April 8, 2016
Dear Members of the National Advisory Committee on Institutional Quality and Integrity and the U.S.
Department of Education,
As organizations and advocates working on behalf of students, consumers, faculty and staff, and college
access, we write to ask NACIQI and the Department of Education to recommend that the Secretary deny
the application for recognition by the Accrediting Council for Independent Colleges and Schools (ACICS).
We come to this conclusion as firsthand observers of the substantial damage to the lives of hundreds of
thousands of students across the country caused by choices made by ACICS that have allowed lowperforming, predatory institutions of higher education access to billions of dollars in taxpayer funds. This
repeated inability of ACICS to act as a reliable authority concerning the quality of education or training
offered by the institutions of higher education or higher education programs it accredits has led
students to take on excessive levels of debt for training that is far too often of minimal value or outright
fraudulent. Many of these dollars now comprise the $130 million and growing in federal student loans
that must now be forgiven due to fraud and the closure of bad actors, to say nothing of the billions more
in Pell Grants received too. 1
In particular, we want to make sure NACIQI and the Department of Education are aware of four key
things when reviewing ACICS: (1) its poor track record of student outcomes, (2) the close ties between it
and executives from troubled colleges, (3) the substantial number of institutions it approved that are or
have been subject to federal and state investigations and settlements, and (4) a lack of any
acknowledgement that there may be a problem with the quality of its work.
Making the correct decision with ACICS is crucial for restoring integrity to the accreditation process. As
noted recently by Department of Education Undersecretary Ted Mitchell “in recent years, we’ve seen far
too many schools maintain their institutional accreditation even while defrauding and misleading
students, providing poor quality education, or closing without recourse for students.”2 Too often ACICS
has been the rubber stamp for federal aid while those things happened. Terminating its ability to allow
institutions of higher education into the federal financial aid programs is the only way to demonstrate
the problems are so serious that the status quo cannot continue. By contrast, failing to take action
would only empower all the other accreditation agencies to know that regardless of how poor your
track record is there will be no consequences.

Poor track record of student achievement
Regulations require that an accreditation agency be a “reliable authority regarding the quality of the
education or training provided by the institutions or programs it accredits” (34 CFR 602.16). Similarly,
the Higher Education Act requires that accreditors set standards that are “of sufficient quality to
achieve, for the duration of the accreditation period, the stated objective which the courses or programs
are offered” (Sec. 491(1)(4)(A)).
A review of student outcomes achieved at ACICS-accredited institutions casts significant doubt on the
agency’s ability to fulfill the two requirements mentioned above. Rather, it shows an agency that
consistently ranks among the worst accreditation agencies in terms of student performance, especially
in relation to debt. For instance, a September 2015 analysis by the Center for American Progress found
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 that the combined student loan default rate for ACICS-accredited institutions (21 percent) was among
the highest all other major accreditation agencies.3 Having such a poor default rate is particularly
troubling because the same analysis found that students at ACICS-accredited colleges were also more
likely to borrow than those at colleges approved by other major accreditors, and that when students did
borrow they took on more debt. 4
Subsequent analyses found similar results. A November 2015 story by ProPublica found that just 35
percent of students at institutions accredited by ACICS graduate.5 That result is 16 percentage points
worse than any of its peer agencies. The repayment outcomes for ACICS students are even direr. That
same ProPublica analysis found that 60 percent of borrowers at ACICS institutions had defaulted or
failed to make progress repaying their loans within three years of leaving school. That number is 13
percentage points worse than any peer agency.6
The unwillingness of ACICS to provide any documents related to its accreditation process makes it
impossible to discern exactly why the agency is incapable of producing outcomes that even approach
the mediocrity seen at its peer accreditors. Regardless of whether these outcomes are the result of
insufficiently rigorous standards, improper enforcement of standards, or lack of reliable decisionmaking, their consequences are too severe to ignore.

