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Administrative Procedures for the Meetings of the Committees on Compliance and Reports

Policies
How a Committee on Compliance and Reports “meeting on the record” is structured — notification timelines, who may represent the institution, document deadlines, and recusal expectations.
Last Updated
June 1, 2021

Policy Statement

The Commission Board of Trustees is responsible for reviewing materials submitted by institutions and acting on the accreditation of institutions. As part of the process, the Board’s standing committees – Committees on Compliance and Reports – meet with representatives of institutions under the following circumstances:

  1. If there is a significant possibility that Commission action could include any of the following appealable actions:
  2. Denial of Candidacy for Initial Accreditation
  3. Removal from Candidacy for Initial Accreditation
  4. Denial of Initial Membership
  5. Removal from Membership
  6. If a meeting on the record has been requested by members of the Committees on Compliance and Reports, the Executive Council, or the President of The Commission.

Meetings on the record may result in a variety of actions, such as, reaffirmation (if appropriate), denial of reaffirmation and a sanction, continued accreditation with no sanction, continued accreditation with imposition or continuation of a sanction of Warning or Probation, denial of or removal from candidacy, or denial of or removal from membership. Final action on the accreditation status of institutions is taken only by The Commission Board of Trustees, subject to any appeals.

Procedures

The following procedures apply to meetings on the record conducted by any of the Committees on Compliance and Reports. The purpose of such a meeting is to seek clarification regarding information previously submitted to the Commission before developing a recommendation for Board of Trustee action.

  1. The President of The Commission will notify an institution of a possible or of definite meeting on the record at least 20 days prior to the beginning of the meeting of the Committees on Compliance and Reports (C&R) so that the institution has ample time to prepare for the interview. For an institution invited for a definite meeting on the record in accord with a previous notification by The Commission or its President, the letter will indicate the confirmed date, time, and location of the meeting; the reason for the interview – the standards cited as being out of compliance; the guidelines and deadlines for submitting additional information or documents; and directions for submitting the names of representatives appearing on behalf of an institution to ensure that the Commission receives the names ten working days in advance of the C&R meeting. For an institution notified of a possible meeting on the record pending a recommendation by C&R readers after a preliminary analysis of the case using documents provided by the Commission and the institution, the letter will indicate the reserved date, time, and location of the meeting; the reason for the possible interview – the standards cited as being out of compliance; the date by which the Commission will confirm whether there will be a meeting on the record (ten working days in advance of the C & R meeting); the guidelines and deadlines for submitting additional information or documents; and directions for submitting the names of representatives appearing on behalf of the institution to ensure that The Commission receives the names ten working days in advance of the C & R meeting. Notification and confirmation of the meeting on the record are transmitted electronically to the chief executive officer of the institution; the original letter is sent by guaranteed mail.
  2. The Chair of a Committee on Compliance and Reports presides during the meeting and is responsible for managing the session and ensuring that the Committee follows policies and procedures. The meeting on the record is structured as follows:
  3. The Committee Chair makes opening comments and outlines the procedures that will be used during the meeting on the record with the institution.
  4. The chief executive officer of the institution introduces institutional representatives and is provided a time-limited opportunity to discuss evidence of compliance outlined in documents and reports, submitted in advance by the institution that responds to issues of non-compliance to the standards identified The Commission visiting committee reports or in other documents submitted to the institution prior to the meeting on the record. An institution is expected to comply with The Commission policy concerning deadlines for submission of information, and failure to do so may be a basis for sanction. An institution that presents to the Committee on Compliance and Reports unsolicited information or information not submitted in a timely manner will be deemed to have waived any objections that it may have to any adverse consequences that may arise from the Committee considering that information. The Committee, at its discretion, may consider such information during its deliberations or it may disregard such information.
  5. The chief executive officer’s opening comments normally will not exceed ten minutes. Additional time is also provided for the chief executive officer, or other institutional officers/trustees, to respond to questions raised by the chair or members of the Committee on Compliance and Reports. Responses by the institution shall be based on information previously submitted to the Committee.
  6. The Committee Chair makes concluding remarks.
  7. The institution's chief executive officer represents the institution during the meeting on the record. The chief executive officer may select no more than four additional institutional employees, system employees, or board members to assist in responding to questions. If an institution plans to address financial issues, its accountant may be included as one of the four institutional representatives. Those selected must be able to attest to the institution's compliance with the Principles of Accreditation. Therefore, attendance by consultants or others under contract, or by public figures who are not employees or board members of the institution or system, is generally not appropriate. The chief executive officer has the right to have the institution’s legal counsel attend the meeting so that counsel can provide advice should any factual or procedural issues arise. If the institution should deem it essential that one of the five representatives be someone other than an institutional or system employee or board member, or an accountant, the institution's chief executive officer must submit a special request to the Chair of the Committee for permission for that person to appear before the Committee. This request should describe the substance of the information that this person is expected to provide and explain in detail why the institution's employees or board members cannot present the same, relevant information. This request should accompany the list of selected representatives which is submitted to the Chair of this Committee through The Commission office usually ten working days in advance of a Committee meeting. The Chair of the Committee on Compliance and Reports may approve or disapprove such a request for any reason. 4. The deadline for submitting documents for consideration by the Committee on Compliance and Reports is ten working days prior to the meeting of the Board of Trustees or one of its standing Committees. The institution may not provide additional materials, including video and audio presentations, to the Committee during the meeting on the record. All documents referred to during the meeting must have been submitted by the date required. (See Commission policy Deadlines for Reports and Profiles.) The President of The Commission may grant an exception to the deadline for submitting documents only in unusual circumstances and only for previously unavailable significant documents. In such cases, the institution must petition the President in writing and include copies of the documents. 5. The Commission expects members of its Board of Trustees and its standing committees to recuse themselves from decisions pertaining to any institution when representatives of the institution have attempted to influence a Board member or a member of The Commission on Colleges and Universities’s standing committee regarding the institution's impending case. In addition, current and former Board of Trustees serving on the board of an institution reviewed during the meeting must not attempt to exert external influence on sitting Board members who will take action on the institution. 6. A Committee meeting with an institution is on the record and is recorded by a court reporter. A transcription of the meeting, which does not include the Committee’s deliberations, will be available to the institution for the cost of transcribing. The minutes of the Committee will record the names of those individuals representing the institution during the meeting and the accreditation action recommended by the Committee and forwarded to the Board of Trustees for final action.
Document HistoryApproved: Commission on Colleges, December 2003 · Revised: Commission on Colleges, June 2006, June 2021 · Edited: December 2007, 2011 · Reformatted: August 2014; August 2018 Procedures revised: December 2019, June 2021
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