Federal Student Aid - IFAP
SFA Information for Financial Aid Professionals
U.S. Department of Education
PublicationDate: 9/1/98

The Recognition Process

The recognition procedures for accrediting agencies are set forth in subpart B of part 602. Other information related to an agency's application for recognition is provided below.

The Application for Recognition

Accrediting agencies desiring to be recognized by the Secretary of Education must apply for recognition and must demonstrate their compliance with the Criteria for Secretarial Recognition (34 CFR Part 602). An agency's application for recognition generally consists of a statement of the agency's requested scope of recognition, evidence of the agency's compliance with the criteria for recognition set forth in part 602, and supporting documentation.

There is no standard application form to be used by agencies applying for recognition. Rather, an agency's application for initial recognition or renewal of recognition consists of a narrative statement, organized on a criterion-by-criterion basis, showing how the agency complies with the Criteria for Secretarial Recognition. For many recognition requirements, the narrative statement need consist only of a brief narrative demonstrating how that the agency complies with a particular requirement. This statement must, however, be accompanied by clearly referenced supporting documentation demonstrating that the agency meets the requirement. For example, §602.21(b)(5) of the regulations requires an agency to have clear and effective controls against conflicts of interest or the appearance of conflicts of interest by the agency's board mem-bers, commissioners, evaluation team members, consultants, administrative staff, and other agency representatives. The agency's narrative statement addressing this issue might simply be a statement that the agency's policies against conflicts of interest may be found in a particular policy document. The agency would have to submit a copy of that document and identify the pages on which the relevant policies were located. The agency might also choose to include a copy of the minutes of a meeting at which an agency representative abstained from voting because of a conflict of interest to demonstrate that it adheres to its written policies.

For other recognition requirements, because of their nature, the brief narrative statement, with supporting documentation, is insufficient to demonstrate compliance. In these cases, the agency's narrative statement should provide sufficient information to demonstrate that the agency's policies, standards, procedures, and practices comply with the requirement. For example, §602.23(b)(5) of the regulations requires that an agency maintain a program of review designed to ensure that its criteria and standards are valid and reliable indicators of the quality of the education or training provided and are relevant to the education or training needs of affected students. As this requirement is fundamental to sound accreditation practices, the agency's narrative statement would have to describe in depth the processes the agency uses to review and update its criteria and standards, the tests it uses to determine their validity and reliability, as well as the results of those tests, and how it determines they are relevant to the needs of affected students. The agency would also have to provide relevant supporting documentation, such as policy statements pertaining to its review program for validating and updating its standards, surveys and the results of those surveys, the constituencies involved in the review process, etc.

The table at the end of this section identifies those recognition requirements for which the brief narrative approach is acceptable and those for which a more detailed narrative statement is required. An agency may use the more detailed narrative format to demonstrate compliance with any of the recognition requirements for which the brief narrative approach is acceptable, if it so desires.

If an agency's application for recognition does not make specific reference to the following documents and does not include them as supporting documentation for one or more of the recognition requirements, the agency must include them as additional supporting documentation:

1. The agency's accreditation standards and procedures

2. The agency's policies and procedures

3. The agency's most recent externally audited financial statement

4. Published lists of accredited schools or programs

5. Self-study guidelines

6. Guidance aid training materials for visiting team members

7. Sample completed self-study reports

8. Sample site visit reports.

9. Sample institution responses to site visit reports.

10. Sample minutes of decision meetings.

11. A list of all complaints received by the agency against an accredited program during the six-month period immediately preceding the agency's submission of its application for recognition, together with a summary of the issues involved in each complaint, the agency's disposition of that complaint, and the current status of the complaint, if it is not resolved by the time the agency submits its application.

12. The agency’s constitution and by-laws.

Note: it would be helpful if the samples provided by an agency for items 7-10 above referred to the same institution(s) or program(s).

Copies of the Application

An agency's application for recognition plus three copies should be submitted to the Chief of the Accrediting Agency Evaluation Branch (AAEB) at the address below. Only the original of bulkier exhibit items, such as self-study reports or team reports, need be submitted with the petition; there is no need for three copies of these items.

