UNITED STATES DEPARTMENT OF EDUCATION
WASHINGTON, DC 20202

September 22, 2016
Roger 1. Williams, Interim President
750 First Street, NE, Suite 980
Washington, DC 20002-4241
rjwilliains@acics.org
Dear Mr. Williams,
I am writing to inform you of my decision regarding the recognition of the Accrediting Council
for Independent Colleges and Schools (ACICS, or the agency). Department of Education staff
and the National Advisory Council on Institutional Quality and Integrity (NACIQI) have each
made recommendations to me. These recommendations were made under Sections 114 and 496
of the Higher Education Act of 1965 (HEA), as amended, and pursuant to relevant statutory and
regulatory provisions.
Both the Department staff and NACIQI recommended that I deny ACICS's petition for
recognition and terminate ACICS's recognition as a nationally recognized accrediting agency.
As required, I considered the full record related to this matter-including ACICS's petition for
renewal, the final staff report from Department of Education staff, the transcript of the agency's
appearance before NACIQI on June 23, 2016, NACIQI's recommendation, and the comments
submitted under 34 C.F.R. §602.35 by both ACICS and Department staff after the NACIQI
meeting.
Having reviewed the record before me, I concur with the recommendations of Department staff
and NACIQL Accordingly, I am terminating the Department's recognition of ACICS as a
nationally recognized accrediting agency.
A CI CS was found to be in violation of numerous regulatory criteria. Department staff reviewed a
large amount of information from a variety of sources, and in the final staff report identified 21
areas where A CI CS was out of compliance with the applicable regulations. I agree that A CI CS is
out of compliance in these areas-specifically:

www.ed.gov

The Department of Education's mission is to promote student achievement and preparation for global competitiveness by
fostering educational excellence and ensuring equal access.

 34 C.F.R. §602.13
34 C.F.R. §602. lS(a)(l)
34 C.F.R. §602.15(a)(2)
34 C.F.R. §602.15(a)(3)
34 C.F.R. §602.!S(a)(S)
34 C.F.R. §602.15(a)(6)
34 C.F.R. §602.16(a)(l)(i)
34 C.F.R. §602.16(a)(l)(v)
34 C.F.R. §602.!6(a)(l)(vii)
34 C.F.R. §602.16(a)(l)(ix)
34 C.F.R. §602.16(a)(l)(x)

34 C.F.R. §602.l 7(a)
34 C.F.R. §602.17(c)
34 C.F.R. §602.18(d)
34 C.F.R. §602.19(b)
34 C.F.R. §602.20(a)
34 C.F.R. §602.20(b)
34 C.F.R. §602.2l(a)-(b)
34 C.F.R. §602.22(a)(3)
34 C.F.R. §602.24(c)(l)
34 C.F.R. §602.27(a)(6)-(7), (b)

Under the law, an accrediting agency that is out of compliance cannot have its recognition
renewed. Agencies may, however, be given up to 12 months to come into compliance. The
Department of Education staff report concluded that ACICS could not remedy many of the
·serious deficiencies identified and therefore come into full compliance within 12 months. During
the NACI QI meeting, citing their judgment based on many years of experience, Department staff
and multiple NACIQI committee members echoed the report's conclusions, despite recognizing
that ACICS could likely remedy some of the deficiencies in 12 months.
At the NACIQI meeting and in its comments submitted after the NACIQI meeting, ACICS
argued that it will be able to comply with each of the regulatory criteria within 12 months.
A CI CS points to a number of recent actions the agency has taken to address areas of noncompliance. I acknowledge that the agency has made recent efforts to address some of the
deficiencies identified-including by revising various policies and restructuring internal
governance bodies. Further, I recognize that it is possible for ACICS to fix some of the 21
compliance problems within 12 months. But overall, I agree with Department staff and NACIQI
that ACICS could not come into full compliance within 12 months.
These violations reveal fundamental problems with the agency's functions as an accreditor. For
example-and this list is not exhaustive-the staff report outlines major problems with: the rigor
of the agency's accreditation and preaccreditation standards and its application of those standards
(34 C.F.R. §§ 602.16(a) and 602.17); its monitoring of the institutions that it accredits (34 C.F.R.
§602.19(b )); and the enforcement of its own accrediting standards (34 C.F.R. §602.20).
ACICS's track record does not inspire confidence that it can address all of the problems
effectively. Many of the problems identified in the staff report are serious and long-standing. The
agency still has not fully addressed issues originally identified in 2013, such as its verification of
placement information from institutions. And most of the remedial efforts currently underway
began in earnest just several months ago, despite having reason to take action long before that.

 Finally, as made clear in 34 C.F.R. §§ 602.32(b) and 602.36(e), demonstrating compliance in this
case requires more than just new policies that address the issues identified by Department staff; it
requires evidence of effective application and implementation of those new policies, practices,
and governance structures, which the agency simply cannot provide for all of these criteria
within 12 months.
In sum, the evidence establishes that the recommendation of Department staff and NACIQI is
reasonable and well-justified. I concur with that recommendation.
Pending any appeal to the Secretary under 34 C.F.R. §602.37, my decision to withdraw and
terminate the Department's recognition from ACICS is the final decision of the Department.
Sincerely,
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Emma Vadehra
Chief of Staff