Good afternoon everyone:
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
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
Helena, MT 59620-3201