of my time is incomparable, for I am the more fortunate beneficiary of this gratifying relationship.  

References

Council for Higher Education Accreditation. “The Council for Higher Education Accreditation (CHEA) Public Member Survey”. https://www.chea.org/public-member-survey. CHEA, January 18, 2023. Accessed May 20, 2023.

Miller, Ben. “Bolstering the public voice in accreditation”. https://www.americanprogress.org/article/bolstering-public-voice-accreditation/. Center for American Progress, June 5, 2019. Accessed May 20, 2023.

There is still space available for program directors, faculty, and administrators of CAAHEP-accredited programs, and representatives of programs considering CAAHEP accreditation at the 2023 CAAHEP Accreditation Workshop. This premier event will be held July 21-22, at the Radisson Blu Mall of America, in Bloomington, Minnesota. Here is one of the agenda highlights:

Jamie Kozel MSN, RN, CPN

Clinical Assistant Professor

Purdue University Northwest 

College of Nursing 

Carmen Macharaschwili, PhD

Academic Strategist

Association of College and University Educators, ACUE

Commission on Accreditation of Allied Health Education Programs

9355 - 113th St. N, #7709, Seminole, FL 33775-7709

W: www.caahep.org  P: 727-210-2350 E: mail@caahep.org