Ties between ACICS and institutional executives
When ACICS went before NACIQI in 2011, Department of Education staff raised concerns that the
agency relied too much upon institutional administrators in its work and lacked sufficient representation
from other constituencies.7 This matters because a lack of diverse voices may undermine the ability to
identify and address serious problems. It also risks cultivating a culture of reciprocal favors, whereby
leaders of troubled colleges agree to give each other a pass on accreditation visits to make their own
reviews easier.
Though ACICS promised to address this problem, recent reports indicate that the organization still
suffers from being too closely connected with executives from troubled colleges. A February 2016
review by ProPublica found that two-thirds of ACICS commissioners are current or former college
executives.8 Even more troubling, one out of every three are representatives from institutions that have
or are facing serious legal challenges from state and federal government actors.
The most egregious instance of these questionable relationships concerns Corinthian Colleges. As noted
by ProPublica, ACICS tapped Beth Wilson to serve as a commissioner in a 2013 election.9 The California
attorney general alleges that Wilson, a former executive vice president at Corinthian Colleges, was one
of the leaders who ordered staff at the college chain to falsify job placement rates.10 Wilson also
previously worked at National College, another institution accredited by ACICS that was sued by the
Kentucky attorney general in 2011 for allegedly faking job placement rates.11 Though Wilson has since
resigned, it is deeply troubling that ACICS thought someone who played a role in perpetrating fraud on a
national scale could be acceptable as a commissioner for an organization tasked with evaluating quality
assurance.
Sadly, Beth Wilson is not the only case of entrusting quality assurance decisions to someone whose
institution is under fire for fraud and misrepresentation. ProPublica notes that ACICS has also tapped
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 executives from ITT Technical Institute, Lincoln Educational Services, Globe University/Minnesota School
of Business, and another Corinthian executive at various times.12 All of these organizations have been or
currently are being sued or investigated by government actors.13

Substantial numbers of ACICS-accredited institutions under investigation
What do Corinthian Colleges, Westwood College, and FastTrain College all have in common? They’ve all
been sued and shut down by state and federal agencies following allegations of substantial
wrongdoing.14 They also all gained access to the federal financial aid programs at least partly through
ACICS.
Comparing the list of institutions of higher education that have faced legal action from state and federal
government officials with the accreditation agencies that allowed them to participate in the student aid
programs reveals a troubling pattern—at least 17 troubled colleges or companies relied on ACICS to get
access to the federal grant and loan dollars they later exploited.15 Even more troubling, ACICS removed
the accreditation for just one of these institutions—Anamarc College, which was raided by the Federal
Bureau of Investigation in 2014 after its abrupt closure.16 In that case ACICS denied the college’s
accreditation in August 2014 after the college already announced its closure.17 With respect to
Corinthian Colleges, ACICS Executive Director Albert Gray testified before the Senate Health, Education,
Labor, and Pensions (HELP) Committee in June 2015 that not a single campus was out of compliance
with his organization’s criteria when it fell apart in mid-2014.18
Not only does ACICS have a substantial track record of approving colleges with problems, it often holds
them up as paragons of the accreditation process. Of the 17 colleges and companies accredited by ACICS
that have faced serious legal trouble, nine were acknowledged as “honor roll” institutions by the
organization over the last five years.19 Several times this recognition came right as the entire company
was falling apart under legal scrutiny. For example, ACICS named two campuses run by Corinthian
Colleges to its honor roll in November 2014, just a few months after the Department of Education
effectively forced the college to shutter or sell off its assets.20
Similarly, ACICS named four campuses operated by the Career Education Corporation to its honor roll in
2011—the same year the company disclosed widespread improper job placement rates.21 Westwood
College, owned by Alta Colleges, also had campuses named to the honor roll in 2009 and 2014—one
year before and one year after settlements with the U.S. Department of Justice and the Illinois attorney
general, respectively.22
Accreditors have substantial responsibility in the federal student aid programs. They are the only actors
with the resources, time, and legal ability to conduct in-depth reviews of the quality of institutions and
programs. Their blessing provides access to billions of dollars in student loans and grants. Because of
this role, an accreditor failing to fulfill its responsibility as a reliable authority on the quality of
institutions and programs exposes students and taxpayers to tremendous amounts of harm and fraud.

Failing to acknowledge a problem
The above sections detail serious problems with ACICS’s work as an accreditor that cast substantial
doubt on the quality of its judgment and ability to act as any kind of arbiter of quality. Yet not only does
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 the agency fail to acknowledge any necessary improvement, it actively defends the success of its current
work.
ACICS’s response to the Corinthian situation has been to deny there was a problem. During his
testimony before the Senate HELP Committee last June, Albert Gray, ACICS’s executive director, told
Senators that his organization purportedly conducts its own investigations whenever allegations arise
against an institution it accredits. With respect to Corinthian Colleges, he stated “we found no evidence
that they [Corinthian] lied to their students or defrauded them.”23 When pressed further on whether
ACICS had made any sort of error with respect to its oversight of Corinthian he stated “I’d be the first to
admit that accreditors like any other organization make mistakes. This was not one of those mistakes.”24
It seems impossible that ACICS could have conducted anything resembling a rigorous investigation of the
allegations against Corinthian and come up with no problems. After all, detailed reviews of job
placement rates by the U.S. Department of Education and the attorney general for the state of California
turned up repeated instances of falsified job placement rates.25 And these allegations that ACICS
dismissed had enough weight behind them in a court of law, leading to a recent $1.1 billion judgment
against Corinthian Colleges.26
Such lack of contrition suggests the issues at ACICS go far deeper than any sort of tweaks or
improvements could make. It paints a picture of an agency that turns a blind eye to severe instances of
fraud, even when allegations or findings by outside government organizations give them a clear path for
where to look. It also demonstrates that simply enforcing a few restrictions on the agency will do
nothing to change its behavior since it believes—and has said before Congress—it has done nothing
wrong.

