Publication Date: February 25, 2010
Subject: General guidance for accrediting agencies and institutions on the treatment of campuses of Title IV-eligible institutions that have been determined to qualify for independent accreditation
Summary: This letter provides guidance for accrediting agencies and Title IV participating institutions on the treatment of campuses that have been determined by the accrediting agency to qualify for independent accreditation from the main campus.
We are writing concerning the treatment of branches, or locations of a Title IV-participating institution, that have been determined by the accrediting agency to no longer qualify as a branch or additional location and instead need to seek independent (main campus) accreditation. We address this issue separately depending on whether or not the change in institutional accreditation involves a change in accreditor because of the geographic scope of the regional accrediting agency.
Regional Accrediting Agencies and Institutions They Accredit
A regional accrediting agency has within its scope of recognition institutions that have their main campuses in the region, and within-region and outside-region locations that would not qualify as branch campuses (34 CFR 600.2) or for independent accreditation. In addition, within-region branch campuses, or locations that have been determined to be separately accreditable by the accrediting agency, are within the scope of the regional accrediting agency that accredits the main campus. Outside-region branch campuses, or locations that have been determined to be separately accreditable by the accrediting agency, are within the scope of the regional accrediting agency that accredits the main campus, but only for the period of time (generally not in excess of two years) in which the Department of Education (Department) considers them to be engaged in the process of obtaining accreditation (or preaccreditation) from an agency whose scope of recognition covers the geographic location of the site, and obtaining approval by the Department of an application for certification as a freestanding institution. The starting date for this two-year period is the date the campus becomes a branch campus, or the accrediting agency advises the school that the location is separately accreditable.
As of the date that accreditation (or preaccreditation) is obtained from the new accreditor, the outside-region branch/separately accreditable location must apply to the Department to participate in Title IV programs as a freestanding institution (Initial Certification) and select the new accreditor as its primary accreditor. The outside-region branch/separately accreditable location should not drop its accreditation with the original accreditor prior to gaining Departmental approval to participate in Title IV programs as a freestanding institution with the new accreditor as its primary accreditor for Title IV program purposes. The outside-region branch/separately accreditable location must demonstrate to the Department, in accordance with 34 CFR 600.11, reasonable cause for the change of accrediting agencies, which must include documentation that the branch/separately accreditable location and institution remain in good standing with the original, regional accrediting agency. If expeditious action to seek and obtain alternative accreditation (or preaccreditation), and certification as a freestanding institution, is not taken, the outside-region branch/separately accreditable location loses eligibility for Title IV programs because its accreditation is no longer within the scope of recognition of the agency that accredits it.
For-profit institutions should seek full accreditation. Obtaining preaccreditation will oblige them to select the new accreditor as their primary accreditor, which is insufficient for for-profit institutions to establish Title IV eligibility. Also, the location should seek designation as a "branch" from the original accreditor and the Department of Education to ensure that the time is appropriately counted toward the two-year rule (see 34 CFR 600.8), which requires that a branch campus of a for-profit institution must be in existence for at least two years as a branch campus before seeking to be designated as a main campus or a free-standing institution.
Whether located inside or outside a regional accrediting agency’s geographic scope, branches or locations that have been directed by the accrediting agency to seek separate accreditation from the main campus must obtain their own accreditation by any deadlines specified by the accrediting agency for expiration of the inclusion of the branch or location in the accreditation of the main campus. If the branch or location fails to obtain its own accreditation, it loses its eligibility to participate in the Title IV programs.
Change in Institutional Accreditation for a Reason Other than Geographic Scope of Recognition
If a branch/location that has been directed by its accreditor to seek separate accreditation from the main campus does so from a different recognized accrediting agency, the branch/separately accreditable location must notify the Department of its intent to seek accreditation from a different accreditor as explained below under "Institution’s Reporting Requirements."
