University Planning

Federal Compliance

Federal Compliance: The 1992 and 1998 Amendments to the Higher Education Act, and subsequent changes to federal regulations by the U.S. Department of Education, put into law several requirements for accrediting agencies that seek federal recognition. This section requires Western Illinois University to document its:

Credits, program length, and tuition

Commission policy states:

The Commission expects an affiliated institution to be able to equate its learning experiences with semester or quarter credit hours using practices common to institutions of higher education, to justify the lengths of its programs in comparison to similar programs found in accredited institutions of higher education, and to justify any program-specific tuition in terms of program costs, program length, and program objectives. Affiliated institutions notify the Commission of any significant changes in the relationships among credits, program length, and tuition.

The key components of this policy address an organization's ability to

  • Provide semester or quarter credit hour equivalencies for transcript courses (courses on transcripts, for example, that provide narrative evaluation or that simply list courses completed)
  • Justify the total number of credit hours in accordance with credit hour expectations for similar programs in other accredited institutions
  • Justify any program-specific tuition

Institutional compliance with the Higher Education Reauthorization Act

Commission policy states:

The Commission expects that its affiliated institutions comply if required with the Title IV requirements of the Higher Education Reauthorization Act as amended in 1998. Therefore, institutions will provide teams for review and consideration the most recent default rates (and any default reduction plans approved by the Department of Education) and any other documents concerning the institution's program responsibilities under Title IV of the Act, including any results of financial or compliance audits and program reviews.

The teams weigh the information and its relationship to the Criteria for Accreditation or the requirements of the Candidacy Program. If a team determines that an institution's failure to meet Title IV default rate thresholds raises significant issues concerning the quality of education provided by the institution or the institution's ability to meet all other Commission requirements, it may recommend further monitoring, probation, or withdrawal of affiliation. The Commission reserves the right to review an institution's status when the Department of Education findings have proven significant noncompliance with the Act.

All organizations receiving Title IV funds need to provide copies of documents relevant to Title IV compliance (or, at a minimum, a clear index of where those documents might be readily found in organizational files). Such documents will typically include program participation agreement (PPA); Eligibility and Certification Renewal (ECAR); program reviews; information about compliance with financial responsibility standards; limitation, suspension, or termination (LST) actions; audits by the Inspector General of the USDE; and the default rate for the most recent three years as established by the USDE.

The organization will also want to provide any other documents with significant information about compliance with the administrative or recordkeeping requirements of Title IV. The self-study report should evaluate the organization's default rate, if any, and its plans for reducing default. If renewal of eligibility, program audits, or other USDE actions raise significant issues, the organization will want to address those issues and subsequent corrective measures in the self-study report.

Although the primary focus of this policy is on compliance with Title IV program responsibilities, organizations should comment briefly on their compliance with other Title IV-mandated student notification requirements such as campus crime-reporting and release of completion/graduation rates, with particular focus on deficiencies or corrective actions demanded by the USDE or other governmental agencies. It is a matter of institutional integrity that organizations provide all relevant information for the team.

Only the Department of Education can establish that an organization has complied with the many responsibilities of Title IV. However, the team will study the materials related to Title IV compliance to determine whether the organization's status with the Department of Education in any way affects its status with the Commission. Clearly, if the fiscal stability of the organization is in jeopardy or if program reviews by the Department or audits by the Inspector General highlight significant lapses in integrity, the team must determine how the organization's relationship with the Commission should be affected. Monitoring through reports or focused visits might be appropriate; in exceptional circumstances, a team might consider probation or withdrawal of status. Should the team discover that the organization appears to have failed to meet its Title IV program responsibilities or is engaged in fraud and abuse, the Commission has an affirmative responsibility to provide this information to the Department of Education.

Federal compliance visits to off-campus locations

Federal regulations for recognition of accrediting agencies require the Commission to conduct a variety of evaluation activities to review and monitor the development of off-campus sites and campuses. Some activities occur at the time of approval of a new site, while other activities occur after the site or campus has been in operation for a period of time or when the institution has multiple sites in place.

The Commission has determined that an off-campus site is a location at which a student can complete fifty percent or more of a degree program. A degree-completion site qualifies as an off-campus site when students in the program can complete all required courses there. Any site at which less than fifty percent of a degree program can be completed is considered a course location.

