March 9, 2015 BY CERTIFIED MAIL Rev. Robert L. Niehoff, S.J., President John Carroll University 1 John Carroll Boulevard University Heights, OH 44118-4581 Dear President Niehoff: This letter is formal notification of action concerning John Carroll University (“the University”) by the Higher Learning Commission Board of Trustees (“the Board”). At its meeting on February 26, 2015, the Board continued the accreditation of the University and placed the University on Notice because the University is at risk of being out of compliance with the Criteria for Accreditation and the Core Components identified in the Board’s findings as outlined below. This action is effective as of the date the action was taken. In taking this action, the Board considered materials from the most recent comprehensive evaluation, including but not limited to the self-study the University submitted, the report from the comprehensive evaluation team, the report of the Institutional Actions Council (IAC) Hearing Committee, institutional responses to these reports, and other materials relevant to the evaluation. The Board required that the University file a Notice Report no later than July 1, 2016 providing evidence that the University is no longer at risk for non-compliance with the Criteria for Accreditation and Core Components identified in this action and that it has ameliorated the issues that led to the Notice sanction. The Notice Report should also provide evidence of continued progress on student assessment outcomes, institutional effectiveness and planning, and communication and morale and should include the following specific documentation:

• evidence that the University has implemented a student outcomes assessment plan showing how data

are being used consistently across all programs and courses in all departments and how these data are being used to inform curriculum decisions including the newly implemented core;

• evidence that data from program reviews is included in the assessment process and these data inform decision-making at the course, program, and institution levels;

• evidence that all programs have participated in and completed a program review and that the next five-year cycle of program reviews is implemented with all programs scheduled within the cycle for further review;

• evidence that institutional planning is linked to the budget and planning decisions are prioritized and integrated through the institution as a whole;

• a new strategic plan in a form standard for higher education and including a regular cycle of strategic planning;

• information about how the University has addressed and will continue to address concerns regarding morale and communication among staff, faculty, and administration;

• evidence that the University has evaluated the success of its strategies to address concerns regarding morale and communication and that the University has a sustainable and strategic plan to address these matters on an ongoing basis;

Rev. Robert L. Niehoff, March 9, 2015 2

The Board also required that the University be required to host a focused visit in September 2016 to validate the contents of the Notice Report. The Board will review the Notice Report and related documents at its February 2017 meeting to determine whether the institution has demonstrated that it is no longer at risk for non-compliance with the Criteria for Accreditation and Core Components identified in this action and whether Notice can be removed, or if the University has not demonstrated compliance, whether accreditation should be withdrawn or other action taken. In addition, the Board placed the University on the Standard Pathway and required that the University host its next comprehensive evaluation (Year Four) in 2018-19 and its evaluation for Reaffirmation of Accreditation in 2024-25. While the Board concluded that the University currently meets the Criteria for Accreditation, the Board nevertheless had concerns about the University’s ability to remain in compliance with the Criteria for Accreditation in the future and based its action to impose Notice upon the following findings made with regard to the University:

The University is at risk of being out of compliance with Criterion Three, Core Component 3.A, “the institution’s degree programs are appropriate to higher education,” for the following reasons:

• at the time of the evaluation visit several academic programs had not developed or published learning outcomes;

• since the evaluation visit the University has developed minimum learning outcomes for each academic program but has not yet differentiated learning outcomes sufficiently by degree level or otherwise demonstrated mature processes to assess student learning outcomes, as noted with regard to Core Component 4.B.

The University is at risk of being out of compliance with Criterion Four, Core Component 4.A, “the institution demonstrates responsibility for the quality of its educational programs,” for the following reasons:

• at the time of the evaluation visit the University had not consistently completed program reviews for its academic programs, and many departments had lacked formal program review for several years;

• since the evaluation visit the University has developed a new template for academic program review and completed three reviews but has not yet demonstrated a consistent pattern of taking responsibility for the quality of academic programs through an ongoing practice of academic program review, as required by this Core Component.

