COMMISSION ON SECONDARY SCHOOLS:
Policy 6.3 Post-secondary Non-Degree Granting Career and Technical Institutions
Section 6.3.5: Third-Party Comments
Reference: §602.23 Operating procedures all agencies must have.
(b) In providing public notice that an institution or program subject to its jurisdiction is being considered for accreditation or pre-accreditation, the agency must provide an opportunity for third-party comment concerning the institution’s or program’s qualifications for accreditation or pre-accreditation. At the agency’s discretion, third-party comment may be received either in writing or at a public hearing, or both.
- 18.104.22.168. Purpose. The purpose of this policy is to:
- Require the Commission and an institution to provide public notice that the institution is being considered for accreditation/reaccreditation, and
- . Provide opportunity for third-party comment concerning the institution’s qualifications for accreditation.
- 22.214.171.124. Definition of Third-Parties. Third-parties are members of an institution’s community of stakeholders that have first-hand knowledge of the institution’s qualifications for accreditation/reaccreditation.
- 126.96.36.199. Requirements for Posting Notices.
- When an onsite accreditation visit is scheduled by the Commission for accreditation or reaccreditation, a notice will be posted in publicly available places by both the Commission and the institution advising the institution’s community of stakeholders that the Commission will accept comments regarding the institution’s qualifications for accreditation/reaccreditation and that comments that meet the requirements listed in 188.8.131.52, below will be considered in the course of the onsite accreditation visit by the visiting team appointed by the Commission.
- The Commission considers that the qualifications for accreditation/reaccreditation are defined by the Commission’s Standards for Accreditation for Career and Technical Institutions
- The notices must include:
- That only comments that relate directly to the institution’s ability to comply with the Standards for Accreditation for career and technical institutions will be considered;
- The web address at which the Middle States Standards for Accreditation can be viewed;
- The requirement that comments must be in writing and include the commenter’s name and affiliation with the institution;
- The requirement that comments must be received not later than 30 days prior to the first day of the onsite visit; and
- The Commission on Secondary School’s address (mailing and e-mail) to which comments may can be sent.
- Public notice by an institution shall be made by at least two means that are accessible to the institution’s stakeholders. Examples include the institution’s website and notice in a local newspaper.
- 184.108.40.206. Requirements for Submitting Third-Party Comments. To be considered in the accreditation process, comments must:
- Be submitted in writing to the President, Commission on Secondary Schools, 3624 Market Street 2 West, Philadelphia, PA 19104;
- Include the full name, address, telephone number of the commenter;
- Be signed;
- State the commenter’s relationship to the institution or how the commenter has knowledge of the institution’s ability to comply with the Standards for Accreditation;
- State the Standard(s) for Accreditation about which comments are provided;
- State the commenter’s evidence for the comment(s) about the institution’s ability to comply with the Standards for Accreditation; and
- Be received by the Commission not later than 30 calendar days prior to the date set for the first day of the onsite accreditation visit to the institution.
- 220.127.116.11. Review and Use of Third-Party Comments. All third-party stakeholder comments that meet the requirements of Section 18.104.22.168 of this policy shall be provided for consideration to both the institution and to the Chair of the Accreditation Visiting Team.
- Institution’s Response to Third-Party Comments. Because comments by third-party commenters provide the Commission with information and/or evidence regarding an institution’s ability to comply with the Standards for Accreditation of Career and Technical Institutions, the President of the Commission shall provide the comments received to the head of the institution prior to the visit of the Accreditation Visiting Team. The institution will be invited to respond to the Commission with comments and/or evidence in response to the comments. The institution may respond in a separate report or as an element of its Self-Study Document submitted to the Accreditation Visiting Team and the Commission.
- Review of Comments by the Accreditation Team. All comments that meet the requirements in 22.214.171.124., above received by the President of the Commission and any response to the comments by the institution shall be provided to the Chair of the Accreditation Visiting Team.
The Chair of the Accreditation Visiting Team shall consider the comments and any response by the institution together with other evidence observed during the visit when determining whether the institution complies with the Standard(s) for Accreditation that are the subject of the comments.
However, it shall not be the responsibility of the Accreditation Visiting Team to resolve any personal or individual issues presented in the comments.
The Accreditation Visiting Team shall not recommend or require any action of the institution based on comments by stakeholders unless the comments have been confirmed by other evidence observed and/or heard by the Team during the accreditation visit.