Tuesday, July 10, 2012

Letter to North Central/Higher Learning Commission Regarding UIU

Back in 2003, I asked for  assistance from the Higher Learning Commission (UIU's accreditors), and they referred me to the Department of Education, which of course, was unresponsive. I then proceeded to send HLC a list of their own accreditation criteria, noting the areas where UIU failed to meet HLC requirements. Then, I copied communications I received from instructors, administrators, etc. I Cc'd all of this to the Department of Education, which also denied having any authority in my case. When I tried to contact HLC again, I received a rude, verbal response from the secretary who would not put me through to the director.

Below is what I sent to HLC. Note the bickering between UIU instructors and their interpretation of UIU's program.

Interestingly enough, when I later requested from the Department of Ed all my documents and communications relating to UIU, ED sent me a few sheets of paper, none of which included the extensive complaints I had sent to Chicago. When I asked them about this, the ED investigator said that's all they had on record. Yet, here I was sitting with a pile of the original communications I had retained for my own files, which means ED must have tossed or lost the documents I sent them. 


Katherine M. Mercurio
306 George St. SW
Vienna VA  22180
Re:  Union Institute and University
Cincinnati Ohio

The following is the criteria specified for accreditation through North Central.  I used red font to indicate areas in which UIU has demonstrated lack of response. I have used blue font to comment.  This document contains complaints related to accreditation issues and does not address my attempts to have personal complaints resolved within the University which I know is outside NCA’s jurisdiction.

Higher Learning Commission of the North Central Association
.A.1a. ACCREDITATION (Adopted August 1992; Revised February 2001; Revised February 2002)
The Commission's evaluation for accreditation, either initial or continuing, seeks to ascertain that an institution of higher education meets the following:
  1. The General Institutional Requirements as adopted by the Commission.
  2. The following five Criteria for Accreditation:
CRITERION ONE: The institution has clear and publicly stated purposes consistent with its mission and appropriate to an institution of higher education.
In determining appropriate patterns of evidence for the criterion, the Commission considers evidence such as:
a.     long- and short-range institutional and educational goals.
b.    processes, involving its constituencies, through which the institution evaluates its purposes.
c.     decision-making processes appropriate to its stated mission and purposes.
d.    understanding of the stated purposes by institutional constituencies.
e.     efforts to keep the public informed of its institutional and educational goals through documents such as the catalog and program brochures.
f.     support for freedom of inquiry for faculty and students institutional commitment to excellence in both the teaching provided by faculty and the learning expected of students. UIU provides no teaching at the graduate level.  Seminars are facilitated by faculty who permit students to structure the timeline and learning environment regardless of group dynamic and topic (example:  an April 2000 seminar in D.C. became a complaint session for students dissatisfied with the program, a forum to discuss sexual discrimination in Southern Virginia, and a round-table on necrophilia.)

The institution has effectively organized the human, financial, and physical resources necessary to accomplish its purposes.
In determining appropriate patterns of evidence for the criterion, the Commission considers evidence such as:
g.    governance by a board consisting of informed people who understand their responsibilities, function in accordance with stated board policies, and have the resolve necessary to preserve the institution's integrity.
h.     effective administration through well-defined and understood organizational structures, policies, and procedures. If these are well defined at the Doctoral level, they are not communicated to the student.  Expectations on major documents such as the Learning Agreement are inconsistent between faculty members and administration.  The staff turnover in the various administrative departments has led to miscommunication on policy and procedure.
i.      qualified and experienced administrative personnel who oversee institutional activities and exercise appropriate responsibility for them. Faculty communicate emphasis on keeping the student in the program, disregarding academic deadlines set by the student and paying tuition regardless of work produced.  (SEE BELOW)
j.      systems of governance that provide dependable information to the institution's constituencies and, as appropriate, involve them in the decision-making processes.  The Graduate Learner Council has been seeking a place in the administrative council in order to allow graduate students to have a voice in the University.  Thus far, this request has been denied by UIU.
k.     faculty with educational credentials that testify to appropriate preparation for the courses they teach.
l.      a sufficient number of students enrolled to meet the institution's stated educational purposes.
m.   provision of services that afford all admitted students the opportunity to succeed. There are few resources available to low-residency students.  Instructors are continuously unavailable (see e-mails), staff is contradictory (see e-mail), and responsibility for research is on the shoulders of the student.  Students write their own curriculum, their own courses, and their own transcripts with little assistance from faculty and staff.
n.     a physical plant that supports effective teaching and learning. Students organize where the learning will take place, and when seminars are scheduled through the University, they are done so at sites that are not licensed by appropriate state authorities.  The residencies provide bare-minimum accommodations for students, no resources, and full cost:  books, transportation, accommodation, etc.
o.    conscientious efforts to provide students with a safe and healthy environment.
p.    academic resources and equipment (e.g., libraries, electronic services and products, learning resource centers, laboratories and studios, computers) adequate to support the institution's purposes. UIU’s Campus Web provides general resources that students can access without being enrolled and paying tuition.
q.    a pattern of financial expenditures that shows the commitment to provide both the environment and the human resources necessary for effective teaching and learning. UIU receives millions of dollars in funding through financial aid and tuition, yet the program itself, including evaluations, is developed and conducted by the students.  There have been complaints lodged by more than one student of inequitable tuition policies, inconsistent handling of accounts, and exorbitant administrative expenditures.
r.      management of financial resources to maximize the institution's capability to meet its purposes. If the purpose of the institution is to collect funds from students, then the goal has been reached.  If the purpose is to educate and award meaningful degrees, the goal has been missed completely.

