The Accrediting Commission for Junior and Community Colleges has pronounced unfair judgment on Northern Marianas College on the basis of an outrageously faulty report conducted during a mere two-day visit to NMC on April 13 and 14, 2010.
It may well be that NMC is deserving of this harsh sanction — a sanction that affects literally thousands in our community, but the so-called evidence presented in this egregious report is clearly weak and does not support the action taken. The report cover indicates that it represents the findings of an “evaluation team.” Two individuals spending two days to evaluate NMC is certainly far less than adequate to conduct a thorough evaluation of the institution, especially when the purpose of the evaluation is to determine the institution’s adherence to accreditation standards/eligibility requirements and to take action on its accreditation status. (By comparison, I once spent eight weeks on a six-member team that conducted an educational evaluation for the US.S. Agency for International Development.) What makes the situation even more appalling is that NMC paid for it — estimated at over $5,000! Finally, the Accrediting Commission, by virtue of its unquestionably accepting a report based on such specious reasoning, is demonstrating that it considers us folks out here to be silent, ignorant islanders — not intelligent enough to discern the difference between credible and questionable evaluation methods, and not concerned enough to speak out about it.
If one removes NMC’s accreditation history and the ten recommendations from the ten pages of narrative that make up the report, the remaining five pages are the portion that present the team’s observations and findings — five pages that are filled with glittering generalities, loaded words, and very little substantive evidence. While ACCJC has established guidelines that call for evaluation and assessment to be based on facts and data, this report, on the other hand, is a model of how not to conduct an evaluation. It smacks of hypocrisy for ACCJC to accept a report that should have been rejected outright because it does not adhere to ACCJC’s own evaluation/assessment guidelines.
So what’s so bad about the report, which is posted on NMC’s website and you can read for yourself? (The report is available at (http://www.nmcnet.edu/media/resource%20documents/ACCJC%20Special%20Visit%20Team%20Report%20(April%2013-14,%202010).pdf).)
First off, the report reads more like a criminal investigation than an evaluation report. The words “admitted” and “acknowledged” are used no less than seven separate times in the pertinent five pages; in six of those times, they are used in statements about NMC Regents. Here are two examples: “Individual regents admitted to….” and “Both the interim President and the Board Chair admitted to….” In one of those six statements, the sentence reads, “Several of the newly appointed regents readily admitted to….” Knowing that the team members had called for meeting with each Regent individually, these statements conjure up the image of a Regent sitting in an interrogation room while responding to allegations; and if the response was out of line with what had been pre-determined, out came a club to whack them on the shins. Furthermore, both team members were present when the individual interviews were conducted! Such tactics demean our Regents (as well as our faculty, staff, and students), and is an insult to our entire community. With regard to the statement containing the phrase “readily admitted to,” a critical reader should readily notice that the admission is attributed to “several of the newly appointed regents.” There are three recently-appointed Regents. One wonders how many of those three it takes to comprise a group of “several.” It is amazing that ACCJC Commissioners were so readily deceived.
One can only conclude that they had made up their minds prior to the report being filed and that it wasn’t read by inquiring minds.
A second problem is that the authors themselves do not have strong convictions about their findings. So, as they draw definite conclusions based on flimsy or no evidence, they hedge by using the terms “seems/appears/believes,” which are contained in thirteen separate instances in the five relevant pages. Again, here are examples: “Several members of the college leadership are so new in their respective positions that they seem….” and “the Board of Regents appeared to be more focused on….” “Seeming to” and “appearing to” engage in questionable or improper actions are hardly concrete evidence. And how much stock can be put into a belief that some action took place?
This brings up a third major problem with the report. The authors craftily replace their lack of data with the use of terms like “several/many/some/numerous/nearly all.” A reader can easily and deceptively be drawn into agreement with the authors’ conclusions as they ignore data and use these terms 28 separate times to replace specificity. (Is it conceivable that such was the case with the Commissioners —that they were duped?) The term “several” is used no less than 14 times! Here are just three examples: several faculty members, several Regents, and several of those interviewed. One wonders how many Regents it takes to make “several,” as there are only seven Regents, and according to the report, only six of them were interviewed. The phrase “several regents” was used eight times, giving the impression that the statements which contained that phrase represent a widely held view on the part of the Board. Such a view may not be warranted at all.
