FEDERAL COMPLIANCE REPORT PREPARED FOR THE HIGHER LEARNING COMMISSION NORTH CENTRAL ASSOCIATION OF COLLEGES AND SCHOOLS

Transcription

1 FEDERAL COMPLIANCE REPORT PREPARED FOR THE HIGHER LEARNING COMMISSION NORTH CENTRAL ASSOCIATION OF COLLEGES AND SCHOOLS DECEMBER 2014

2 Palmer College of Chiropractic 2014 Federal Compliance Report Table of Contents 1. Introduction Assignment of Credits, Program Lengths and Tuition:... 3 Credit Hour Worksheet... 3 Credit Hours... 3 Length of Degree Programs-Justification of Tuition Differences Institutional Records of Student Complaints... 4 Formal Complaint Categories and Resolution Procedures... 4 College Investigations... 6 Centralized Complaint Tracking... 6 Student Informal Complaint Categories and Resolution Procedures Publication of Transfer Policies... 8 Transfer Policies... 8 Educational Agreement Programs Practices for Verification of Student Identity Title IV Program Responsibilities: General Program Responsibilities Financial Requirements CFI and Financial Responsibility Default Rates Campus Crime Information Student Right to Know Satisfactory Academic Progress and Attendance Policies Contractual Relationships Consortial Relationships Required Information for Students and the Public Advertising and Recruiting Materials and Other Public Information Review of Student Outcome Data Standing with State and Other Accrediting Agencies Programmatic Accreditation State Authorization Public Notification of Opportunity to Comment... 18

3 Palmer College of Chiropractic 2014 Federal Compliance Report Table of Contents: Appendices Appendix A: Commission Policy FDCR.A Assignment of Credits, Program Lengths and Tuition Worksheet for Use by Institutions on Assignment of Credit Hours and Clock Hours Academic Affairs Policy: Definition of a Credit Hour Appendix A.1: 2014 Summer Course Schedules (available on the Portal) Appendix A.2: 2014 Fall Course Schedules (available on the Portal) Appendix B: Commission Policy FDCR.A Institutional Records of Student Complaints Palmer College of Chiropractic Learning Outcomes Assessment Survey for the Adjudication Process Appendix C: Commission Policy FDCR.A Practices for Verification of Student Identity Academic Affairs Policy: Student Identification for Distance and Correspondence Education Institutional Policy: Use of College and Electronic Communication Services Appendix D: Commission Policy FDCR.A Advertising and Recruiting Materials Marketing and Communication: Annual Website Review Process

4 Palmer College of Chiropractic 2014 Federal Compliance Report Introduction Palmer College of Chiropractic maintains compliance with federal regulation as it applies to Title IV program responsibilities as well as compliance with federally mandated Higher Learning Commission (HLC) policies. The following report is written in accordance with the HLC Federal Compliance Program. Assignment of Credits, Program Lengths and Tuition: Commission Policy FDCR.A : An institution shall 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 shall notify the Commission of any significant changes in the relationships among credits, program length, and tuition. Assignment of Credit Hours: The institution s assignment and award of credit hours shall conform to commonly accepted practices in higher education. Those institutions seeking or participating in Title IV federal financial aid, shall demonstrate that they have policies determining the credit hours awarded to courses and programs in keeping with commonly-accepted practices and with the federal definition of the credit hour, as reproduced herein for reference only, and that institutions also have procedures that result in an appropriate awarding of institutional credit in conformity with the policies established by the institution. Credit Hour Worksheet Palmer completed the Worksheet for Use by Institutions on Assignment of Credit Hours and Clock Hours. This worksheet and supporting 2014 course schedules for each program and each campus are contained in Appendix A. Credit Hours Palmer operates on a trimester system at the Davenport campus and on a quarter system at the West and Florida campuses. Assignment of credit hours is calculated in accordance with the federal definition of a credit hour and is referenced in the College s Academic Affairs policy excerpted in Appendix A. Palmer publishes all information regarding credits and length of programs in the College Catalog and website. Length of Degree Programs-Justification of Tuition Differences Variance in regional costs, cost of instruction, and related clinical-instruction costs for programs provided at Palmer s three campuses are assessed in setting tuition rates for each program. Market comparison data is compiled annually and taken into consideration when the tuition is reviewed for annual increases. Variance in tuition rates for the three doctor of chiropractic programs (DCPs) is a reflection of the economic market in which the campus is based. All fees and charges to students are ultimately set by the Palmer College Board of Trustees. Fee schedules are public and are available on the College website. Program length and tuition detail is presented Table F.1. 3

