Photo Jorge Lopez

By Jim Miller

This summer few people outside of the Bay Area probably noted what was one of the most important stories about higher education in America: City College of San Francisco (CCSF) is losing its accreditation.

After years of wrangling, the Accrediting Commission for Community and Junior Colleges (ACCJC), one of the seven regional accreditors in the western United States whose job it is to ensure the quality of higher education programs announced that CCSF was losing its accreditation in July of 2014.

Why should you care? Because ACCJC’s decision had very little to do with the quality of instruction and much more to do with imposing a new business model on community colleges that narrows their mission and opens the door to more privatization in American higher education. And San Francisco is being used as an example to intimidate other colleges to fall in line with ACCJC’s questionable “reform” agenda. Thus, what happened in San Francisco could happen in San Diego.

The reaction to this extreme punishment for CCSF, an institution that serves 90,000 students, many of them working class, immigrant, or in adult education, and had never been sanctioned before last year, was outrage.

As the California Federation of Teachers (CFT) put it:

At no point in the accrediting commission’s so-called assessment has anyone faulted the quality of education our students receive.

This arbitrary and punitive action by the Commission, coming on the heels of numerous protests over its illegal evaluation processes, serious conflicts of interest by its president and other representatives, and violations of Federal and State law, reveals the extent to which the Commission is out-of-touch with its primary mission, to recognize, and collaboratively assist colleges in meeting Federal requirements for the benefit of their students.

The ACCJC has cultivated a climate of fear and intimidation throughout the entire community college system. They have usurped the authority of the Chancellor’s office of the California Community College system by involving itself in financial operations of the community colleges. Yet, efforts to raise questions about their behavior and conflicts of interest have been followed with further sanctions against the institutions that have dared to speak out.

The CFT believes a robust, thorough, and transparent accrediting process conducted by qualified and legitimate educators and one that engages the entire education community is critical to developing workable short and long-term strategies for academic achievement.

Coercion and intimidation to impose its own top down and extremist philosophies on colleges have no place in our schools or our democratic society. This most egregious example of a reign of terror has gone unchecked by top-level system wide bureaucrats.

The CFT will continue to stand with the students, faculty and staff of CCSF.
We will work to overturn this unjust decision that threatens the entire City College community and colleges throughout California and the western region.

Credit: Daily Kos

The three most central reasons cited for the CCSF’s loss of accreditation were that there were too few administrators, outdated technology, and depleted reserves. Of course, after years of budget cuts, these are all predictable problems that are largely out of the hands of the college unless the college decided to take money out of the classroom and put it towards these priorities.

Thus, after their initial warning, CCSF’s administration under the guidance of a special trustee with extraordinary powers set out to use Prop. 30 funds as well as new revenue from a parcel tax to address those areas while cutting class offerings and faculty salaries at the same time—not exactly what voters thought this money would be used for.

Still this wasn’t enough. Thus ACCJC decided to yank accreditation from CCSF despite their ongoing efforts to adhere to their demands. CCSF’s punishment for putting more resources into the classroom than administrative overhead was a death sentence.

ACCJC Gone Wild!

If this sounds crazy to you, it is. How did we get here? The answers are disturbing. In his comprehensive study of this mess, “ACCJC Gone Wild,” Marty Hittelman gives some crucial context:

The Accrediting Commission for Community and Junior Colleges (ACCJC) is the accreditation agency for the Community Colleges of California. It currently works under the Western Association of Schools and Colleges (WASC) although there seems to be activity by the ACCJC to distance itself from WASC.

A proposed ACCJC appeal process removes WASC from the appeals process leaving the final decision made on any appeal of an ACCJC Commission action left to an ACCJC Commission appointed panel. In short, the ACCJC itself appoints the panel that decides whether their action to remove the accreditation of a college was warranted. Talk about a kangaroo court.

Barbara Beno, a former college president whose contract was not renewed by the college district, has served as the President of the ACCJC since August of 2001. During her term of office the ACCJC has changed from being a collegial accrediting agency that helps its colleges to satisfy accreditation standards by offering training and assistance to both visiting teams and college constituencies to one that issues sanctions with a vengeance. The Commission operates in secret and applies its standards in an arbitrary and inconsistent manner. It disregards the public policies of California. From time to time questions regarding conflict of interest on the part of Commission members and staff have been raised. As a result of the secret operations of the Commission, it is difficult to determine who is voting or influencing a vote regarding a particular college’s accreditation.