In compliance with the federal requirement, the Commission conducts

  • A site visit for each of the first three off-campus sites an organization establishes
  • A site visit to an organization with multiple off-campus sites within five years of its last comprehensive evaluation
  • A site visit or another form of monitoring for an organization that is experiencing a rapid growth of sites
  • A visit before extending accreditation to include a new site for an organization under Commission sanction, or experiencing serious financial problems, or already known for having inadequate quality assurance processes

Typically, a site visit will constitute Commission review. However, in some cases a focused visit may be appropriate. This review applies to organizations in both PEAQ and AQIP.

A site visit can be conducted by a peer reviewer or by a staff member. The site visitor determines whether the site meets the description provided when the organization sought approval for its inclusion in its accredited status. The visitor submits a report to the Commission, which acknowledges the report and adds it to the official file that will be shared with the next evaluation team or AQIP review process. If the report identifies issues deserving further Commission monitoring, the organization is asked to submit a response, and Commission staff take the recommendation and response to the next scheduled Institutional Actions Council meeting.

Institution's advertising and recruitment materials

This policy clarifies the Commission's concern about accurate consumer information, particularly advertising and recruiting materials. Organizations and teams should especially note that whenever an organization makes reference to its affiliation with the Commission, it will include the Commission's address and phone number.

The policy covers any reference to the organization's status with the Commission, including references in radio messages and television ads and on billboards. In including the Commission's contact information, the organization should use the URL of the Commission's Web site, rather than the street address, and its local, rather than toll-free, phone number. To avoid confusion, particularly among prospective students, organizations should clearly and prominently provide their own contact information so students know how to reach them. USDE added this requirement in its regulations for accrediting agency recognition to make sure consumers know how to reach the responsible accrediting agency with questions or concerns.

Professional accreditation

The University's XX Undergraduate Catalog displays the XX professional associations granting discipline-based accreditation to academic programs and nonacademic services at the University. All teacher preparation programs are accredited by the National Council for Teacher Education and are certified by the Illinois State Board of Education. There have been no past, present, or pending adverse actions taken against the University by any professional association.

Requirements of institutions holding dual institutional accreditation

The University is not affiliated with another Council for Higher Education Accreditation-recognized or federally recognized institutional accrediting association. Requirements of institutions holding dual institutional accreditation are not applicable.

Institutional records of student complaints

The Department of Education expects evaluation teams to be aware of major complaints or categories of student concerns that may or may not be addressed in the self-study report. To comply with federal regulations, the Commission expects an affiliated organization to provide a comprehensive evaluation team with an organizational account of the student complaints it has received and their disposition. This account should cover the two years of operation preceding the comprehensive evaluation.

Organizations have a variety of ways of providing the account, and almost any manner of accounting will be acceptable to a team. One manner of accounting is a log that tracks complaints from inception to disposition, but an organization may utilize any means of collecting and reporting on this information that is comfortable.

Aware that students can register concerns in all sorts of ways, ranging from informal conversations to articles in student newspapers and formal letters filed with appropriate offices, the Commission believes that the reporting obligation should focus principally on nontrivial complaints, either academic or nonacademic, made formally in writing, signed by a student, and addressed to and submitted to an organizational officer with the responsibility to handle the complaint. However, organizations may choose to report generally on complaints received at a variety of points and in a variety of ways on campus.


  • Rhonda Kline, Director, Institutional Research and Planning, Co-Chair
  • Judi Dallinger, Assistant Provost, Co-Chair
  • Earl Bracey, Associate Vice President, Student Services
  • *Bill Bushaw, Director, Financial Aid
  • Sue Collins, Assistant Director, Residential Facilities
  • Kristin Dunstan, Director, University Marketing
  • *Kathy Orban, Associate Athletics Director/Senior Women's Administrator
  • Tammy Seitz, Director of Marketing, Western Illinois University-Quad Cities

*former member

Meeting Schedule

  • 2008
    • November 17 - 3:30 pm - in person meeting - SH205 CODEC to QC Rm114
    • 2009
      • July 24 - email meeting
      • July 27 - email meeting
      • August 10 - email meeting
      • August 12 - email meeting
      • September 17 - email meeting
      • October 2 - email meeting with Steering Team liaison group