5 Palmer College of Chiropractic 2014 Federal Compliance Report Table F.1: Program Length and Tuition Rates Program Doctor of Chiropractic - Iowa Campus Hours for Completion Program Length and Tuition Rates Academic Term Convention Program Length (based on full-time status) 172 credit hours Trimester 3.33 years Tuition Rate $10,828/term $32,484/year 2 (Block Tuition Rate) Doctor of Chiropractic - Florida Campus 224 credit hours Quarter 3.25 years $8,201/term $32,804/year 3 (Block Tuition Rate) Doctor of Chiropractic - California Campus 235 credit hours Quarter 3.25 years $8,084/term $32,336/year 4 (Block Tuition Rate) Master s- Iowa Campus 36 credit hours Trimester 2 years 428 (per Credit Hr) Bachelor s Completion Iowa Campus 120 credit hours Trimester 4 years 211 (per Credit Hr) Associate of Applied Science Iowa Campus 70 credit hours Trimester 1.33 years $2,817/term $8,451/year 1 (Block Tuition Rate) 1 $211 per credit hour for less than 14 credit hours and over 22 credit hours 2 $677 per credit hour for less than 16 credit hours and over 21 credit hours 3 $513 per credit hour for less than 16 credit hours and over 21 credit hours 4 $506 per credit hour for less than 16 credit hours and over 21 credit hours Institutional Records of Student Complaints Commission Policy FDCR.A : An institution shall make available an account of the student complaints it has received, its processing of those complaints, and how that processing comports with the institution s policies and procedures on the handling of grievances or complaints. Formal Complaint Categories and Resolution Procedures Palmer takes student concerns seriously and has established policies, rules, and processes for the resolution of formal complaints. Each procedure is unique not only as to the type of complaint, but also the person (i.e., student, staff, faculty) against whom the complaint is directed. The list below specifies 4

6 Palmer College of Chiropractic 2014 Federal Compliance Report the types of complaints for which a more formalized process is used for resolution. The Office of Adjudication tracks complaints filed by students; data is represented in Table F.2. Table F.2: Student Complaints Calendar Year Total Filings Complaints Filed by Students Student Ethics Cases Sexual Harassment FERPA Filings With Findings Filings Without Findings Sanction Total Filings Filings With Findings Filings Without Findings Sanction Total Filings Filings With Findings Filings Without Findings Resolution Complaint Tracking Within the Department 1. Disability Services: When a student raises a complaint regarding disability accommodations, that student is directed to Disability Services and the complaint is reviewed and resolved in accordance with the Handbook for Students and Applicants with Disabilities. 2. Personal Injury Complaints: When a student sustains a personal injury, students are directed to report the matter to the Security Office. 3. Complaints Regarding Crime: When a student raises a complaint regarding a crime, that student is directed to report the matter to the Security Office. Complaint Tracking - Centralized 1. Discrimination/Harassment Complaints: When a student raises a complaint against anyone in the College community regarding discrimination on the basis of a protected class (other than disability), the complaint is reviewed and resolved in accordance with the Handbook on Equal Opportunity and Procedures for the Resolution of Discrimination/Harassment Complaints. 2. Complaints Regarding Employees: When a student raises a complaint about an employee, the resolution process will be determined and reviewed in accordance with existing applicable institutional, academic and human resources policies; collective bargaining agreements; faculty handbooks or other relevant guiding documents for employee performance and behavior. 3. Complaints Regarding Students: When a student raises a complaint of misconduct against another student and the misconduct does not involve sexual misconduct or other unlawful harassment/discrimination on the basis of a protected class, then the College follows the Student Disciplinary Code outlined in the Student Handbook. 4. Discrimination/Harassment against Students with Disabilities: When a student raises a complaint regarding discrimination on the basis of the student s disability, the complaint is reviewed and resolved in accordance with the Handbook for Students and Applicants with Disabilities. 5