CRITERION THREE: The institution is accomplishing its educational and other purposes.
In determining appropriate patterns of evidence for the criterion, the Commission considers evidence such as:
s.     educational programs appropriate to an institution of higher education:
§  courses of study in the academic programs that are clearly defined, coherent, and intellectually rigorous; The students on this program are responsible for writing the program from the planning through transcript stages.  Students receive feedback that is not academic in content but rather focuses on superficial aspects of the program (such as bibliographies).  Assessment is inconsistent and in some cases, nonexistent since faculty who are not experts in fields of study are assessing doctoral documents. (SEE BELOW)
§  programs that include courses and/or activities whose purpose is to stimulate the examination and understanding of personal, social, and civic values;
§  programs that require of the faculty and students (as appropriate to the level of the educational program) the use of scholarship and/or the participation in research as part of the programs;
§  programs that require intellectual interaction between student and faculty and encourage it between student and student. The faculty is rarely available, and any interaction is the responsibility of the student.
t.      assessment of appropriate student academic achievement in all its programs, documenting:
§  proficiency in skills and competencies essential for all college-educated adults;
§  completion of an identifiable and coherent undergraduate level general education component;
§  mastery of the level of knowledge appropriate to the degree granted.
§  control by the institution's faculty of evaluation of student learning and granting of academic credit.
u.     graduate program that:
§  distinguish clearly graduate from undergraduate offerings;
§  expect students and faculty to value and engage in research, scholarship, and creative activity;
§  restrict graduate academic credit for prior learning to credit validated by examination, credit based on documented faculty evaluation of a portfolio of original work products, or credit awarded by an institution of higher education either affiliated with a recognized U.S. accrediting association or approved by an appropriate national ministry of education;
§  are approved, taught, and evaluated by a graduate faculty that possesses appropriate credentials and experience; and As indicated previously, seminars are run by students while faculty serve merely as passive facilitators in most cases.  Peer days are convened and planned by students.  Evaluations are completed by students.  Faculty evaluating areas of study are not mandated to hold degrees in that field.  Students do not know who reads/evaluates dissertations/PDE’s. 
§  use results of regular internal and external peer review processes to ensure quality.
v.     faculty have and exercise responsibility for determining the institution's award of academic credit. (Adopted February 2001)
w.    effective teaching that characterizes its courses and academic programs. There is little if any teaching in this program; this does indeed characterize the program as a whole.
x.     ongoing support for professional development for faculty, staff, and administrators.
y.     student services that effectively support the institution's purposes.  There are no student services.  The main contention among dissatisfied students is the lack of administrative response to complaints, inadequate dispute resolution processes, no University supported student forum, and inconsistent application of policy and procedure.
z.     staff and faculty service that contributes to the institution's effectiveness For many, there is little connection between the learner and faculty.
aa.  if appropriate:
§  evidence of support for the stated commitment to basic and applied research through provision of sufficient human, financial, and physical resources to produce effective research; UIU appears to maintain the minimum staff and faculty requirements.  Although this is a low residency program, faculty are not required to be technologically adept, and they can refuse common transmissions such as e-mail. (SEE BELOW)
§  evidence of support for the stated commitment to the fine and creative arts through provision of sufficient human, financial, and physical resources to produce creative endeavors and activities; Creative endeavors are limited since faculty do not have to remain technologically current and resources are dependent on the resourcefulness of the student.  (See Below)
§  evidence of effective delivery of educational and other services to its community;
§  evidence of development and offering of effective courses and programs to meet the needs of its sponsoring organization and other special constituencies.

The institution can continue to accomplish its purposes and strengthen its educational effectiveness.
In determining appropriate patterns of evidence for the criterion, the Commission considers evidence such as:
bb.  a current resource base financial, physical, and human that positions the institution for the future.
cc.  decision-making processes with tested capability of responding effectively to anticipated and unanticipated challenges to the institution.
dd.  structured assessment processes that are continuous, that involve a variety of institutional constituencies, and that provide meaningful and useful information to the planning processes as well as to students, faculty, and administration.
ee.  plans as well as on-going, effective planning processes necessary to the institution's continuance.
ff.    clear identification of how the institution can strengthen its educational programs.
gg.  resources organized and allocated to support its plans for strengthening both the institution and its programs.

