I have been working with Neil Moisey and campus legal counsel to update BOR Policy 320.1, Accreditation. I have attached the redlined policy to this email. I will include my specific reasons for each proposed change below, but first would like to address some assumptions about this policy. We have assumed that this policy exists for the purpose of deciding which institutions (outside of the MUS) can be lawfully authorized to operate in the State of Montana. Pursuant to MCA 20-25-107, the Board of Regents is charged with monitoring and/or approving non-MUS post-secondary institutions seeking to operate in the State of Montana. The BOR history of this policy supports that reading (See http://www.mus.edu/board/meetings/Archives/5-2001agendaBOR.htm).
My understanding is that at least some and maybe all campuses rely on this board policy in determining what institutions is must accept transfer credits from. Because of that reliance, campuses have raised concerns about our decision to add Department of Education recognized accrediting agencies to the list of accrediting agencies recognized by the BOR in 320.1. Currently, the policy only lists the six regionals and any accrediting agency recognized by CHEA.
I would like to discuss this issue on Thursday as we would like to move forward in making changes to policy 320.1, but did not intend for these changes to have any effect on campus decisions related to the transfer of credits and want to ensure before we make changes that they will not. To aid in our discussion, I would point everyone towards BOR Policy 301.5, which I believe should be looked to for purposes of credit transfer. This policy states that “all college level courses from regionally accredited institutions of higher education will be received and applied by all campuses of the MUS, and by the community colleges, towards the free elective requirements of the associate and baccalaureate degrees.” http://www.mus.edu/borpol/bor300/301-5.pdf.
To summarize, my reading has been that BOR Policy 320.1 does not affect campus decisions on the transfer of credits from institutions outside of the MUS – this policy relates to the Regents’ role as an authorizing agency within the State of Montana, and not to any internal MUS or campus processes. Instead, I believe that 301.5 deals with acceptance of transfer credits and clearly states that a school must have regional accreditation for the transfer to be automatic.
I have included below the explanation for the proposed changes to 320.1 for your information. I look forward to seeing everyone on Thursday.
Section B: We have been applying the religious exemption in practice and I thought it made sense to clearly state it in board policy. I took the language from the DOE regulations that allows states to use this exemption.
Section C: We had been allowing CHEA approved accrediting agencies, but not DOE approved accrediting agencies, and I could not find a good reason for the distinction. Not accepting accrediting agencies approved by the DOE makes us an outlier compared to other states. In addition, if we want to join the state authorization reciprocity agreement, we will have to agree that accreditation by a U.S. Dept. of Ed. recognized accrediting agency is sufficient.
Section D: Our current system makes it impossible for a new school to establish itself in Montana. We rely on accreditation for authorization, and accrediting agencies will not accept institutions as candidates for accreditation until the institution has operated for several years within a state. The proposed changes are very similar to the system that South Dakota uses.
Jessica M. Brubaker, Associate Legal Counsel Office of the Commissioner of Higher Education Montana University System 2500 Broadway Helena, MT 59620-3201 406-444-0314
According to the Residency Policy Section IC2 an individual can file an intent to establish residency. This is meant to allow a person to state they are working toward residency without doing an action item right away.
AACRAO joined a series of higher education community letters (attached) to address legislation in both the House and Senate aimed at tackling the student loan interest rate issue.
The Smarter Solutions for Students Act (H.R. 1911) would treat the subsidized and unsubsidized portions of the Stafford federal student loan the same, pegging their interest rates to the 10-year Treasury rate. It would also cap the rates to protect borrowers against anomalies. Although we agree that changes need to be made to address a long-term plan, we have some concerns some of its provisions and their impact on students.
The Senate's Student Loan Affordability Act of 2013 (S. 953) would maintain the current 3.4 percent interest rate on subsidized student loans for another two years, temporarily stalling the planned July 1 increase on July 1 until the issue can be considered in the reauthorization of the Higher Education Act. The legislation would pay for the extension through changes to tax law affecting retirement accounts, the oil industry and tax deductions for foreign companies.
We believe that lawmakers are motivated to reach a reasonable compromise on this matter, but the battle is just beginning. The House is scheduled for a floor vote on H.R. 1911 tomorrow. We will keep you updated.
The Residency Policy has been changed to reflect that 7 credits or more are considered to be “in excess of one-half of a normal full time credit load.” This change was posted on May 14, 2013. Here is a link to the updated policy. http://www.mus.edu/borpol/bor900/940-1.pdf
In addition, the posted policy also noted in the history section at the end of the policy that the change was temporary and would expire after spring semester 2013.
I hope this information will help in explaining to students why they cannot register for 7 credits for the fall semester if they are trying to establish residency. If our office can provide any assistance, please do not hesitate to contact me.
Jessica M. Brubaker, Associate Legal Counsel Office of the Commissioner of Higher Education Montana University System 2500 Broadway Helena, MT 59620-3201 406-444-0314 firstname.lastname@example.org
Today, the U.S. Department of Education announced that beginning with the 2014-2015 federal student aid form, the Department will – for the first time – collect income and other information from a dependent student’s legal parents regardless of the parents’ marital status or gender, if those parents live together.
The Free Application for Federal Student Aid (FAFSA) will provide a new option for dependent applicants to describe their parents’ marital status as “unmarried and both parents living together.” Additionally, where appropriate, the new FAFSA will use terms like “Parent 1” and “Parent 2” instead of gender-specific terms such as “mother” and “father.”
Education Secretary Arne Duncan said, “All students should be able to apply for federal student aid within a system that incorporates their unique family dynamics. These changes will allow us to more precisely calculate federal student aid eligibility based on what a student’s whole family is able to contribute and ensure taxpayer dollars are better targeted toward those students who have the most need, as well as provide an inclusive form that reflects the diversity of American families.”