7 Palmer College of Chiropractic 2014 Federal Compliance Report College Investigations College investigations are situational, dependent upon the category and regulatory jurisdiction in which the complaint falls. For example, complaint processes that require investigations against staff or administrators are dictated by staff handbook procedures. Complaint processes that require investigations against faculty or faculty clinicians are dictated by relevant collective bargaining agreements or faculty handbook. Palmer may appoint internal and/or external parties to conduct an investigation of a complaint. Centralized Complaint Tracking Complaints are centrally tracked to ensure they are dealt with in a fair and consistent manner. Complaints are tracked daily for use as an assessment tool for the Office of Adjudication. The postadjudication data collected via the complaint tracking process is used to measure the effectiveness of the student ethics process, student learning outcomes as they pertain to behavioral expectations, the institutional environmental effect on student learning outcomes and demographics. Student Informal Complaint Categories and Resolution Procedures Palmer recognizes that its students may at times have a need to resolve concerns regarding a College policy, procedure, or other matters. Palmer relies on a decentralized and informal model for serving students with complaints. Complaints are addressed to the appropriate functional area with the knowledge, expertise, and authority to respond to the complaint. This approach is appropriate because most complaints can be effectively resolved in an informal manner by the individuals working in the relevant department. Department personnel possess the greatest amount of experience with the policies and procedures that apply in the case at hand, are most familiar with the particulars of the student s circumstances and can draw from experiences of similar situations to propose options and solutions. Palmer expects prompt and fair efforts on the part of its department administrators to achieve satisfactory resolution at the appropriate level. Such informal complaints are typically not tracked. They may include: 1. Course-Related Academic/Clinic Course-Related Academic Complaints When a student raises a general course-related or clinic-related complaint the student is directed to the following information in the Student Handbook and the complaint is referred to the appropriate College Official for resolution: If a student has a concern regarding a test, quiz, practical, examination, class assignment, class requirements, grades, conflicts with midterms or finals, or any other course-related academic concern, the student should first make every effort to communicate with the instructor as soon as possible. If a student has a clinic course-related concern, the student should first make every effort to communicate with the instructor as soon as possible. Contact the instructor during posted office hours, through their address, or by phone (listed in the class syllabus). The standard listing for instructor addresses is by first name followed by a period, the last (for example: john.doe@palmer.edu for Dr. John Doe). Please allow a reasonable amount of time for a response, keeping in mind that instructors are not on campus at all times. If a concern has not been resolved after communicating with the instructor, the student should then contact the following: Davenport, IA, campus: Appropriate department chair 6

8 Palmer College of Chiropractic 2014 Federal Compliance Report Port Orange, FL., campus: Appropriate department director or clinic director San Jose, CA, campus: Dean of Student Affairs If the instructor is one of the individuals listed above, this second step is unnecessary. If the concern has not been resolved after steps 1 and 2, the student should contact the Dean of Academic Affairs at his or her respective campus. The decision of the Dean is final. 2. Course-Related Non-Academic Complaints When a student raises a complaint other than a course-related academic complaint, the student is directed to the Dean of Academic Affairs at his or her respective campus. 3. General Class Complaints Except as otherwise described, the class representative may take other general concerns of his/her class to the following: Davenport, IA, campus: Vice Chancellor for Student Affairs Port Orange, FL, campus: Director for Student Services San Jose, CA, campus: Dean of Student Academic Affairs 4. Additional Complaints/Questions - In addition to the above specified types of concerns, students may refer to the directory published in the Student Handbook for other concerns. Department personnel will connect the student with the appropriate person within the department who will answer questions and assist them in resolving the reported matter. Effectiveness of the Student Ethics Process The effectiveness of staff interaction, in complaint processes, is measured through the following items: clarity of communication, respect, professionalism, sufficiency of procedural information provided, and adherence to established procedures. Complaint process effectiveness is assessed with the following measures: perceived procedural fairness, panel bias, protection of student rights, process timeliness, opportunity to be heard, total number of cases, type of resolution (informal/formal), type of violation, type of sanction, number of findings (or no findings), appeals, recidivism, findings upheld by Appeal Officials (in whole or part), drug/alcohol related violations, violations that include crime, effectiveness and fairness (filer perspective). The indicators of complaint process and staff interaction effectiveness are captured through survey questions on the adjudication process Learning Outcomes Assessment Survey, sections B and C, in Appendix B. Student Learning Outcomes - Adjudication Process The purpose of assessing student learning outcomes as they pertain to the complaint process is to evaluate if students have a greater understanding of expectations for behavior. The Compliant Process Learning Outcomes Survey, sections D-H, measure sanction effectiveness through the following components: 1. If students understand expectations for appropriate behavior 2. If students are less likely to engage in misconduct in the future 3. If students make the connection between their behavior and its effect on the community 4. Special circumstances students feel contributed to behavior 5. Positively impacted values 6. Positively impacted attitudes 7. Positively impacted future behavioral choices 7