A branch or separately accreditable location that is subject to the directive to obtain separate accreditation and that is within the scope of recognition of the original accrediting agency may continue to use the accreditation of the main campus for Title IV purposes for whatever period of time is required for it to develop into an autonomous institution and during any time thereafter in which it is in preaccreditation status, as long as the accrediting agency continues to include the branch/separately accreditable location in the accreditation of the main campus. However, it must apply to participate in Title IV as a freestanding institution (Initial Certification) if a recognized accrediting agency grants it separate and full accreditation. Within-region branches/locations would not need to seek separate accreditation unless required to do so by their accrediting agency. They could continue to be included under the accreditation of the main campus and to operate as a branch or location for Title IV purposes.
Accrediting Agency Notification to the Department of Education
The accrediting agency must notify the Department at the same time it notifies the institution of the need to seek a different accreditor and/or independent status.
Institution’s Reporting Requirement to the Department of Education
In accordance with 34 CFR 600.11, the institution must notify the Department at the time it begins the process of seeking a new institutional accreditor. The institution is considered to have begun the process on the date it becomes a branch campus or is notified by the accrediting agency that it is separately accreditable. The branch/separately accreditable location’s notification must include all materials related to its accreditation or preaccreditation; materials demonstrating reasonable cause for changing its accrediting agency; and evidence that the branch/separately accreditable location and institution remain in good standing with the original accrediting agency.
To apply for freestanding recognition from the Department, the institution must submit an Application for Approval to Participate in Federal Student Financial Aid Programs for Initial Certification via www.eligcert.ed.gov.
Accrediting Agency's Responsibility for Continued Oversight
An accrediting agency that requires a branch or location to obtain separate accreditation must continue to enforce its own standards while the branch or separate location seeks alternative accreditation. If the agency finds evidence of non-compliance in the course of arriving at the conclusion that separate accreditation is required, the agency must also take prompt action to enforce its standards. An agency that has reason to believe an institution that it continues to accredit but that is seeking alternative accreditation is failing to meet its Title IV, HEA program responsibilities or is engaged in fraud or abuse remains responsible for notifying the Department of the situation.
Extent of Accreditation Review
In accordance with 34 CFR 602.17, an accrediting agency must conduct its own review of any non-main campus seeking independent accreditation to determine whether the campus meets its standards. Judgments relied on in the accreditation process must be the agency’s own. Accreditation by another accrediting agency, recognized or unrecognized, cannot be "transferred" or given "full faith and credit."
A recognized agency’s process for granting accreditation to an institution accredited by another recognized agency, or for granting accreditation to a non-main campus seeking independent accreditation, must undergo review by the Department as part of the recognition process if it differs from the process the agency uses in other grants of initial recognition. Such a process would need to comply with all of the Criteria for Recognition, including, but not limited to, 34 CFR 602.17 (application of standards) and 602.28 (regard for decisions of States and other accrediting agencies).
If you have questions about accreditation, please contact the Department’s Office of Accreditation and State Liaison at (202) 219-7011. Questions about Title IV eligibility should be addressed to the appropriate School Participation Team of the School Eligibility Channel in the Office of Federal Student Aid. A list of the Teams, telephone numbers, and the states served is enclosed.
Daniel T. Madzelan
Delegated the Authority to
Perform the Functions and Duties of the
Assistant Secretary for Postsecondary Education
School Participation Team Phone Numbers
New York/Boston Team - (646) 428-3750 & (617) 289-0133
New Jersey, New York, Puerto Rico, the Virgin Islands, Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont
Philadelphia Team - (215) 656-6442
Delaware, the District of Columbia, Maryland, Pennsylvania, Virginia, and West Virginia
Atlanta Team - (404) 562-6315
Alabama, Florida, Georgia, Mississippi, North Carolina, and South Carolina
Chicago Team - (312) 730-1511
Illinois, Indiana, Minnesota, Ohio, and Wisconsin
Dallas Team - (214) 661-9490
Arkansas, Louisiana, New Mexico, Oklahoma, and Texas
Kansas City Team - (816) 268-0410
Iowa, Kansas, Kentucky, Missouri, Nebraska, and Tennessee
Denver Team - (303) 844-3677
Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, and Wyoming
San Francisco/Seattle Team - (415) 486-5677 & (206) 615-2594
Arizona, California, Hawaii, Nevada, American Samoa, Guam, Federated States of Micronesia, Palau, Marshall Islands, Northern Marianas, Alaska, Idaho, Oregon, and Washington