President Beno and the Commission members, have, since Beno took over, conducted a reign of terror in which any sign of disloyalty to the ACCJC or difference with any of their policies is met with threats of more severe sanctions. In some cases, actual sanctions have been levied against colleges where criticisms of the Commission itself have occurred. As one CEO told me, it is “Beno’s way or the highway.” As a result, most college administrators and faculty are afraid to speak out against the excesses of the ACCJC. Even visiting team members have been unwilling to step forward and expose abuses for fear of hurting the chances of their home institutions. In June of 2013 the ACCJC stepped up its muzzling of both visiting team members and Commission members by passing a series of policy changes that require non-disclosure of Commission proceedings.

The goal of accreditation, according to the United States Department of Education, “is to ensure that education provided by institutions of higher education meets acceptable levels of quality.” In the Special Edition of the February 2001 ACCJC News it is pointed out that “In achieving and maintaining its accreditation a higher education institution assures the public that the institution meets standards of quality, that the education earned there is of value to the students who earn it, and that employers, trade or professional-related agencies and other colleges and universities can accept a student’s credentials as legitimate.”

The ACCJC does not value colleges for their quality of instruction, but instead the ACCJC issues sanctions that are based on the successful performance of excessive documentation and data gathering, reviews of policy and procedures, and adherence to education practices that are not based on scientific studies.

What is really going on here is a move toward standardization and the dumbing down and narrowing of curriculum to only include those things that can be quantitatively measured, whether or not those measurements actually mean anything. Thus we have the ACCJC’s emphasis on the need not for more full time faculty or more courses for students, but for more administrators and technocrats to manage the data flow. Hittelman again:

Approaches to evaluation such as Measurable Student Learning Outcomes (SLOs) that are not recognized as model standard practices by the majority of college educators as illustrated by faculty resistance to the imposition of the measurable student learning outcome methodology, are imposed on the colleges using the threat of sanction.

SLO’s are written to describe what specific knowledge and skills a student should have and be able to demonstrate at the conclusion of a course, program, and/or degree. SLO’s are to be used to provide data collection to measure student academic success. The implementation of SLO’s requires considerable work and effort. In addition to the tests given by instructors to determine how well a student is doing in a class and what grade should the student earn, SLO’s are used to determine whether the specific “outcomes” have been achieved. The data from the SLO’s is then supposed to be used to determine whether the classes are successful in terms of student success. The visiting teams do not report on the success of the various SLO’s.

The problem with SLO’s in the eyes of many instructors is that they do not lead to better teaching and learning and are a very big waste of time. Instead they tend to lead to a standardized curriculum that does not address the full needs of the students. Such important elements as motivation, critical thinking, interest, creativity, and the ability to learn on one’s own are difficult if not impossible to measure with SLO’s – and as a result become less important in the minds of those who would rate educational quality based on SLOs.

In addition to putting pressure on colleges to narrow and standardize curriculum, Hittelman points out that the ACCJC is also aiming to reduce access to colleges and change their core mission. That was a key point in San Francisco:

Some of the arguments supporting ACCJC sanctions against City College of San Francisco and several other colleges raise questions with regard to the mission of the community colleges in California. A goal of ACCJC’s interpretation of its standards seems to be to reduce open access to a wide variety of programs and students in the name of reduced resources. In short, the Commission is attempting to change the very mission of community colleges through ACCJC’s ability to sanction. This action is clearly in conflict with Federal Regulation 34 CFR 602.17(a)(1).

And it’s not just San Francisco that is paying the price, ACCJC has indeed “gone wild” issuing far more sanctions than any other such accrediting body in the United States:

From 2003 to 2008 the six United States regional accrediting bodies issued a total of 126 sanctions to community colleges in the United States. 112 of these were issued by the ACCJC under Beno’s direction. ACCJC has continued to be out of step with the other accrediting agencies. From June 2011 to June 2012 the ACCJC issued forty-eight of the seventy-five sanctions (64%) issued nationwide. The community colleges in California represent about 19% of the community colleges accredited nationally. In short, the 19% of the colleges nationwide that are under ACCJC generated 64% of the national sanctions.