9 Palmer College of Chiropractic 2014 Federal Compliance Report 8. Recidivism Publication of Transfer Policies Commission Policy FDCR.A : Each institution shall determine its own policies and procedures for accepting transfer credits, including credits from accredited and non-accredited institutions, from foreign institutions, and from institutions which grant credit for experiential learning and for non-traditional adult learner programs in conformity with any expectations in the Commission s Assumed Practices. An institution s periodic review of its transfer policies and procedures should include evaluation of their clarity to those who administer them, to the students who follow them, and to employers and other stakeholders. It should also include the consistency of their interpretation and application throughout the institution, as well as their responsiveness to new types of learning opportunities outside institutions of higher education. An institution shall demonstrate that it has transfer policies that are publicly disclosed and that such policies include a statement of criteria established by the institution regarding transfer of credit earned at another institution. Transfer Policies Policies and procedures regarding admission of transfer students and the transfer of credit to Palmer are defined in the Academic Affairs Student Policies: Transfer Students/Advanced Standing Policy and published in the College Catalog, Student Handbook, and on the website. The policy addresses transfers from other institutions as well as transfers between Palmer campuses. Students wishing to transfer from Palmer College of Chiropractic to another institution must contact that institution directly to determine whether credits will be accepted. As with any academic program, transferability of credit is at the discretion of the accepting institution. Educational Agreement Programs Palmer offers educational (articulation) agreement programs to students wishing to earn concurrent credit toward an undergraduate degree and a Doctor of Chiropractic degree. The College has partnered with hundreds of educational institutions to provide this option to students. There are three types of agreements offered: 3+1 agreements, BS articulation agreements, and DC curriculum agreements. A complete listing of institutions by agreement type is available on the College website. 3+1 Agreements Under 3+1 agreements students attend the first three years of undergrad at a partner institution, take the fourth and final year as the first year in the Doctor of Chiropractic program. Upon completion of the first year in the Doctor of Chiropractic program, students transfer back to the undergraduate institution to be conferred a Bachelor s degree. B.S. Articulation Agreements The B.S. articulation agreement is established as a Memorandum of Understanding to facilitate the transfer from an undergraduate institution to the Bachelor of General Science program. D.C. Curriculum Agreements The D.C. curriculum agreement ensures the coursework taken at the undergraduate level will easily satisfy admission requirements and transfer to the Doctor of Chiropractic program on any Palmer campus. 8

10 Palmer College of Chiropractic 2014 Federal Compliance Report Practices for Verification of Student Identity Commission Policy FDCR.A : An institution offering distance education or correspondence education shall have processes through which the institution establishes that the student who registers in the distance education or correspondence education courses or programs is the same student who participates in and completes and receives the academic credit. Palmer defers to both the Federal and HLC definitions of distance and correspondence education/courses, in which all or at minimum, 75% of instruction and interaction occurs via electronic communication or correspondence with the faculty and students physically separated from each other. Palmer offers a limited number of courses through distance and correspondence education during the last term, in which a student may be enrolled in an off-campus clinic rotation. Students enrolled on the Davenport and West campuses complete concurrent coursework via correspondence during an offcampus clinic rotation. Effective July 2014, concurrent Florida campus courses were moved to an online format. Palmer adheres to the Academic Affairs Instructional Policy: Student Identification for Distance and Correspondence Education, as excerpted in Appendix C to verify students enrolled in courses are the same students participating in and receiving credit for the course, thus safeguarding academic integrity and student privacy. Student identity is verified by one or more of the following methods: College issued secure log-in and password. Students are assigned a secure Palmer account by the Information Services (IS) department upon admission to the College. Data relative login information is protected using standard encryption technology. Passwords and login information management is governed by the institutional policy, Use of College Electronic Communication Services, see also Appendix C. Student identity verification for proctored examinations. Extension Faculty (Preceptors) and DoD/VA Adjunct Appointments alike are required via contract and terms of appointment to adhere to the applicable policies contained in respective program handbooks for verification of student identity. Both the Preceptor Program Handbook and the Department of Defense Veteran s Affairs Internship Program contain appended references to the Academic Affairs Policy: Student Identification for Distance and Correspondence Education. Other College approved technologies or practices. The College Academic Oversight Committee (CAOC) is charged with approving technology and practices for distance and correspondence courses to ensure the proper verification of student identity. Departmental coordination of Information Services (IS) and/or Center for Teaching and Learning (CTL) is conducted by deans and College-level directors as a means of assessing security and compatibility with College systems, verifying student identity through a login and password system and protecting student information through standard encryption technology. Policy dictates faculty must seek and secure approval of the Academic Dean before using new technologies or practices to verify student identity. At present, there are no fees associated with the verification of student identity. Should students be expected to incur additional cost in the future, Palmer will provide notification at the time of registration or enrollment. 9

