ATS Targeted Issues Checklist


Targeted Issues Checklist for Schools and Evaluation Committees

School Name: Holy Apostles College & Seminary

Visit Dates: October 24-27, 2016

Section Five of the Handbook of Accreditation describes various types of text found in the standards, including the following statement (p. 3):

[Another type] consists of mandatory requirements that reflect regulatory or ethical expectations… [They reflect] regulatory requirements of authorities outside the member schools, such as governmental agencies, or normative ethical guidelines that are true for any organization related to the Christian or Jewish traditions, like being honest and treating persons fairly . . . [These] requirements usually require a single, discrete institutional behavior or policy . . . This type of text leads to a simple evaluative task: determining whether the school does or does not [meet] the requirement. The standards [and procedures] have relatively few of these mandatory requirements. In self-studies, schools should audit their institutional policies and behaviors to affirm their compliance. In accreditation evaluations, committees should confirm the school’s compliance.

This checklist assists evaluation committees in confirming that a school meets these various requirements (“targeted issues”). This checklist is not a substitute for addressing these issues in the self-study report or in the committee’s narrative report of the evaluation visit, but serves as assurance that the school and the committee have addressed specific issues that are required by the Board of Commissioners or entities that certify accreditation by the Commission on Accrediting.

These targeted issues are listed below in two parts: Part 1 describes issues (from both standards and procedures) for which all schools are held accountable, and Part 2 describes issues for which only schools participating in Title IV programs (for USDE federal financial aid) are held accountable. Please note that one other key issue, Standard 1, section 1.2.2.2, on “ongoing evaluation procedures for educational effectiveness,” is covered by a separate document titled “Checklist for Effective Assessment.”

Part 1. Requirements for All ATS Accredited Schools

Commission on Accrediting Standards
2.2 With regard to state, provincial, and federal authorities, schools shall conduct their operations in compliance with all applicable laws and regulations.
The school must provide a copy of all necessary legal documents verifying that the school has appropriate authority to operate its main campus and any extension sites. If the school enrolls any out-of-state online students, it must document how it determines whether those students trigger any state regulations and, if so, how those regulations are met. Please list here where these legal and other documents may be found (e.g., a copy of the school charter is in TIC File 2.2 in Document Room or found online at …).
School Response

Holy Apostles College & Seminary has been pursuing state authorization within all states in which it has students and will complete its last three states, Iowa, Minnesota and Alabama, in late-spring 2016. Of the other states that require authorization, Holy Apostles has maintained its paperwork with them since originally signing up, and these include Wyoming, Maryland, and Michigan. As new states develop requirements, as was recently the case in Michigan (at a cost of $10,000), Holy Apostles completes the paperwork for them and submits them with the requisite fee. Copies of all state authorizations will be in the Document Room in a file labeled “State Authorization.”

Update: September 13, 2016, Holy Apostles College & Seminary has initiated the process by which to join SARA, the State Authorization Reciprocity Agreement, following the August, 2016, announcement by the State of CT Office of Higher Education that it was entering SARA. This move on the part of our college will complete the remainder of the states. Holy Apostles will continue to pursue paperwork with the individual states while CTOHE is working through their own processes.

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

.3 The school shall ensure that all published materials, electronic and print, including catalogs, academic calendars, and promotional literature, accurately represent the institution to its various constituencies and publics, including students and prospective students. All charges and fees, including refund policies, should be fully disclosed. Schools should exercise care in advertising to portray the institution fairly and honestly to the public. Wherever appropriate, published institutional documents shall employ gender-inclusive language.
The school must provide a copy of or reference to the document(s) that list the school’s charges and its refund policy, as well as provide representative samples of published materials listed above. Please list here where these published materials may be found (e.g., TIC File 2.3 or online at …).
School Response

All published materials, electronic and print, accurately represent the institution. During the 2015 NEASC Self-Study process, a Public Disclosure Committee was formed and has been maintained in existence to provide periodic review of institutional publications to ensure that new information is consistent with institutional realities and that old information is updated as those realities change. Documents that list the school’s charges and its refund policy (which is different per Maryland State Law for students from the State of Maryland than it is for students from any other state), as well as provide representative samples of published materials, will be found in the document room in a folder labeled “Public Disclosure.”