Conclusion
ACICS has failed to fulfill its role and mission as an accreditation agency that is expected to act as a
reliable authority on institutional quality. It has repeatedly relied upon executives of troubled colleges to
make final decisions about allowing colleges into the federal aid programs. It has not only failed to act
when other actors do ACICS’s job for it, but held up many troubled colleges and companies as role
models for the accreditation process. Unsurprisingly, such lax gatekeeping has resulted in the worst
student outcomes of any major accreditor—a trail of numbers that represents a massive toll of human
devastation across the country. It has left low-income students burdened by debts they have no hope of
repaying after being lied to and lured into programs of questionable quality through false promises and
statistics.
Many of these problems would likely have been caught had ACICS done its job in the manner required
by regulations and its own standards. Most of these investigations and settlements resulted from
allegations of falsified job placement rates—a measure the agency claims it uses to judge the
institutions of higher education it accredits as well as their programs. Yet failing to do sufficient due
diligence to ensure that colleges were truthful in the figures reported to ACICS allowed students to be
deceived time and again. And its continued lack of any regret in its choices demonstrate that the agency
would do everything exactly the same way again.

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 Decisions made by NACIQI and the U.S. Department of Education have significant implications for the
integrity of the accreditation process. Allowing this troubled actor to continue its laissez-faire attitude
toward quality assurance weakens the effectiveness and purpose of the entire system. Restoring trust in
the system can only be accomplished by sending a strong and clear message that failing to live up to the
requirements of the triad will be met with swift and meaningful punishment.
In a recent post on Ed.gov, Undersecretary Ted Mitchell wrote “Accreditation can and must be the mark
of quality that the public expects.”27 For that to be true, ACICS can no longer be part of the process.

Sincerely,
American Association of State Colleges and Universities (AASCU)
Americans for Financial Reform
Campaign for America’s Future
Center for Public Interest Law of the University of San Diego School of Law
Center for Responsible Lending
Children’s Advocacy Institute of the University of San Diego School of Law
Consumer Action
Consumers Union
Faculty Forward Network
Generation Progress
Higher Ed, Not Debt
The Institute for College Access & Success (TICAS)
Mississippi Center for Justice
National Consumer Law Center, on behalf of its low-income clients
National Women Veterans Association of America
Project on Predatory Student Lending at the Legal Services Center of Harvard Law School
Service Employees International Union (SEIU)
Student Debt Crisis
USPIRG
Veterans Education Success
Veterans for Common Sense
VetJobs
Young Invincibles

