By Kathryn Dodge, Ph.D., Founder, Dodge Advisory Group, LLC and Joanne Wenzel
As former state regulators, and now current ACCSC public commissioners, we are staunch advocates for the important role played by state authorization agencies; but we have also discovered through our experiences that schools do not always recognize the benefits of maintaining strong and positive relationships with those agencies. The more you know about your environment, the better prepared you will be to protect and promote your institution as well as provide your students with a positive experience.
Every state is different. The roles, size of the staff at the state level and philosophical approaches are dramatically different as is evidenced by distinct laws and rules that govern the regulation of postsecondary institutions of higher education in each state. Processes also vary. For example, California has three separate entities for public institutions of higher education, a separate agency for California Grants and a bureau that oversees all private entities. Conversely, a small state, such as New Hampshire has one entity responsible for regulating private, degree granting, and non-degree granting institutions. Regardless of the scope or type of your institution, the program types or degree levels, whether your institution chooses to be accredited, or whether your institution opts to participate in federal financial aid programs, your institution will always have to interact with an agency at the state level.
The purpose of this article, then is to offer some proactive, practical tips for strengthening your engagement with your state authorization entity.
Tip #1: Know your school’s mission and be able to articulate it to anyone who asks. Not only should you know your school’s mission but everyone in your organization should be clear about your institutional mission. Anyone that may, at any point, have contact with your state approval agency should be very clear about what your school does and why and be able to articulate school purpose, plans, and alignment of plans with your stated mission.
Tip #2: Initiate relationships with the staff before you have a particular need – Be proactive. Know your state regulator, learn how the agency is organized and how it works. Initiate and maintain relationships. When in doubt, pick up the phone, communicate, and keep a record. Don’t ever mistake a good relationship with friendship. Most regulators don’t have any friends so don’t send individual gifts or put them on the spot by asking them to social functions.
Tip #3: Make nice with all levels of staff and contact the right person. Be sure to respect all levels of staff, don’t think going “straight to the top” or around the person with a lesser title is always a good thing. The person you want to speak with is the person that knows about the issue that you are experiencing. That person is not always the boss or the manager or even the analyst and that person that you assumed was “in your way to the top” can make your life miserable. The same holds true when you think about contacting your legislator. We caution you to exhaust all other avenues to find a resolution before you go down that path. If you get to know the staff before there are problems, you may never have problems, because you are more comfortable speaking with those that can help address possible problems before they become real issues.
Tip #4: Be in good standing – stay in good standing. Be in good standing – stay in good standing. Be in good standing – stay in good standing! If you don’t know what “good standing” is, find out. Reach out to the state authorization agency and find out how you can become better informed about compliance. If you have been proactive about meeting staff this needn’t be a scary call or note.
Tip #5: Communicate clearly and always. Eliminate guesswork for your state agency (see tip #1). As you alert your state agency to any proposed changes, reinforce how those changes align with the institution’s stated mission. This approach gives regulators confidence in your capacity to plan and it reduces the possibility of surprise. Activity that is unexpected threatens trust between you and your state regulator. Less guessing by your state regulator will make it easier for them to clarify what they need from you which means it will take you less time to submit what is requested and it will also be more efficient for the reader at the state agency.
Tip #6: Be active. Attend training, rule-making sessions, board meetings, advisory meetings, look for opportunities to engage in “call for comments” when changes to the rules or regulations are proposed, etc. Your input is more valuable than you can imagine. Volunteer whenever you can.
Sometimes there are opportunities to influence through informal conversation as a result of a cultivated relationship based on tips 1, 2 and 3.
Tip #7: Engage in the legislative process. Follow hot topics. If there is a legislative issue that erupts in your state, be sure to seek a perspective from your state regulator. Don’t assume you know all there is to know about the topic. The more you know about various perspectives (controversial or otherwise) the more prepared you can be to speak well to the issues and their implications for all involved. Remember that the legislative branch is separate from the executive branch and what happens in the legislature may not be what the executive branch exactly had in mind so what is going on in the legislature may not be supported by the approving agency.