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

2.9 Member schools shall make public a statement of their policy on transfer credits earned at other institutions of higher education, including the criteria used for their decisions.
The school must provide a copy of or reference to its transfer policy, listing where the policy is found (be specific). Evaluation committees must also interview recruitment/registrar staff and sample transcripts.
School Response

Holy Apostles Policy on Transfer credits may be found on its website at http://www.holyapostles.edu/admissions/transfer-students/ and in the 2015-2016 catalog on page 50.

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

6.3.1 Policies regarding students’ rights and responsibilities, as well as the institution’s code of discipline, shall be clearly identified and published.
The school must provide a copy of or reference to all published policies regarding students’ rights and responsibilities, including its student handbook. Please list here where those may be found.
School Response

Student rights and responsibilities are found in the various student handbooks (for seminarians, for religious sisters, for commuter students and for online students (the handbook for which will be promulgated in late-spring of 2016).  A student code of conduct is located on pages 51-52 of the 2015-2016 catalog.  All documents related to student rights and responsibilities, mainly found in the handbooks, will be made available in the Document Room in a folder entitled Student Handbooks.

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

6.3.4 Schools shall maintain adequate student records regarding admission materials, course work attempted and completed, and in other areas as determined by the school’s policy. Appropriate backup files should be maintained and updated on a regular basis. The institution shall ensure the security of files from physical destruction or loss and from unauthorized access.
The school must describe how it maintains and protects student records. The evaluation committee must investigate that student records are adequately maintained and appropriately protected.
School Response

The school has a Records Retention Policy and a FERPA Guidelines Policy that defines how Student Records are maintained and protected. Staff work with student files via the Populi Student Information/Learning Management System so that even remote access is gained securely, and all student records are transmitted securely, which is especially the case in the way the school receives transcripts through a secure file transmission service from the sending registrars. Occasionally, students will email copies of their unofficial transcripts for degree planning purposes as they’re beginning the admissions process, and given that email is not the most secure of sending methods, the college is currently seeking another means by which those documents may be transmitted and received.

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

6.3.5 Institutions shall demonstrate that program requirements, tuition, and fees are appropriate for the degree programs they offer.

The school must list below and provide a copy of or reference to degree program requirements and published tuition and fees. The committee must confirm this through interviews and document reviews.

School Response

Program requirements, as demonstrated within the degree program sections of the catalog, are appropriate for the degree programs Holy Apostles offers. Each program contains a normative number of credit hours required for completion in comparison to its peer institutions. Each degree program has articulated goals and outcomes with each of its concentrations having complementary goals and outcomes.  The courses on the graduate level are all taught in respect to the federal definition of a credit hour, and graduate students in the academic programs are required to engage the courses on a graduate level that is oriented toward research within the disciplinary area for the purpose of preparing all students with the capacity to understand how to engage in theological or philosophical research.

Holy Apostles lowered its tuition by 28% for its undergraduates and 8.5% for its graduates in July, 2015, for the purpose of granting a general scholarship to all students and matching the tuition offered by Southern New Hampshire University. It maintains the lowest tuition in its class at only $320 per credit hour, and the expectation is that students will be able to graduate debt-free or nearly debt free. The college’s tuition and fees information may be found on its website at http://www.holyapostles.edu/tuition-and-financial-aid/

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

6.3.6 Institutions shall publish all requirements for degree programs, including courses, noncredit requirements, and grading and other academic policies.

The school must document where it provides its degree program requirements and other policies listed here.

School Response

Degree program requirements are provided within the institutional catalog among the degree program sections and also on the website via http://www.holyapostles.edu/degree-programs-2/ All syllabi are published on the website prior to the registration period each term. All publications concerning requirements for Degree programs, courses, non-credit requirements (such as summative evaluation), grading and other academic policies will be available in the Document Room in a folder entitled “Academic Programs”.

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

6.3.8 The institution shall have a process for responding to complaints raised by students in areas related to the accrediting standards of the Commission and schools shall maintain a record of such formal student complaints for review by the Board.

The school must document its complaint process, provide copies of any written complaints, and share its response(s).

School Response

Holy Apostles has a process for responding to complaints raised by students in areas related to the accrediting standards of the Commission. The Academic Grievance process is available in the catalog and on the website at http://www.holyapostles.edu/degree-programs/academic-grievance/ All formal grievances are filed with the appropriate academic dean and maintained in the office of the Chief Academic Officer. All non-academic formal grievances are filed with the President-Rector and maintained in his office. A record of all formal complaints and their resolutions raised by students will be provided in the Document Room in a folder entitled, “Formal Complaints.”