In 2013 the ACCJC continued its assault on California’s community colleges when it sanctioned 10 out of 23 (43.4%) colleges before it in January of 2013 and 10 out of 21 (47.6%) colleges in June of 2013. Their action included putting College of Sequoias on SHOW CAUSE (the college must prove that it should not have its accreditation removed) and removed the accreditation from City College of San Francisco effective July 2014.

Clearly, the ACCJC has become a rogue agency.

Who’s Running the Show?

Obviously, the ACCJC has a conflict of interest as it has transformed itself into not just an evaluator but also a lobbying group pushing for various forms of education reform, such as completion-based funding models and more. They have broken federal laws, destroyed key documents, intimidated critics, ignored their own rules, and totally disregarded the notion that agencies involved in the public’s business should be accountable to the public and operate transparently.

Indeed, as CFT has challenged their role, the ACCJC has shredded documents, tried to impose confidentiality requirements on publicly elected trustees, sought to destroy shared governance on campuses, and tried to undermine collective bargaining agreements. In sum, the ACCJC is a profoundly undemocratic private entity licensed by the U.S. Department of Education that seeks to operate in secret with no accountability to anyone.

What’s the Agenda?

Much of what ACCJC is doing is in line with the agenda of the Lumina Foundation, a private group born of Fannie Mae profits that has $1.4 billion in assets and is associated with Bill Gates. One of Lumina’s key policy goals is to increase the number of college graduates in the United States through the use of data collection, tracking, and a narrowing of college curriculum to better suit the needs of the corporate world. As Hittelman reminds us, “Lumina helped sponsor the 2011 Annual conference of the American Legislative Exchange Council (ALEC). ALEC helps develop right wing legislative ‘model bills.’ Almost 98% of ALEC’s funding comes from Exxon Mobil, Reynolds American, Altria, corporate ‘foundations’ like the Charles G. Koch Charitable Foundation, or trade associations like the pharmaceutical industry’s PhRMA as well as other like minded corporations.”

Recently, the Lumina Foundation gave the ACCJC $450,000 in grant monies in order to fund a project which they call “Application of the Degree Qualification Profile (DQP) to Two-Year Colleges in the Western Region.” By doing this Lumina is attempting to influence accreditation standards that would require the identification and measurement of desired educational outcomes.

As Hittelman points out, “This grant is in addition to the $1.5 million given to WASC to redesign its accreditation process.” This involves choosing colleges, a number of which have a member from the ACCJC Commission at their college, to serve as incubators for creating learning outcomes as models for other colleges.

Thus it is a kind of inside game. And the private agenda of Lumina and company fits perfectly with the ideological bent of ACCJC, an institution dedicated to data collection in the service of outcomes measurement as the heart of the new technocratic utopia of higher education. And, of course, if the public schools fail–as they have been deemed to have done in San Francisco–that opens the door for the for-profits to pick up the slack and, of course, tax payer dollars.

Indeed, already, as CCSF sees plummeting enrollment the beneficiaries are the for-profits and the companies seeking to make money off of the “disruption” of higher education.

San Francisco, the Chicago of Higher Education?

After this summer’s devastating news, the fight to save CCSF has evolved into a campaign to pressure the Department of Education to not renew its recognition of ACCJC and reverse the sanctions. As one educator put it in In These Times, San Francisco City College is “the Chicago of higher education.” Just as parents and teachers in Chicago’s public education system are struggling against draconian school closings being done in the service of corporate education reform, those fighting to keep CCSF open are up against similar enemies. And if they fail to save CCSF, the ripples will spread throughout the country to a college near you.

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Jim Miller

Jim Miller, a professor at San Diego City College, is the co-author of Under the Perfect Sun: The San Diego Tourists Never See and Better to Reign in Hell, and author of the novels Drift and Flash. His most recent novel is Last Days in Ocean Beach.

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