11 Palmer College of Chiropractic 2014 Federal Compliance Report Title IV Program Responsibilities: Commission Policy FDCR.A : An institution shall demonstrate that it complies if required with the Title IV program responsibility requirements of the Higher Education Reauthorization Act as most recently amended. Therefore, institutions will provide for Commission review any documents concerning the institution s program responsibilities under Title IV of the Act, including any results of financial or compliance audits and program reviews, audits reports by the Office of Inspector General of the U.S. Department of Education, and any other information related to its fulfillment of its Title IV responsibilities. Default rate: An institution shall make reasonable efforts to ensure that its students do not take on excessive debt either through federal or private loans. An institution shall also demonstrate that it is appropriately fulfilling its Title IV responsibilities to manage its student loan program, to minimize student default on such loans, and to provide accurate information to the U.S. Department of Education when required in conjunction with its loan program. Therefore, an institution will submit to the Commission information about its participation in federal and private loan programs as well as its threeyear Title IV default rates and any default reduction plans provided to the U.S. Department of Education. General Program Responsibilities The institution should provide the Commission with information regarding the status of its Title IV program; in particular, the institution should submit information about recent findings from Title IV program reviews, inspections, or audits. The institution should disclose any limitation, suspension, or termination actions that the Department of Education has undertaken and the reasons for those actions. The institution should also disclose any fines, letters of credit, or heightened monitoring arising from the Department of Education. The institution should address, in its self-study, the consequences of these challenges for its short and long-term financial health. The institution should also discuss its response and corrective actions to these challenges. Palmer complies with all Title IV program requirements. Initial Title IV eligibility began in A program review was conducted in May 2011 as a result of the OPEID merger consolidating all campuses; at that time Palmer was determined eligible for continued participation in Federal Student Financial Aid Programs through December 31, No limitation, suspension, or termination action has been initiated by the Department, nor has the Department heightened monitoring or issued any fines or letters of credit. Annually, the Office of Financial Planning undergoes a study and evaluation of internal accounting controls used in administering federal financial assistance programs conducted by an external accounting firm. No material weaknesses or significant deficiencies were identified in Palmer s processing of financial aid for the period of July 1, 2012 to June 30, The audit contains findings that did not warrant full resolution by the school participation teams and these findings will be addressed in the next audit report submitted to the U.S. Department of Education. Financial Requirements CFI and Financial Responsibility The institution must provide information about the Department s review of the institution s composite ratios and financial audits. In particular, the institution should provide information about the A-133 portion of the audit. The Commission also analyzes each institution s financial ratios to determine whether there might be financial concerns. The team should check with the institution and with Commission representatives regarding whether the Commission or the Department has previously raised 10

12 Palmer College of Chiropractic 2014 Federal Compliance Report concerns about an institution s finances based on these ratios. If so, the institution should have addressed in its documents the actions it has taken and plans to take in response to these concerns. Palmer follows Generally Accepted Accounting Principles to ensure consistent and transparent financial processes. Concurrent with the annual compliance audit, the College also undergoes an external financial audit of its business affairs. This information is submitted to the U.S. Department of Education in accordance with Federal Regulation A-133. As evidenced by fiscal year calculations reflected in Graph F.3, the College holds a Composite Financial Index Score (CFI) of 3.0, and is identified as low-risk. Graph F.3: Composite Financial Index Score (CFI) Palmer College Composite Financial Index PCC's CFI Orange Zone Red Zone Fiscal Year CFI Zone Private Inst Financial Panel Review Above 3.0 to 1.5 No review; Healthy Zone In 1.4 to 1.0 Review if 2 or more consecutive years; request additional financial documents Below.09 to -1.0 Review if 1 year; request additional financial documents Default Rates The institution should take steps to avoid excessive loan default rates. The institution should disclose student loan default rates as provided by the Department for the three years leading up to the visit. If the default rates are higher for the institution than its peer institutions or if rates have exceeded Departmental thresholds or triggered a Department review, then the institution should address the actions it has taken in response and submit to the team any corrective plan filed with the department. Note for 2012 and thereafter institutions and teams should be using the three-year default rate based on revised default rate data provided in September

13 Palmer College of Chiropractic 2014 Federal Compliance Report Palmer encourages responsible student borrowing at all stages of the college experience including campus visits, orientation, and throughout the student borrower s enrollment. The College calculates cohort default rates based upon 2009 U.S. Department of Education regulations. From Palmer s three-year cohort default was 3.4% - 3.5%. In comparison to the peer institutions in Table F.4, Palmer s default rate is lower than the three-year cohort default rate of its peer institutions which range from 4.1% to 5.5%. Table F.4: Peer Institution Three-Year Cohort Default Rate Peer Institution Three-Year Cohort Default Rate* FY 2009 FY 2010 FY 2011 Life Chiropractic College (West) 5.7% 8.8% 3.9% Southern California University of Health Sciences 4.9% 5.2% 3.2% Cleveland Chiropractic College (Kansas City) 8.5% 6.9% 6.7% Texas Chiropractic College Foundation 7.5% 11.2% 7.8% New York Chiropractic College 1.9% 1.7% 2.4% Logan University 1.1% 1.2% 2.9% National University of Health Science 5.5% 4.0% 5.0% University of Western States 1.6% 2.9% 3.3% Palmer College of Chiropractic 3.5% 3.4% 3.5% Parker University 5.1% 11.4% 7.6% Northwestern Health Sciences University 4.3% 2.4% 2.8% Sherman College of Chiropractic 8.1% 6.3% 0.0% Average Default Rate 4.8% 5.5% 4.1% *Data taken from the National Student Loan Data System (NSLDS) for students. Institutional level data, is not indicative of only Doctor of Chiropractic Programs. In an effort to maintain or decrease the College s cohort default rate, the Office of Financial Planning provides debt management information to students. The Default Prevention Program provides individualized counseling, available in person or via phone during regular business hours. During the fall of 2013, Palmer developed and implemented a financial literacy pilot program at its Davenport campus called Financially FIT. The program was created to increase students awareness of the implications of borrowing and is tailored to meet the needs of students based on the stage of their college career. At present, statistically reliable data is not available, however it can be estimated that 10% of Davenport students participated in This program is scheduled to be launched on the branch campuses during the year. Campus Crime Information Title IV responsibilities include the legal obligation to disclose information to students and to the public about campus crime, athletic participation (N/A) and other information. The institution should provide samples of those disclosures in the Resource Room. In addition, the institution should discuss in its selfstudy any findings from the Department regarding these disclosures and be prepared to discuss them with the team. 12