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

ES 6.4.4 The institution shall, on a regular basis, make available to the public a summary evaluation of the educational effectiveness of its approved degree programs. The school shall determine the frequency and manner of this information.

The school must provide a link to and copy of its published educational effectiveness statement, which should include evidence of effectiveness for each degree program, such as completion and placement rates and/or other appropriate measures (see section 1.4.2 of each degree program standard).

School Response

A public summary evaluation of Holy Apostles educational effectiveness of its approved degree programs has been started at http://www.holyapostles.edu/the-community/about-us/public-statement-of-educational-effectiveness/ For much of the data necessary in terms of graduation and retention rates, the school is only just now in a position to prepare those for publication. The reason has to do with the time limitations of the degree programs. Up until the 2010-2011 Catalog, students had 10 years to complete the graduate programs, so data will not be available for the entering class of 2009 until 2019; however, with the 2010-2011 catalog, the time limitation for the program was adjusted to six years, which means that the first real graduation and retention data became available following the April, 2016, commencement ceremony. That data will be processed and posted on the website in the summer of 2016. Cohort data from 2006 may also be collected and posted at this time for the sake of comparison. The documentation will be made available on the website at the link above and in the Document Room in a file labeled Educational Effectiveness.

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

ATS Commission Policies and Procedures (applicable to all schools)
VII.A.4 In preparation for an evaluation visit, a school shall advertise to its constituencies at least 60 days prior to the visit that it is receiving an evaluation committee and invite comments in writing to the school and/or to the Commission concerning the institution’s qualifications for accreditation. These comments will be available to the evaluation committee. The evaluation committee may also include an open hearing scheduled during the course of the visit.

The school must document how it advertised this evaluation visit, along with any formal comments received.

School Response

Like with the NEASC reaccreditation visit, the school will advertise its upcoming evaluation committee visit in all local papers, on its website, through all institutional emailing lists, in all its courses and via all its social media, which will reach all places where persons interested in the college will be able to be made aware of it.

http://www.holyapostles.edu/public-notice/ – School Website (posted September 9, 2016)

http://www.hacsalum.com/hacs-initial-evaluation-visit-october/ – Alumni Association Website

https://www.facebook.com/holyapostlescollegeseminary/posts/10154563570199874  – Facebook

http://www.holyapostles.edu/wp-content/uploads/Holy-Apostles-ATS-Self-Study-May-2016.pdf – publication of self-study on our website (posted on September 9, 2016)

Email distribution to all members of the community on September 9, 2016

Announcement was sent to all local papers on September 9, 2016

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

X.A.2 Accredited members shall disclose . . . in their printed and/or electronic bulletin, calendar, or catalog the status of their accreditation (using language from COA Procedures X.A.2).

The school must provide a copy of and reference to how it discloses its accredited status.

School Response

At present, the school discloses in the front matter of its catalog that it is an associate member of the Association of Theological Schools. Following its initial accreditation, it will use the language from the COA Procedures to announce its accredited status. At present, Holy Apostles announces on its website at http://www.holyapostles.edu/accreditation-and-honors/#1455204433680-546839d7-559f and in the front matter of its catalog its associate member status.

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

VI.G.5 Schools conducting distance education must have a process by which the institution establishes by use of secure login and pass code… or other means that are effective in verifying student identity and protecting student privacy… In addition, the school must notify students of any projected additional student charges associated with [this requirement at] registration.

The school must document its policies and practices regarding student identification, privacy, and fees.

School Response

Holy Apostles uses a secure login to the Populi Student Information/Learning Management System for the purpose of authenticating its online students and protecting student privacy. A $35 registration fee is applied to the student registration each term that the student is enrolled for the purpose of paying for his or her digital footprint. The registration fee is advertised on the website and on the registration form each term, and the charge is applied at the point of registration each term in a manner that is transparent and clear on the student’s financial tab or invoice. Documentation concerning the verification of student identity and protection of student privacy will be available in the Document Room in a folder labeled “Student Verification and Privacy.”

Committee Response

The committee has reviewed the evidence and determined that the school

☐ does not conduct distance education.