Ms. Naomi Randolph
Chief, Accreditation Agency
Evaluation Branch
U. S. Department of Education
ROB-3, Room 3915
7th and D Streets SW
Washington, DC 20202-5244

Time Frame for Submission of an Application

.Application for Initial Recognition
The Accrediting Agency Evaluation Branch (AAEB) accepts applications for initial recognition at any time. To receive consideration at a particular meeting of the National Advisory Committee on Institutional Quality and Integrity, an agency seeking initial recognition must submit its application at least six months in advance of that meeting. Consideration of the agency's application at the first Advisory Committee meeting that occurs after the six-month time frame is not guaranteed, however, as Department staff may need more time to complete its independent evaluation of the agency and to observe at least some of the agency's site visits and decision meetings, as required by §602.11(b)(1).

An agency considering applying for initial recognition is encouraged to contact AAEB as early as possible to discuss its possible application and to afford Department staff the opportunity to observe its site visits and decision meetings. Because observation of an agency's site visits and decision meetings by Department staff is a critical component of the review of the agency's application, it is imperative that an agency seeking initial recognition submit a list of scheduled site visits and decision meetings with its application for recognition. If an agency does not provide Department staff with an opportunity to observe an adequate number of site visits and decision meetings (typically 2-3 of each) before the Advisory Committee meeting at which the agency requests consideration of its application, Department staff may recommend that the agency's application be denied.

Agencies seeking initial recognition are reminded that recognition by the Secretary is not a prerequisite for an agency to function as an accrediting body, i.e., an agency does not have to obtain recognition before it begins to accredit institutions or programs. Rather, recognition is granted by the Secretary to an agency that can demonstrate by its accrediting actions and decisions that it is a reliable authority regarding the quality of education offered by the institutions or programs it accredits. In general, this means that an accrediting agency seeking initial recognition has had about two years' experience functioning as accrediting agency - establishing standards, evaluating institutions or programs for compliance with those standards, and making accrediting decisions based on those standards - before it submits its application for recognition. It also means that the agency has gained acceptance of its standards, methods of evaluation, and accreditation decisions, as required by §602.22, during those two years. In addition, it means that the agency has demonstrated that it has been organized under conditions that reasonably ensure its stability and permanence.

Application for Continued Recognition
Agencies that have been granted recognition by the Secretary are notified by the Secretary, each time recognition is granted or renewed, of the expiration date of their recognition period. They should plan to submit their application for renewal of recognition approximately six months in advance of the spring or fall meeting of the Advisory Committee that precedes the expiration date. AAEB usually notifies agencies a year in advance of the Advisory Committee meeting at which their renewal application is to be considered and informs them of the date by which their application is due to AAEB. In the same notice, AAEB also requests a schedule of the agencies' site visits and decision meetings for the upcoming year in order to plan its observation of at least some of those activities, as required by §602.11(b)(1).

Hearing Before the Advisory Committee

When Department staff completes its evaluation of an agency's application for recognition, the designated Department official places the agency's application on the agenda of the National Advisory Committee on Institutional Quality and Integrity. The designated Department official also provides the Advisory Committee with the accrediting agency's application and supporting documentation, the Department staff analysis of the application, all information relied upon by Department staff in developing the analysis, any response by the agency to the analysis or third-party comment, any Department concurrence with or rebuttal to the agency's response, and any third-party information the Secretary receives regarding the agency.

The Advisory Committee meets at least twice a year to review applications for recognition submitted by accrediting agencies. The usual times for the Committee meetings are spring (May-June) and fall (November-December). Although each member of the Advisory Committee receives every Department staff analysis of an application for recognition and all the other materials mentioned in the preceding paragraph, the Executive Director of the Advisory Committee usually assigns two or more Committee members to serve as principal readers for each application. The Advisory Committee may, at its discretion, choose to divide into subcommittees to consider particular applications for recognition.

An agency that applies for recognition is invited to make an oral presentation before the Advisory Committee. The Advisory Committee also hears oral presentations from Department staff and from third parties who request to be heard.

The Advisory Committee conducts its business in public, and a transcript of the proceedings is made.

Expansion of Scope

An application for expansion of an agency's scope of recognition may be included as an integral part of an application for renewal of recognition or it may be submitted separately. If expansion of scope is sought prior to the agency's next regularly scheduled review, agency personnel should consult with AAEB staff concerning the application format.