14 Palmer College of Chiropractic 2014 Federal Compliance Report Annual Guide to Campus Safety and Abuse Awareness The Office of Compliance publishes the Guide to Campus Safety and Abuse Awareness in accordance with federal regulations. Current crime statistics are published for each of the three campuses on the College website. The publication provides students and employees with an overview of the College s programs relative to safety and the prevention of alcohol and drug abuse. Information contained in the guide covers the following topics: 1. Policies and rules on substance abuse and campus violence 2. Educational resources regarding substance abuse and crime prevention 3. Campus security updates 4. Updated local and campus crime statistics 5. Sex Offender Registry contact information 6. Emergency response information Additional Security Resources Security Activity Logs The security offices located on each campus maintain activity logs of campus crime reported within the previous 60 days. Palmer Alert Palmer Alert is the College s notification system which utilizes landline phones, cell phones, voic , e- mail and text messaging to distribute emergency notifications to staff and students. All alerts are distributed via the Marketing and Communication department subsequent to administrative approval. Report a Crime Palmer expects all students, employees and visitors to comply with all policies, procedures and rules regarding safety. Victims and witnesses alike are required to report crimes immediately to Campus Security. Campus Security can be reached by calling the phone number (non-campus phone), extension (campus phone system) or Code Blue phones located in all campus parking lots. Crime report forms are available via the College website and may be completed anonymously. Early Alert Response System (EARS) The EARS is a web-based reporting system launched in 2009 that allows individuals to submit concerns to positively address behavioral challenges before they become a hindrance to student and or staff experience. All reports are confidential except when disclosure is required by law or is necessitated by intervention. Student Right to Know Title IV responsibilities require that institutions provide graduation/completion for the student body by gender, ethnicity, receipt of Pell grants, and other data as well as information about the process for withdrawing as a student, cost of attendance, refund and return of Title IV policies, current academic programs and faculty, names of applicable accrediting agencies, description of facilities for disabled students, and the institution s policy on enrollment in study-abroad. In addition, certain institutions need to disclose their transfer-out rate. The institution should provide samples of these disclosures in the Resource Room. In addition, the institution should discuss in its self-study any findings from the Department regarding these disclosures and be prepared to discuss them with the team. 13

15 Palmer College of Chiropractic 2014 Federal Compliance Report The Higher Education Opportunity Act of 2008 requires institutions participating in Title IV student aid programs to make certain disclosures available to students. Required disclosures are outlined in Table F.5 below. Palmer s Marketing and Communication and Admissions departments undergo Compliance Training for College Communications, providing annual review and regulatory updates regarding misrepresentation rules and fair consumer practices. Table F.5: Student Right to Know Disclosures & Required Public Information Commission Policy FDCR.A Title IV Program Responsibilities, Student Right to Know & Required Public Information Student Right to Know Disclosure Website URL College Catalog Student Handbook Admission Requirements Graduation/Completion Rates Withdrawal Policy --- Cost of Attendance* Net Price Calculator npcalc.htm Refund/Return of Financial Aid --- Calendar Academic Programs Grading Policy --- Faculty Accreditation Disabled Student Facilities and Services dationsforstudentswithdisabilities/ pp. 53, p. 67 p. 87 p. 45 p pp , 48 pp pp pp p. 33 p. 60 p. 59 p. 64 pp p. 11 p. 13 p. 15 p. 52 Study Abroad *Student Services notifies students of tuition increases (by campus) annually prior to the Summer term p. 37 p. 62 Satisfactory Academic Progress and Attendance Policies The institution is required to have a Satisfactory Academic Progress policy and an attendance policy as part of the Title IV program. It must document to the Commission that these policies are readily available 14

