C.S. 3.13 POLICY COMPLIANCE

In a letter[1] dated July 11, 2017, 2017 Dr. Denise Young requested that Palo Alto College respond to concerns raised by unsolicited information received by the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC), as stipulated by SACSCOC policy.  These concerns raised questions for the SACSCOC Board of Trustees regarding Palo Alto College’s autonomy and the College’s ongoing compliance with six standards of the Principles of Accreditation.  This narrative responds to Comprehensive Standard 3.13 (Policy Compliance: Reaffirmation of Accreditation and Subsequent Reports).  Specifically, the SACSCOC Board of Trustees asks that the College address the following: provide sufficient evidence that the institution, as a separate entity, has authority for the appointment and employment of all institutional personnel; provide sufficient evidence that your institution represents itself as a separate entity as exemplified in institutional materials, such as the College Catalog, websites, marketing materials, and other documents; clarify whether the institution represents itself as a single institution (Alamo Colleges) with multiple campuses, or multiple independent institutions (Palo Alto College) with the U. S. Department of Education.

Statement of Compliance:  Palo Alto College is in compliance with Comprehensive Standard 3.13 (Policy Compliance: Reaffirmation of Accreditation and Subsequent Reports). The College has authority for the appointment and employment of all institutional personnel, represents itself as a separate entity in its institutional materials, and represents itself as a separate entity with the U.S. Department of Education. The case for compliance is structured as follows:

1. Sufficient evidence in the form of Board policy, hiring processes, and corresponding practices demonstrates that Palo Alto College has full authority over the recruitment, selection, and hiring of all college personnel.
2. Sufficient evidence in the form of distinct college materials and indication of independent accreditation status demonstrate that Palo Alto College represents itself as separate entity in its institutional materials.
3. As indicated through several federal identifiers, Palo Alto College represents itself as an independent institution with the U.S. Department of Education.

A.   FULL AUTHORITY FOR APPOINTMENT AND EMPLOYMENT OF PERSONNEL

Palo Alto College has full authority over the recruitment, selection, and hiring of all college personnel as indicated through the following evidence:  

1. Hiring Process and Practice. Palo Alto College has full control over its recruitment, selection, and hiring processes which identifies the best qualified candidates for all available positions. The College has an autonomous, comprehensive hiring process which adheres to the following steps for every position:

• Vacant position is posted on the College’s job website[2].
• Search committee of college personnel is formed.
• Search committee short-lists candidates for interview with committee.
• Search committee recommends finalists for interview with College President and appropriate Vice-President.
• College President discusses the finalists with appropriate College manager/administrator.
• In consultation with the College President, the appropriate College manager/administrator approves the selected candidate for hire.  Where required — only in the case of administrators and full-time faculty— the College President recommends the selected candidate to the Chancellor for approval by the Board of Trustees. 

Evidence of the College’s hiring processes in practice are reflected in a college-wide message[3] sent by the President which informed the college community of several hiring searches which took place in Spring 2017. Specific examples supporting Palo Alto College’s full authority over appointment and employment of college personnel are apparent in the hiring packets — which include a snapshot of employment opportunities at the College, the job posting, and a description of the hiring search, and Board minute orders and meeting reports where applicable — for recently appointed positions: an administrator[4], a full-time faculty[5] member, and a full-time staff[6] member. In fact, the most recently approved administrator role, Dean of High School Pre-College Programs, is unique to Palo Alto College and does not exist at any college within the Alamo Community College District. The review, selection, and appointment of these positions was determined by College personnel; the administrator and full-time faculty positions were approved by the Board of Trustees in accordance with Board Policy D.2.5 (Hiring Authority, Status, Assignments and Duties).

2. Board Policy.Palo Alto College has full authority over the recruitment, selection and hiring of all college personnel; only administrators and full-time faculty require board approval. Non-contract and temporary staff do not require Board approval. In July 2017, Board Policy D.2.5[7] (Hiring Authority, Status, Assignments and Duties) was revised to provide clarity to the hiring practices of Palo Alto College. The policy states that the Chancellor, in consultation with the College President, recommends administrators and full-time faculty appointments to the Board of Trustees for approval.

