Hawai‘i Community College

Academic Senate

Support for the Council of Regional Accrediting Commissions’ (CRAC) Principles


Whereas accreditation has historically been a voluntary process for institutions to determine student learning and educational quality through a rigorous, collegial and peer-reviewed evaluation using approved standards and criteria; and

Whereas accreditation predates the Higher Education Act; and

Whereas the regional accrediting institutions for higher education have worked continuously with individual institutions to support their meeting the evaluation standards; and    

Whereas through “negotiated rulemaking,” the U.S. Department of Education (USDOE) has proposed revisions to the Title 34 (Education) of Code of Federal Regulations (http://www.gpoaccess.gov/cfr/index.html) specifically §602.16; and

Whereas the proposed USDOE rule changes are punitive for community colleges rather than collegial and

supportive. For example, USDOE would impose “mandatory new quantitative performance standards for ALL prebaccalaureate vocational education programs in the areas of completion rates, placement rates, and, where applicable, pass rates on State licensure or other methods of occupational competency. The standards themselves could be set by institutions (or, lacking that, accreditors), but they would have to be approved by the accrediting agency, whose standards in turn would be approved by ED [USDOE]” (from April 30, 2007 statement by David Baime, American Association of Community Colleges); and

Whereas the proposed USDOE rule changes infringe on an individual state’s right to administer its

educational systems;

Whereas in “negotiated rulemaking,” consensus has not yet been achieved between the American Association of Community

Colleges and the USDOE; and

Whereas the Council of Regional Accrediting Commissions (CRAC) is also concerned about the proposed

administrative rule changes; and  

Whereas the CRAC has developed and adheres to five key principles that guide accreditation

and the different roles of individual institutions and academic programs;

now therefore be it

Resolved that the Hawai‘i Community College Academic Senate endorse the five key principles as developed by CRAC:


1.       “Any definition of educational outcomes or performance levels should be set by institutions, not by accreditors or the Department of Education.

2.       Performance should be evaluated by multiple indicators, not by ‘bright lines’ using a single measure.

3.       Regional accreditation should assess performance at the institutional level, not programmatic level.

4.       Comparisons of outcomes should be undertaken by institutions, where appropriate, and should not be mandated by the Department of Education or accreditors.

5.       Any new regulation should be able to be implemented without significant new burden on institutions” (from May 1, 2007 letter from Barbara Beno, Council of Regional Accrediting Commissions) and be it further


Resolved that the Hawai‘i Community College Academic Senate request the Chair of the Senate to distribute this resolution of concern to: the College’s Administrative Team, the President of the ASUH-HawCC, Vice President Morton, President McClain, all members of the UH Community College Faculty Senate Chairs (CCFSC), Governor Lingle, the University of Hawai`i Professional Assembly Board of Directors, the UHPA Executive Director, the United States Congressional Delegation (Representatives Abercrombie and Hirono, Senators Inouye and Akaka), each Executive Director of the regional accrediting commissions, the Vice President for Government Relations of the American Association of Community Colleges, and the U.S. Secretary of the Department of Education. 



Passed unanimously on May 9, 2007