16 Palmer College of Chiropractic 2014 Federal Compliance Report to students, satisfy state or federal requirements, and are being appropriately applied by the institution in individual student situations. In most cases, teams should verify that these policies exist and are available to students, typically in the course catalog or student handbook. Note that the Commission does not necessarily require that the institution take attendance but does anticipate that institutional attendance policies will provide information to students about attendance at the institution. Satisfactory Academic Progress The Office of Financial Planning monitors students for Satisfactory Academic Progress (SAP) pursuant to federal regulations. The Satisfactory Academic Progress (SAP) Policy for Recipients of Financial Aid outlines SAP eligibility criteria: treatment of course withdrawals, incompletes, repeated course and electives; statuses; appeals; special circumstances; academic load; and length of time allowed to complete academic course of study. Attendance Instructors are responsible for establishing attendance policies including mandated attendance for each course. Policies must be clearly stated in each course syllabus. Additional details relative to course attendance can be located in the Student Handbook (p. 85) and the College Catalog (p. 66). Contractual Relationships Contractual Relationships: The institution should disclose its contracts with third-party entities not accredited by a federally recognized accrediting agency as a part of the materials in preparation for the on-site evaluation. The institution should have previously disclosed all existing contracts to the Commission in the 2010 and 2011 Annual Institutional Data Updates. The Commission s substantive change policy requires that the institution notify the Commission of any new contracts for up to 25 percent of an academic program, that the institution obtain prior Commission approval before initiating any contract for 25 to 50 percent of a program, and that the Commission approve contracts for more than 50 percent of a program only in exceptional circumstances under strict scrutiny. The institution should review the document Information on Contractual and Consortial Arrangements more information. Davenport and Florida students in their final term of the DC program have the option to complete their clinical training through the Intern Preceptor Program; West students are required to take part in the off-campus Field Training Program. Field doctors in these programs volunteer to serve as preceptors. Through this contractual relationship the field doctors are non-paid extension faculty. Off-campus preceptorships account for only seven percent of the total curriculum. Palmer s clinical preceptorships do not include a formal instructional component; therefore they meet the exclusionary definition found in the Information on Contractual and Consortial Arrangements HLC resource. Palmer College is not required to submit the annual list of preceptor doctors HLC s Annual Institutional Update. Consortial Relationships Consortial Relationships: The institution should disclose its consortial relationships with other entities accredited by a federally recognized accrediting agency as part of the materials in preparation for the on-site evaluation. The institution should have previously disclosed all consortial relationships to the Commission in the 2010 and 2011 Annual Institutional Data Updates. The Commission s substantive change policy requires that the institution notify the Commission of any new consortium for 25 to 50 percent of an academic program and that the institution obtains prior Commission approval for any consortium that offers 50 percent or more of an academic program. The institution should review Information on Contractual and Consortial Arrangements. 15

17 Palmer College of Chiropractic 2014 Federal Compliance Report Palmer does not have any consortial relationships for delivery of its programs with entities accredited by a federally recognized accrediting agency whereby such a relationship would provide at least 25% - 50% or more of an academic program. The College understands Commission Policy INST.F regarding institutional change which would require Commission notification and/or approval, should such a relationship be entered. Required Information for Students and the Public Commission Policy FDCR.A : An institution demonstrates that it makes available to students and the public fair, accurate and complete information in catalogs, student handbooks, and other publications that include, at a minimum, information about the institution s calendar, grading, admissions, academic program requirements, tuition and fees, and refund policies. Public information regarding Palmer s calendar, grading and admissions, program requirements and refund policies can be found on the College website, Handbook, and Catalog. Details regarding these disclosures as well as their source are fully outlined in Table F.5 of Commission Policy FDCR.A regarding Student Right to Know. Palmer provides required student information through its Student Handbook at: The College s current catalog is available at: Advertising and Recruiting Materials and Other Public Information Commission Policy FDCR.A : An institution s public information including its advertising and recruiting materials shall evidence the same fairness and accuracy the Commission expects in an institution s catalog and other documents for students. Disclosure of Affiliation Status: If the institution chooses to reference its accreditation status in advertising and recruiting materials or other document or location, that disclosure will accurately explain its status with the Commission and the academic programs, locations and other institutional activities included in its accreditation. Palmer discloses accurate information regarding its institutional and programmatic accreditation status to current and prospective students as well as to the public through the HLC Mark of Affiliation and Council on Chiropractic Education (CCE) required accreditation language. Both the HLC Mark of Affiliation, as well as required CCE language, can be found in three separate but primary locations which are listed below. The Student Handbook and College Catalog can be accessed from the College website by linked file as well. 1. Palmer website Accreditation Student Handbook College Accreditation, page College Catalog General College Information, pages Advertising and recruitment materials may indicate the College and Doctor of Chiropractic Program are accredited. All such material includes a reference to the College website, which provides the HLC Mark of Affiliation and the required link to the HLC webpage for additional information on Palmer s 16