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U.S. Department of Education, “U.S. Department of Education Announces Path for Debt Relief for Students at 91 Additional
Corinthian Campuses,” available at http://www.ed.gov/news/press-releases/us-department-education-announces-path-debtrelief-students-91-additional-corinthian-campuses
2 Ted Mitchell, “ Strengthening Accreditation to Protect Students,” available at http://blog.ed.gov/2016/03/strengtheningaccreditation-to-protect-students/
3 The Accrediting Council for Continuing Education and Training had a default that was one-tenth of one percentage point lower
than the figure for ACICS. Ben Miller, “Up to the Job: National Accreditation and College Outcomes” (Washington: Center for
American Progress, 2015), available at https://www.americanprogress.org/issues/highereducation/report/2015/09/08/119248/up-to-the-job/
4 Ibid.
5 Annie Waldman, “Who Keeps Billions of Taxpayer Dollars Flowing to For-Profit Colleges? These Guys,” ProPublica, November
3, 2015, available at https://www.propublica.org/article/accreditors-billions-of-taxpayer-dollars-flowing-to-for-profit-colleges
6 Ibid.
7 U.S. Department of Education, “Staff Report to the Senior Department Official on Recognition Compliance Issues,” pages 2223, available at https://www2.ed.gov/about/bdscomm/list/naciqi-dir/2011-spring/staff-analyses-6-2011.pdf.
8 Annie Waldman, “Who’s Regulating For-Profit Schools? Execs from For-Profit Colleges,” ProPublica, February 26, 2016,
available at https://www.propublica.org/article/whos-regulating-for-profit-schools-execs-from-for-profit-colleges.
9 Accrediting Council for Independent Colleges and Schools, “New Commissioner Bios,” available at
http://www.acics.org/commission%20actions/content.aspx?id=5767.
10 Waldman, “Who’s Regulating For-Profit Schools.”
11 Jack Brammer, “Attorney General Jack Conway Sues National College of Kentucky,” Lexington Herald, September 28, 2011,
available at http://www.kentucky.com/news/politics-government/article44128146.html.
12 Waldman, “Who’s Regulating For-Profit Schools.”
13 U.S. Securities and Exchange Commission, “SEC Announces Fraud Charges Against ITT Educational Services,” May 12, 2015,
available at https://www.sec.gov/news/pressrelease/2015-86.html; The Attorney General of Massachusetts, “AG Healey
Secures Additional $2.3 Million for Students Misled by For-Profit Schools,” July 30, 2015, available at
http://www.mass.gov/ago/news-and-updates/press-releases/2015/2015-07-30-for-profit-schools-settlements.html; and The
Office of the Minnesota Attorney General, “Minnesota Attorney General Lori Swanson Files Lawsuit Against Minnesota School
of Business and Globe University,” July 22, 2014, available at
http://www.ag.state.mn.us/Office/PressRelease/20140722SchoolofBusiness.asp.
14 U.S. Department of Education, “U.S. Department of Education Heightens Oversight of Corinthian Colleges,” June 19, 2014,
available at http://www.ed.gov/news/press-releases/us-department-education-heightens-oversight-corinthian-colleges; Ashley
Smith, “Fall of a For-Profit,” Inside Higher Ed, December 8, 2015, available at
https://www.insidehighered.com/news/2015/12/08/profit-westwood-college-wont-accept-new-students; and U.S. Attorney’s
Office Southern District of Florida, “FastTrain Owner and Admissions Representative Convicted of Federal Student Aid Scheme,”
November 24, 2015, available at https://www.justice.gov/usao-sdfl/pr/fasttrain-owner-and-admissions-representativeconvicted-federal-student-aid-scheme.
15 Center for American Progress analysis of data from U.S. Department of Education, “The Database of Accredited
Postsecondary Institutions and Programs,” available at http://ope.ed.gov/accreditation/Search.aspx (last accessed April 4,
2016) and David Halperin, “Law Enforcement Investigations and Actions Regarding For-Profit Colleges,” Republic Report, last
updated April 4, 2016, available at http://www.republicreport.org/2014/law-enforcement-for-profit-colleges/
16 Kvia, “FBI searches Anamarc College, Home of College’s Owners,” August 27, 2014, available at
http://www.kvia.com/news/fbi-raids-anamarc-college/27752626.
17 Tricia Martinez, “Anamarc College Fires Teachers Cancels Classes, What’s Next,” Kiss FM EL Paso, July 2, 2014, available at
http://kisselpaso.com/update-anamarc-college-fires-teachers-cancels-classes-whats-next/.
18 U.S. Senate Committee on Health, Education, Labor, & Pensions, “Reauthorizing the Higher Education Act: Evaluating
Accreditation’s Role in Ensuring Quality,” minute 101, available at http://www.help.senate.gov/hearings/reauthorizing-thehigher-education-act-evaluating-accreditations-role-in-ensuring-quality.
19 See the detailed public comment submitted by the Center for American Progress for more on this statistic.
20 Accrediting Council for Independent Colleges and Schools, “ACICS Annual Conference and Business Meeting,” November 3-5
2014, available at http://acics.org/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=6286&libID=6271, page 30.
21 Career Education Corporation, “Career Education Corporation Schools Enter ‘Show Cause’ Status with Accreditor,” available
at http://www.careered.com/press-room/press-releases/career-education-corporation/career-education-corporation-schoolsenter-show-cause-status-with-accreditor.
22 Accrediting Council for Independent Colleges and Schools, “Annual Meeting and Leadership Conference 2009 Program,” June
12-13 2009, available at http://acics.org/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=4134&libID=4173, page 8, and

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 Accrediting Council for Independent Colleges and Schools, “Accrediting Council for Independent Colleges and Schools, “ACICS
Annual Conference and Business Meeting,” page 30
23 U.S. Senate Committee, “Evaluating Accreditation’s Role,” minute 116.
24 Ibid, minute 119.
25 U.S. Department of Education, “Department of Education and Attorney General Kamala Harris Announce Findings from
Investigation of Wyotech and Everest Programs,” available at http://www.ed.gov/news/press-releases/department-educationand-attorney-general-kamala-harris-announce-findings-investigation-wyotech-and-everest-programs.
26 Associated Press, “California awarded $1.1B judgement against for-profit college,” Washington Post, March 24, 2016,
available at https://www.washingtonpost.com/national/higher-education/california-awarded-11b-judgment-against-for-profitcollege/2016/03/24/223dd4e6-f1fc-11e5-a2a3-d4e9697917d1_story.html.
27 Mitchell, “Strengthening Accreditation.”

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