The institution demonstrates integrity in its practices and relationships.
In determining appropriate patterns of evidence for the criterion, the Commission considers evidence such as:
hh.  student, faculty, and staff handbooks that describe various institutional relationships with those constituencies, including appropriate grievance procedures.
ii.     policies and practices for the resolution of internal disputes within the institution's constituency. Dispute resolution has proven to be ineffective and falls to the hands of concerned students.  (See Below)
jj.     policies and practices consistent with its mission related to equity of treatment, non-discrimination, affirmative action, and other means of enhancing access to education and the building of a diverse educational community.
kk.  transcripts that follow commonly accepted practices and accurately reflect a student's academic experience. (Adopted February 2001) Students form their own transcripts which can not be transferred mid-program since no other institution will recognize such a process.  See Student Handbook for details.
ll.     institutional publications, statements, and advertising that describe accurately and fairly the institution, its operations, and its programs.
relationships with other institutions of higher education conducted ethically and responsibly. The incestuous relationship between Vermont College and UIU has roused media interest.  UIU has attempted to gain educational licensure in D.C. under the Vermont College umbrella and was refused.  However, seminars continue to be scheduled at this “site.”
mm.                appropriate support for resources shared with other institutions.
nn.  policies and procedures regarding institutional relationships with and responsibility for intercollegiate athletics, student associations, and subsidiary or related business enterprises.
oo.  oversight processes for monitoring contractual arrangements with government, industry, and other organizations.

The Commission can add to, delete, and revise the lists of evidence after publishing notice of the proposed changes. Any changes to the stated criteria must be circulated to the membership for comment before final Commission approval.
Institutions must have accreditation reaffirmed not later than five years following initial accreditation, and not later than ten years following a reaffirmation. The time for reaffirmation is made a part of the accreditation decision, but may be changed if the institution experiences or plans changes.

The judgment that the institution meets the criteria is based on detailed information about all parts of the institution. This information may be in a self-study report, a series of documents resulting from self-evaluation processes, or other institutional documents. It can be confirmed in the written report of the visiting team; in the pattern of portfolios, reports, and appraisals required of institutions participating in the AQIP processes; or in other documents agreed to by the Commission and the institution as core elements of a customized process for continued accreditation.

If the institution has graduated its first class not more than one year before the Commission’s evaluation, the effective date of accreditation will be the date of the graduation of the first class.

I.A.1b. CANDIDACY (Adopted August, 1992. Revised August 1996, effective September 1, 1996;

©2001 Higher Learning Commission of the North Central Association
Direct inquiries and comments about this site to webmaster@hlcommission.org

courses of study in the academic programs that are clearly defined, coherent, and intellectually rigorous;
“I assume you have not had a response from Merv C.  I believe he is not taking
on any new learners for any role.  Even if he were, I would be uncomfortable
working with him on a learner's committee.  We are too far apart on our
interpretations of UIU.” “I also am uncomfortable working with Arlene Sacks on a learner's committee.  I don't want a learner to be caught between widely differing perspectives on the Union requiements and process.  So, please strike Arlene from your list.” (Excerpts from Faculty communication concerning extensive search for Second Core, UIU faculty committee member)

human, financial, and physical resources to produce creative endeavors and activities;
“However, I do not accept documents as attachments to e-mail.  When you are ready to send me your Learning Agreement you must do so in hard copy.” (Excerpt from faculty communication regarding specific request to read electronic copy since the content focused on distance learning/we-based curricula)

policies and practices for the resolution of internal disputes within the institution's constituency
“I just read your letter again.  These people never cease to amaze me.  We all
know that when someone is on speaker phone everyone identifies themselves. 
That's just plain rude!  What's more it just sends the message one more time
that they cannot be trusted.  I'm very disappointed that an institution that
is supposed to be learner centered would do such a thing.  And, Emily Harbold
is associate vice provost for learner services.  Anyone in that position
cannot afford to participate in such unfair tactics.  She just as well resign
because no one will go to her with their issues.  And, if the "other
interested parties" happened to be an attorney.....that's really foul.  All
of the attorneys I have worked with regarding such matters as this would
never allow what occurred.

Again, I am truly sorry that they put you through this surprise phone call. 
My anger is just about at the "white coals in the grill" level.”  (Excerpt from Graduate Learner Council Chair communication for internal dispute resolution.)

qualified and experienced administrative personnel who oversee institutional activities and exercise appropriate responsibility for them.

”Before I give you available dates, I assure you that the September "deadline"
is an artifact of external pressures.  The Dean's Office understands the
difficulties of arranging a meeting, often when all the documents are in good
order.  A message from me that you are finalizing the LA and/or the meeting
date is sufficient to gain an extension.  So, don't worry about that aspect. “  (Excerpt from e-mail sent to learner regarding continued delay of certification meeting.)

RE:  Appropriate facilities for residencies:
“The Union Institute and University does not have authority from the District of Columbia Education Licensure Commission ("the Commission") to operate in Washington, DC.
DC Code Title 31, Sub-section 1609(a)(1), provides in pertinent part, that no person or postsecondary educational institution incorporated in the District of Columbia or outside the District of Columbia shall operate a postsecondary educational institution in the District of Columbia, offer postsecondary education, have the power to grant or confer or offer to grant or confer a postsecondary degree or diploma or certificate, unless the institution is granted a license to do so from the Commission.”

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