18 Palmer College of Chiropractic 2014 Federal Compliance Report accreditation status and the CCE required language. The term Accreditation is accessible on every webpage on the College website via footer navigation links. Palmer adheres to a continuous, dynamic review process involving the Admissions, Marketing and Communication, and any other applicable departments to ensure clear and accurate information is portrayed in advertising and recruiting materials. The Admissions and Marketing and Communication departments are responsible for ensuring all advertising, recruitment and other public material is accurately portrayed. Annually, both departments complete Compliance Training for College Communications via the Office of Accreditation and Licensure to acknowledge and ensure compliance with fair consumer practices and federal regulations regarding misrepresentation. Additionally, the Marketing department follows departmental procedures, evidenced in Appendix D for maintaining and updating the College website, printed recruitment materials, and recruitment presentations. Review of Student Outcome Data Commission Policy FDCR.A : An institution shall demonstrate that, wherever applicable to its programs, its consideration of outcome data in evaluating the success of its students and its programs include course completion, job placement, and licensing examination information. Palmer annually collects completion data for each program offered, such as national board examination scores and pass rates, and Title IV default rates. Programmatic accreditation for doctor of chiropractic programs through the Council for Chiropractic Education (CCE) requires evaluation and posting the National Board of Chiropractic Examiners (NBCE) exam scores as a direct program assessment measure. Annually, program effectiveness key indicators such as NBCE pass rates, program completion, graduation rates, and Title IV loan default rates are evaluated by Academic Affairs. Palmer s completion and outcomes data is available to prospective and current students on the Palmer s website. Standing with State and Other Accrediting Agencies Commission Policy FDCR.A : An institution has a responsibility to remain in good standing with each state in which it is authorized or licensed as well as with any other institutional or programmatic accrediting agency recognized by the U.S. Department of Education by which it is accredited or preaccredited up to the point that it voluntarily withdraws from such relationships. An institution shall fairly represent to the Commission and to the public its history or current or previous status with other institutional or programmatic accrediting bodies and with each state in which it is authorized or licensed. An institution shall disclose to the Commission any pending or final state actions that affects the institution s legal status or authority to grant degrees or offer programs and any pending or final actions by an accrediting agency to withdraw accredited or pre-accredited status, impose a sanction or deny an application for such status. Such disclosure shall take place at the time of the action by the other entity and on the Commission s Institutional Update as well as in preparation for a comprehensive evaluation by the Commission. Programmatic Accreditation Palmer s Doctor of Chiropractic Degree Program (DCP) is programmatically accredited by the Council on Chiropractic Education (CCE). The Council on Chiropractic Education (CCE) requires the following language is included in public disclosures. This statement can be found in the College Catalog, Student Handbook as well as the College website. 17

19 Palmer College of Chiropractic 2014 Federal Compliance Report The Doctor of Chiropractic degree program at Palmer College of Chiropractic s Davenport, IA; San Jose, Calif.; and Port Orange, Fla. Is awarded programmatic accreditation by The Council on Chiropractic Education, 8049 North 85th Way, Scottsdale, AZ , Phone: (480) , Website: State Authorization In accordance with individual state legislation and the Higher Education Opportunity Act, Palmer maintains authorization or authorized exemption in all jurisdictions in which it is required by individual state regulations for recruiting and preceptorship physical presence. The Office of Accreditation and Licensure is responsible for monitoring regulation and managing required state authorization. To this end, this office employs procedural methods for review and maintenance of documentation regarding state authorization. State regulations are reviewed on an annual basis. College recruiting and preceptorship presence is collected each term, from each campus. Both state regulations and internal College data are reviewed for changes indicating need for further action on the part of the College. Consequent correspondence and proof of status with state postsecondary agencies is housed with the Office of Accreditation and Licensure. Public Notification of Opportunity to Comment Commission Policy FDCR.A : The Commission shall seek comment from third parties about institutions being evaluated for accreditation or candidacy. As part of the comprehensive evaluation, institutions shall publicize the forthcoming evaluation in accordance with established Commission procedures regarding content, dissemination, and timing. Palmer has identified major internal and external constituencies for notification of public comment. The following statement was distributed via local newspapers (Quad City Times, San Jose Mercury News, Daytona Beach News-Journal), social media outlets, internal student and departmental employee e- mail/meetings, campus-wide news communications, campus/clinic digital monitors, and posted on the College website. Palmer College of Chiropractic is seeking comments from the public about the College in preparation for its periodic evaluation by its regional accrediting agency. The College will host a visit February 2-6, 2015, by a team representing the Higher Learning Commission of the North Central Association. Palmer College of Chiropractic has been accredited by the Commission since The team will review the institution s ongoing ability to meet the Commission s Criteria for Accreditation. The public is invited to send written, signed comments regarding the College to: Public Comment on Palmer College of Chiropractic The Higher Learning Commission 230 South LaSalle Street Suite Chicago, IL

20 Palmer College of Chiropractic 2014 Federal Compliance Report Comments also may be submitted via the Commission's website at (Please select HLC Institutions, Visit List, and Third-Party Comment) Comments must address substantive matters related to the quality of the institution or its academic programs. All comments are due by January 2,