Tip #8: Don’t take anything personally. Stuff happens! Late fees, on-site inspections, questions about applications and the handling of complaints happen. For example, the approving agency receives a complaint and contacts you, as you are drafting your response you’re thinking “Wait, we are a good school and do the right thing and the state approving agency should know that and give you a break…right?” No, not right and don’t get mad about it. If the personnel at your state agency do not know (or remember) your name it may be a good thing. The state may be large and therefore it may be not easy or natural to cultivate relationships. Therefore, not knowing who you are, may be a good thing as they may only have time to focus on “problem” schools and people. It’s possible that even if they did know you, the approving agency is doing their job. Either way, what is more important is that YOU know who they are (see tip #2).
Tip #9: Know your accreditor. As with the state, be proactive (see tip # 2). Know your accreditors’ requirements for state communication and adhere to them, strictly. The more your state knows about your relationship with your accreditor the better. The state agency personnel may already have a relationship with staff from your accreditor, make sure your messaging is consistent. Volunteer accreditor communications to your state. While your state may not require such communication, knowing you volunteered it sends a message about your commitment to transparency. It could improve your efficiency. Some states are limited in staff capacity and are, therefore, committed to a regulatory process that compliments that of accreditors recognized by the United States department of education. As a result, they may look for ways to conduct their work without being contradictory or duplicating that which recognized accreditors require. Other states have robust systems that require institutions to meet a set of specific state standards that may contradict or duplicate accreditation requirements. If that is the case in your state, you will need to figure out a way to overcome that challenge.
Tip #10: Respond to all requests promptly and with the utmost transparency. State agencies often have systems in place to track complaints. They want to be sure students are not being taken advantage of by a school. If they ask for information about anything, be sure to respond promptly, with a positive tone. They are looking for information and not for more work. The easier you make it for them to be assured that your students are being treated fairly, consistent with your promises to students in the form of advertisements, enrollment agreements and catalog, the easier it will go for all. If they detect an issue that needs attention, be open. Let them know you appreciate it being brought to your attention. If you already have a plan in place communicate the plan with a timeline and provide evidence of the resolution that will be available for their review. If you do not have a plan, let them know you will develop one and do so. They are looking to solve problems. Help them do so.
If you keep these tips in mind and earnestly put them into action, there is a very good chance that your relationship with your state will be positive and strong.
A good, proactive relationship with your state may increase your productivity, efficiency and reduce your frustration. A troubled relationship with your state, on the other hand, will not serve you, your institution, or students well. Remember, your investment in establishing strong and positive relationships with your state will pay dividends in several ways. Perhaps these tips provide new ideas for engagement or simply serve as a reminder about the importance of the state relationship. In any case, strong and positive relationships with your state will serve your institution, you and your students well.
DR. KATHRYN DODGE is the founder of the Dodge Advisory Group, LLC. In addition to serving as a Public Commissioner and Vice Chair of ACCSC, Kathryn serves on the board for the Commission for Physical Therapy Education and on the distance education committee for Accrediting Bureau for Health Education Schools. Furthermore, by gubernatorial appointment, Kathryn represents New Hampshire as a Commissioner at Education Commission of the States and is on the founding board of the National Council for State Authorization Reciprocity Agreements. Kathryn earned her Doctor of Philosophy in Human and Organization Systems and her Master of Science in Human Development from Fielding Graduate University in Santa Barbara, California. She also earned a Master of Arts in Guidance and Counseling/ Student Personnel from Montclair State University in Montclair, New Jersey, and her Bachelor of Arts in Biblical Literature from King’s College in New York, New York.
Contact Information: Kathryn Dodge, Ph.D. // Founder // Dodge Advisory Group, LLC // 603-924-9741 // email@example.com // www.dodgeadvisory.com
JOANNE WENZEL, for the last 19 years, worked in various capacities for the California State oversight agency for private postsecondary schools in California, most recently serving as the Bureau Chief, California Bureau of Private Postsecondary Schools, a position from which she retired in 2017. Before moving into to the regulatory and compliance side of education, Joanne worked directly with students daily at the campus level with a focus on student affairs, career development, and financial aid advising. A former community college instructor, Joanne has also work with the University of California and Arizona State University in a diverse number of roles. Joanne holds a Master of Education in Higher Education from Arizona State University in Tempe, Arizona and Bachelor of Science in Business Administration from California State University in Fresno, California.