Then there is a fourth concern, the use of highly charged words, which prompt emotional rather than rational responses from the reader: “internecine warfare between faculty and staff factions,” “morose and fearful,” “rail against,” “climate of fear,” “a state of confusion and unrest,” “expressed dismay,” and “seemed despondent.” These words are not used as quotes from those interviewed, but most often as the authors’ summary of the interview sessions.
A fifth fault is that the authors never give the number of faculty, staff, or students that they actually interviewed or met with. Such information is normally standard in reports of this type, sometimes in an appendix. The only specificity with regard to the number of people interviewed is the number of Regents (six) and identification of administrative personnel (five including the interim President) and the Faculty President and the Staff President. They do cite Student Government, but make no mention of the number of students in this group. They also claim in some cases that a conclusion is based on clear evidence, but they do not bother to present the evidence, as in “The team determined that there is clear evidence that the board is not acting autonomously from the Commonwealth government.” Are we to accept their claim on the basis of faith? Obviously the Commission did.
A sixth problem is with two of the team’s sources of information, which they do cite: “The team also received numerous unsolicited emails from current and former employees as well as reviewed numerous articles in the local newspapers the Saipan Tribune and the Marianas Variety.” These sources raise the following questions:
Were the emails anonymous? If so, why would they be acceptable? How many separate individuals did the emails come from? Is it possible that multiple messages came from the same individual? Are local newspapers credible sources of information for such an important report? Was there any attempt to verify the information in the newspaper articles that the authors relied upon in making their observations/findings and drawing their conclusions?
Concern number seven deals with the paucity of information presented in the portion of the report that concludes that NMC falls short in terms of its meeting two Eligibility Requirements and five Standards — those that deal with Institutional Financial Management and Integrity. Namely, the report charges that governmental influence and pressure undermines NMC’s autonomy and that the College has failed to take corrective action on deficiencies noted in audits of its federally funded programs for fiscal years ending in 2008 and 2009.
With respect to governmental influence, here are four statements from the report: “The team heard numerous examples and allegations of governmental interference with college operations. Prior to the team visit, the Commonwealth governor announced a proposal to reduce NMC staffing by nine positions as an austerity measure…. There was no recognition, among the interviewed Regents, that the Commonwealth government’s ability to dictate college staffing infringed on institutional autonomy [emphasis added]. . . . Numerous interviews, with Regents and with staff, revealed a common belief of both direct and indirect political influence. The team determined that there is clear evidence [emphasis added] that the Board is not acting autonomously from the Commonwealth government.” Although the claim is made that the evidence clearly supports the authors’ contention that the CNMI government is interfering with college operations and that such infringes on NMC autonomy, only one example is given. And this one example was probably taken from a local newspaper article.
There are two problems here: the authors made no attempt to verify the information they presented as factual, and they clearly did no research to try to understand the CNMI budget process. (I suspect that someone may have tried, but the two “team” members were not open to information that didn’t support their pre-established convictions.) In the CNMI government budget process, each governmental agency/department is directed to submit a budget request to the Governor’s Budget Office. The Governor’s Budget Office then compiles the requests and checks the total of all requests against the projected government revenues for the pertinent fiscal year. Invariably, the total amount for the requests is many millions of dollars more than the amount of the projected revenues. Because the Governor is required by law to submit a balanced budget to the CNMI Legislature, he and his Budget Office must decide how much to allocate each department/agency. The result is that the budget proposal submitted to the Legislature is almost always less than the amount requested by the agency/department. This is what happened in this case. Simply put, the amount to be allocated to NMC was less than the amount that it requested. The Governor definitely did not “reduce NMC staffing by nine positions” as stated in the report. The source of such information was not cited; however, there was a Saipan Tribune article on April 12, 2010 which carried the title: “Fitial Zeroes out 12 Posts for NMC.” (Note that this article indicates 12, not 9, positions.) Whether it was 9 positions, or 12, or 4 (as the Budget Office states), the point it is important to note that these were all vacant positions and they were not cut from NMC’s officially adopted consolidated budget. The vacant positions were part of NMC’s budget request.
