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FAME Regulatory Bulletin

When Changes are Made in Accrediting Agencies

With the recent decision of the U.S. Department of Education (ED) to end its recognition of the Accrediting Council for Independent Colleges and Schools (ACICS) as a national entity approved to accredit postsecondary institutions, schools that are accredited by ACICS have to make a decision to wait out an appeal from ACICS or gain another ED-recognized accrediting agency’s approval and submit that change to ED. ACICS has 10 calendar days to inform ED of its intent to appeal and another 20 days to file the appeal. If their appeal is denied by ED, then schools have 18 months to obtain the approval of another primary accrediting agency that is recognized by ED.

A few steps will be taken by ED at this time. ED will revise the school’s Program Participation Agreement (PPA) to update its ending date to coincide with the end of the 18 months. ED will place the school on Provisional Certification or update their current Provisional Certification to amend the expiration date to also coincide with the end of the 18 month period. ED could also place additional conditions of the provisional certification such as a limitation on growth, etc.

FAME cannot help you make the decision of whether you should wait for an appeal, but we can explain how you can notify ED of the change in your primary accrediting agency via the Application for Approval to Participate in the Federal Student Financial Aid Programs (E-App).

Before notifying ED, research accrediting agency options that would work for your programs and level of offerings. Schools should also contact their state authorizing agency to determine if there are any state requirements that may affect them for being accredited by an accrediting agency that loses its recognition by ED.

Schools should not end their current accreditation until ED approves the new primary accrediting agency because without an approved accrediting agency your school will lose Title IV eligibility.

Here are the steps to follow:

1. Notify ED in writing of your intent to change your primary accrediting agency at the start of the process.
a. With the notification, you need to submit a copy of your current accreditation along with the name of the current accrediting agency, the name of the new primary accrediting agency that you are applying to, and the reason for changing.
2. Email this notification and documents to: CaseTeam@ed.gov
3. Be sure to have, “Notification Regarding Accreditation”, in the subject line.
4. When the new accreditation is approved you must notify ED via the E-App.
a. Section B, Question 15
b. You must submit a copy of the new accreditation approval and Section L (signature page) and any other documents as required.

 

Non-profit and public schools can complete this process, as well, and submit a copy of their pre-accreditation status if ED accepts that status from the agency you have selected as your primary accrediting agency.

Schools may contract with FAME to complete the E-App.

(2016-2017 FSA Handbook, Volume 2, Chapter 5)

(ED’s Frequently Asked Questions on ED’s blog posting “What College Accreditation Changes Mean for Students”)

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This material is presented for informational and educational purposes only and should not be considered to be giving legal advice.

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