B.   REPRESENTATION AS A SEPARATE ENTITY

Palo Alto College represents itself as a separate entity in College materials as indicated in the following evidence:

1. College’s Materials Aligned with Brand Standards. New brand standards and logo stylesheets were developed and applied to various Palo Alto College materials following clarification regarding naming conventions. In January 2017, Board Policy A.1.1[8] (Legal Name and College Organizational Units) was revised to provide clarity as to the naming convention of the District. The Board of Trustees added “Alamo Colleges District” as an assumed name of the Alamo Community College District, which is the College District’s legal name. This naming convention follows that of other systems with independently accredited colleges such as Texas A&M University, the University of Texas, and the University of Tennessee. Evidence of the new brand standards and the College’s representation as a separate entity are depicted in the following materials:

• Brand Standards Guide[9]
• College Website[10]
• Student Transcript[11]
• Course Catalog[12]
• Outreach Schedule[13]
• Acceptance Letter & Packet[14]
• Starts Here Campaign[15]
• Fact Book[16]
• State of the College Publication[17]
• President’s Message[18]

2. Expression of Independent Accreditation Status. Palo Alto College’s accreditation status is distinctly expressed in the About Us[19] section of the College’s website, the most recent Course Catalog[20], and general information brochures[21]. The Board of Trustees website[22] clearly states the independently accredited status of the College. Offer letters of employment for adjunct faculty[23] and staff[24] clearly state appointment to Palo Alto College.  Faculty contracts[25] also show their distinct affiliation with the College.

C. REPRESENTATION AS AN INDEPENDENT INSTITUTION WITH THE U.S. DEPARTMENT OF EDUCATION

Palo Alto College represents itself as an independent institution to the U.S. Department of Education through various means — and accordingly, is also recognized by the U.S. Department of Education as an independent institution — as evidenced by the following:

1. Unique Integrated Postsecondary Education Data System (IPEDS) Number. Palo Alto College has a unique IPEDS number[26] (246354) and reports all IPEDS data using this unique identifier, and the National Center for Education Statistics produces an IPEDS Data Feedback Report[27] for Palo Alto College.

2.  Individual Federal Grant Submissions and Reporting. Palo Alto College has a unique DUNS number (782010227) used in federal grant applications submitted on grants.gov[28].  Grant award letters[29] and congressional notifications[30] demonstrate the U.S. Department of Education’s recognition of the College’s independent status.  Annual Performance Reviews (APR)[31] for grant programs further demonstrate the College’s representation as an independent institution with the U.S. Department of Education.

3.  Unique Federal Student Aid (FAFSA) School Code. Palo Alto College has a unique Federal School Code[32] (016615) used by students applying for federal financial aid.  As indicated in the Federal Student Aid website[33], the U.S. Department of Education requires that schools participating in federal student aid programs be independently accredited.

4.  Recognition as an Independently Accredited Institution. A U.S. Department of Education [34]letter[34] regarding confirmation of acceptable practices dated February 7, 2017, states that “the Department acknowledges that the four Alamo Colleges, San Antonio College, St. Philip’s College, Palo Alto College, and Northwest Vista College, are separately accredited by the Southern Association of Colleges and Schools Commission on Colleges.” This letter serves as federal recognition that Palo Alto College is an independent institution and aligns with the College’s representation of itself as a separate entity.

5.  College-specific Reporting to the Department of Education.  In compliance with the Jeanne Clery Disclosure of Campus Security Policy and Campus Statistics Act, an annual Clery Act report[35] is submitted detailing Palo Alto College information. College correspondence[36] informs the Department of Education and the Clery Act Compliance Division (CACD) that Palo Alto College certifies that the 2012, 2013, and 2014 Annual Security Reports were distributed in accordance with the Clery Act. Furthermore, the College conducts a program review as required by the Drug Free Schools and Communities Act as a condition of receiving any federal funding or other financial assistance. A hard copy of the AY2014 Biennial Review[37] of the College’s Alcohol and Other Drug Programs is available through the office of the Vice President for Student Success and can be provided to the U.S. Department of Education as requested. The Clery Act and Biennal Review Reports each reflect college-specific reporting to the Department of Education.