Equally important to know is that NMC’s budget request is primarily for personnel costs; operations funds come from NMC’s collected revenues such as tuition and fees, indirect costs for administrating federal grants, federal funding, donations, fund raising drives, etc. Once the Legislature passes a budget law, NMC is free to spend the personnel allocations on whatever positions it sees fit. Such has been the case for decades and has not changed. A copy of the Governor’s 2011 budget proposal to the CNMI Legislature, obtained from the Governor’s Budget Office for the purpose of this letter, shows only a reduction in the amount requested by the Governor for NMC as compared with the amount that NMC requested. The number of positions in both the NMC request and the Governor’s proposal remains at 116 positions. Of utmost importance in this lengthy (but necessary) explanation is the fact that the Governor did not dictate college staffing. Other than this one example, the report gives no factual evidence to merit its contention that the CNMI government is interfering with college operations.
With respect to the audits, there is no mention made about the severity of the deficiencies. Were they major problems or slight oversights? Also, the report implies that the Regents are at fault for not knowing about this.
However, one might well contend that the CEO is responsible for addressing this and keeping the Regents informed. So might the former President be at fault here? Although this is not offered as an excuse for not dealing with these audit deficiencies, it is to NMC’s credit that the institution has accepted this finding and has already begun taking steps to deal with it.
One final matter that somehow got lost in this evaluation. The former President was suspended in January 2010.
The team visit occurred only three months later. The report stated that “the College has experienced considerable turnover in all but one senior administrative position. Several positions are staffed with “acting” appointments. The interviewed incumbents expressed that they were unsure of their roles….” It’s hard to imagine that the college would have gotten as bad as described in report in only three months if the former President had seen to it that these key positions were filled by competent administrators who were trained regarding their role and could have carried on in the absence of the former President. Moreover, no mention whatsoever is made of the disproportionately high turnover in top administrative and faculty positions during the term of the former President. Let’s assume that all the findings were adequately supported and that NMC is in the state which the report would have us believe. If so, shouldn’t the report be more supportive of the Regents’ decision to remove the former President?
I’ve learned that the college made at least two attempts to call ACCJC’s attention to the poor quality of this report and to point out specific faulty details — once in an email message to the ACCJC President and once in a statement before the Commission at the June meeting in California. The following is a portion of the interim President’s statement before the Commission at its June 2010 meeting in San Francisco:
“[W]hat concerns us most about the April 13-14, 2010 ACCJC Special Visit Report is that several claims in the report offer no specific and/or direct evidence but rely, rather, on hearsay, circumstantial evidence, and inaccurate and unreliable media reports. As a result, some of the claims in the report overstate their case, use superlative language, and border on exaggeration.
“As active participants in an accreditation process that relies on evidence-based, data-driven decision making, it behooves all of us to ensure that when making observations, claims, or recommendations, we do so fairly and objectively, based on hard evidence, not rumor, gossip, or tabloid journalism. We hope that the Commission will keep this in mind when deliberating on the report.”
In both instances, the very well-stated and highly justified position of NMC was obviously rejected.
I long for the good old days — when the Accrediting Commission was more of a mentor and offered helpful assistance instead of being our adversary. The Commission’s role as primarily a policing agent does not serve the Micronesian colleges well. Let’s be clear, however; we’re not asking for a free pass and for deficiencies to be overlooked — just some guidance, understanding, and empathetic concern — and competent evaluators.
NMC is certainly not alone in feeling the wrath of accrediting agencies. Is it conceivable they have become far too powerful? Read “Are Accreditors Running The Colleges?”
http://www.mindingthecampus.com/originals/2008/07/by_anne_neal_the_western.html
In closing, here’s my personal thinking: the CNMI community should be outraged by this report and the action taken on the basis of it. ACCJC owes the CNMI an apology due to its careless action; ACCJC should withdraw its sanction of NMC; and ACCJC should see to it that a proper evaluation of the circumstances at NMC be conducted — at its own expense.
IVAN PROPST
Susupe, Saipan
Propst served NMC in various capacities from 1986 to 2007. He has over three decades of training and experience in the field of evaluation and assessment at all levels of education, which includes considerable training in the field (by federal government program officials and ACCJC representatives), publishing numerous articles on testing and evaluation, developing testing and assessment instruments, conducting evaluations for numerous instructional programs, participating in four NMC self studies (once as self study chair), serving as NMC’s Accreditation Liaison Officer, working as a team member on accreditation visits to other colleges in the region, being contracted by AID for two projects in Africa, and working with the South Pacific Commission on evaluation and assessment of instructional programs.
