Last December, the Department of Education’s Inspector General released a bizarre alert memorandum concerning American InterContinental University, a for-profit school with branches throughout the country, and its accreditor, the Higher Learning Commission of the North Central Association of Colleges and Schools (HLC). As Kevin noted at the time, the report certainly seemed like strong stuff, even questioning whether the accreditor should be trusted by the Department. Unfortunately, whole pages worth of redacted information made it impossible to tell exactly what had gotten the Department so incensed.
The Department’s response to a Freedom of Information Act (FOIA) request filed by Education Sector helps shed some light on the issue. Though the Department refused to release additional documents related to this issue, it did un-redact more portions of the alert memo (PDF).
Based upon this new information, we now know that the accreditor’s concerns about AIU stemmed from the school’s offering of 9 credits for individual undergraduate and graduate courses, mostly in the business department—classes that the alert memo refers as being “inflated in credit.” According to Jeff Leshay, a spokesperson for Career Education Corporation, AIU’s parent company, these were either accelerated courses that could be completed by students in five weeks or students could pass two of them simultaneously over the course of 10 weeks. A total of 186 undergraduate courses featured this credit structure.
When HLC reviewed these classes as part of an accreditation decision, it found some of them to have insufficient content to justify the awarding of 9 credits. “There were some undergraduate courses that the [accreditation] team thought were awarding too much credit for what the course was,” said Sylvia Manning, the president of HLC. “I don’t think it’s a question of whether you offer 9 credit courses, it’s a question of how much you do for the nine credits.”
The accreditor’s report at one point even refers to AIU’s credit policies as “egregious,” a finding that was un-redacted by the Department in response to the FOIA request. Manning downplayed the word, noting that “its range of meaning is fairly wide” and the team meant it in the sense of “out of line with common practice.”
HLC did, however, find that the inflated credit issue was not sufficient to affect the accreditation decision, as Manning said the school is “good enough to accredit provided they cure the problems that we see.”
Why should the possibility of inflated credit courses matter? For starters, students need to earn credits in order to graduate. Providing too much reward for insufficient classwork could mean that students are leaving school having not learned as much as their degree would indicate. Second, it creates problems when transferring in or out of the institution, as something worth 9 credits at one school may only be worth 3 or 4 credits elsewhere. As a general rule of thumb, credits earned on a 10-week quarter system, such as the one at AIU, are typically worth about two-thirds of that amount when converted to a semester system. A 9 credit course is thus roughly equivalent to a 6 credit class. (Typical semester-length classes are worth about 3 or 4 credits.)
Both in response to the accreditor’s findings and as part of an already ongoing process, AIU moved to a new system this calendar year that awards only 4.5 credits per course. Only students who came in before the change can still take 9 credit courses. “We were comfortable and confident in the credit structure that we had,” Leshay said. “We’ve now shifted gears into another one that we are also confident in.” He added that the school changed to the new system both to help with ease of course transfer and because it better aligned with common credit standards.
Here’s where the difficulty between connecting credit hours and content comes into play. At first Lesahy stressed that the course changes were “more about restructuring them to fit with a 4.5 credit course structure than it was about changing content because we felt very comfortable and proud about the content that was included.” He added that this meant students would have to take more courses, “but it wouldn’t be accurate to say that it’s exactly double because the courses were restructured so some courses split in two. But it’s not an exact 50 percent of content in the first course and 50 percent in the second.”
That answer raises questions about how the new structure fits with HLC’s finding that the content offered in the 9 credit courses did not merit 9 credits. Saying the work in a 9 credit course does not merit 9 credits suggests that dividing the course roughly in two would not merit a duo of 4.5 credit courses. When pressed about this issue, Leshay said all of the 9 credit courses were evaluated both as part of an annual process and in response to HLC. “Every one of those 186 courses either had content added or content otherwise updated or adjusted,” Leshay said. ” Sometimes it’s not that you’re adding more content, you’re updating or revising content.”
Why all the redactions?
The credit value of classes is a pretty important issue for students. Those trying to graduate need to know if they’ve fulfilled distribution requirements or need to take more classes. Transferring students need to know either how much their courses will be worth at another institution or what kind of credit they will receive for the classes they bring in with them. So why is an alert memo dealing with an issue that would seem very important to students so heavily redacted?
Part of the answer lies with the nature of accreditation. Manning said HLC’s team reports are kept confidential as a way of encouraging greater openness among the school and accreditor. Since the alert memo largely contains selected findings from the team report, this information is not publicly released.
But there can be significant effects from releasing such a heavily redacted memo. Manning expressed concerns that releasing the alert memo in the midst of the ongoing investigation into problems already identified by HLC “does a lot of collateral damage,” especially for students. “As soon as you put something like [the alert memo] into the media, a lot of students are going to have their credentials called into question in a way that is unfair to the students,” Manning said. “And we tend to put the interests of the students first.” It would be unfair to blame past students for this situation, but isn’t questioning the courses that make up a credential logically lead to questions about the degree anyway?And shouldn’t past students want to be fully aware of this issue?
I asked Manning if the accreditor required students to be notified of the change and the concerns raised. She said it did not because the accreditor only requires the notification of students if a school is sanctioned, and the actions against AIU did not meet that threshold.
So how does all of this square with the language in the alert memo itself, which says things like “HLC’s accreditation of AIU calls into question whether it is a reliable authority regarding the quality of education or training provided by this institution”? Unfortunately, the high levels of redacted information make it impossible to tell if the Department’s language is merited or over the top. The bits of information released in response to our FOIA provides better clarity, but lots of important questions remain unanswered.


Chad Aldeman
Kristen Amundson
John E. Chubb
Constance Clark
Peter Cookson Jr.
Thomas Dawson
Joni Finney
Andrew Gillen
Sara Mead
Jeff Selingo
Ben Wildavsky
Mandy Zatynski 