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

Part 2. Requirements Only for Schools Participating in Title IV Programs

2.7 Institutions participating in US federal student financial assistance programs shall comply with prevailing governmental guidelines regulating these programs. Default rates on student loans above the federal threshold, or failure to comply with federal guidelines, is cause for review of an institution’s overall conformity to the standards of accreditation of the Commission. Schools shall demonstrate that they have resolved effectively all areas of deficiency identified in audits, program reviews, and any other information provided by the [USDE] to the Commission.

The school must document its response to each of the following questions as instructed below.

 

1.       Does the school list ATS as its recognized accreditor for Title IV funds?   NO

2.       What is the school’s most recent cohort default rate for student federal loans?  2.8%
Please place in the Documents Room a copy of the school’s most recent official cohort default rate letter from the USDE.

3.       Does the school have a clean audit (Circular A-133) for federal financial aid?   YES

If NO, school must provide explanation here, including what steps it has taken.
Clean Record.

4.       Has the USDE required the school to submit a Financial Responsibility letter since the last comprehensive evaluation?   NO

If YES, the school must provide an explanation here, including its current status.
No Financial Responsibility letter required by the USDE.

5.       Does the school have an appropriate Satisfactory Academic Progress policy?   YES

http://www.holyapostles.edu/tuition-and-financial-aid/#1450907682498-d5a07ad4-a12f

6.       How does the school verify student participation in instruction (i.e., what prevents students from receiving financial aid for classes they enrolled in but never attended)?
The Academic Dean of Online Learning requires all faculty to submit two reports each term (at the end of weeks 2 and 5) concerning student attendance. Students who are not attending are reported to the Director of Online Student Affairs who reviews the list against a list of the financial aid recipients for the purpose of reporting to the Financial Aid Officer which students are not attending.

7.       Does the school have an appropriate policy and practice for awarding credit that aligns with commonly accepted practices and with the federal definition of a credit hour? (See page 5 of USDE Guidance Regarding a Credit Hour.) The evaluation committee will review random samples of various course syllabi (in different programs and in different delivery methods) to ensure that the school’s practices conform to its policies.
Yes, the policies and practices for awarding graduate credit that aligns with commonly accepted practice and with the federal definition of a credit hour were instituted in the spring of 2012 during the initial revision of the online programming and are included in the Handbook for Online Instructors along with some methods for negotiating credit hours. All Syllabi underwent a comprehensive review in 2015-2016 for the purpose of ensuring appropriate formatting, with a focused review on course requirements scheduled for the summer of 2016.

8.       Please indicate below where the evaluation committee can find the most recent copy of the school’s Campus Security (Clery) Report.
The evaluation committee will find the most recent copy of Holy Apostles Clery Report in the Document Room within a folder entitled “Clery Report.”

9.       Does the school offer at least 25 percent of any educational program through contractual or consortial arrangement(s) with one or more entities not certified to participate in the Title IV programs? If yes, please list the entity(ies) involved, and explain the nature and extent of the contractual or consortial arrangement(s).

Holy Apostles offers 25% of its MA in Theological with a concentration in Bioethics through a consortial arrangement with the National Catholic Bioethics Center through the hiring of Fr. Tad Pacholczyk to serve as an adjunct faculty member at Holy Apostles for the purpose of his providing to the college the NCBC’s program of study. Because Fr. Tad is a Holy Apostles adjunct professor, the college considers the courses to be in-house.

Additionally, Holy Apostles has in April, 2016, signed an articulation agreement with the Paul VI Catechetical Institute in St. Louis, MO, to provide as many as 9 hours of advanced standing credit to students who complete as many as six courses within the Paul VI program per ATS ES 7 and NEASC Standard 4, Section 35.

Committee Response to all items in 2.7

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 

6.4.1 Senior administrators and financial aid officers shall review student educational debt and develop institutional strategies regarding students’ borrowing for theological education. (NOTE: Section 6.4.2 of Standard 6 addresses schools’ provision of financial counseling to students; that may also be reviewed during the evaluation, though it is only a “should” statement.)

The school must document its process for reviewing student debt and cite here where that may be found. The committee must review this evidence, as well as interview appropriate staff and students, to determine if the school has appropriate strategies to keep student educational debt loads reasonable.

School Response

Documentation concerning the process for reviewing student debt may be found in the Document Room in a folder entitled “Financial Aid and Student Debt.”

Committee Response

The committee has reviewed the evidence and determined that the school

☐ meets this requirement with no further comment or action needed.

☐ meets this requirement and a comment appears in the committee report.

☐ does not meet this requirement, so a recommendation appears in the committee report.

 


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