The University is at risk of being out of compliance with Criterion Four, Core Component 4.B, “the institution demonstrates a commitment to educational achievement and improvement through ongoing assessment of student learning,” for the following reasons:

• the University has a longstanding pattern of inconsistent and inadequate sustained attention to assessment of student learning and failed to implement the 2007 assessment plan presented to the Commission;

• the University presented limited evidence of a functional assessment and academic program review across all curricula and programs to the evaluation visit team;

• the assessment data reflected only initial stages of collection and analysis and provided no indication that assessment was used to improve student learning;

Rev. Robert L. Niehoff, March 9, 2015 3

• faculty had not been fully engaged in the assessment process with less than half of the full-time faculty engaging in committee work in 2010-12;

• since the evaluation visit University has made progress in identifying leadership for assessment; completing student learning outcomes for all majors; establishing a clear assessment plan, timetable and system; allocating resources for assessment; and engaging faculty in assessment;

• however, the University has not yet shown evidence of a mature assessment system operating on regular basis to inform decision-making and contribute to ongoing improvement of the curricula, as required by this Core Component.

The University is at risk of being out of compliance with Criterion Five, Core Component 5.B, “the institution’s governance and administrative structures promote effective leadership and support collaborative processes that enable the institution to fulfill its mission,” for the following reasons:

• at the time of the evaluation visit the University’s governance and administrative structures

did not provide evidence of effective leadership for the institution because of serious communication and morale issues across the governance structures;

• communication among administrators and between the Board or administration and the faculty had often appeared to be one-way and not marked by appropriate collaboration or receptivity;

• committees intended to facilitate shared governance lacked effectiveness because there was insufficient orientation of all committee members and lack of understanding by all committee members of the collaborative role of such committees;

• since the evaluation visit the University has acted to re-establish leadership structures across the University, establish new committees to address collaboratively the budget and related areas, and provide increased opportunities for communication;

• however, the University has not yet demonstrated that such changes are effective on a long-term basis in facilitating effective leadership and collaboration, as required by this Core Component.

The University is at risk of being out of compliance with Criterion Five, Core Component 5.C, “the institution engages in systematic and integrated planning,” for the following reasons:

• the evaluation visit team found that the University had not appropriately linked strategic

planning with budgeting, assessment of student learning, and academic program review; • the evaluation team also found that faculty and department chairs and other internal

constituents lacked appropriate input into the budget, planning and decision-making processes;

• also, because assessment activities were suspended in the past, analysis of evidence from assessment of student learning outcomes did not appropriately inform planning, budgeting, and evaluation processes;

• since the evaluation visit the University has demonstrated that, while it has not had a systematic planning process, it has engaged in strategic thinking leading to institutional progress; it is also beginning a new strategic planning process and centralizing assessment and program review so that it may better inform planning;

• however, the University has not demonstrated a long-term pattern and practice of systematic and integrated planning, as required by this Core Component.

The University is at risk of being out of compliance with Criterion Five, Core Component 5.D, “the institution works systematically to improve its performance,” for the following reasons:

Rev. Robert L. Niehoff, March 9, 2015 4

• the evaluation visit team found that the University lacks documentation of systematic

evaluation of institutional performance and improvement that provides overarching vision and perspective for institutional planning;

• the University did not provide the team with evidence that an institutional effectiveness plan was operational, and the development of future institutional goals did not include necessary environmental scanning or institution-wide performance evaluations;

• since the evaluation visit the University presented evidence of new structures and policies to improve institutional performance; however, the University has not yet fully integrated its academic assessments with financial, enrollment, facilities and operational outcomes data nor has it demonstrated a long-term pattern of systematic institutional work to improve performance, as required by this Core Component.

The University meets with concerns Criterion Five, Core Component 5.A, “the institution’s resource base supports its current educational programs and its plans for maintaining and strengthening their quality in the future,” because the University has increased its tuition discount rate at the expense of net revenues, and has relied on increased endowment spending for several years to support its operational expenses, even though such draws may be technically permitted by the endowment rules used by the University, which is a pattern that compromises institutional resources over time if not corrected.

At this time, the Commission will reassign the University from its liaison Vice President Karen Solomon to Vice President Anthea Sweeney. If you have any questions or concerns about the information in this letter, please contact Dr. Sweeney. Please be assured that Dr. Sweeney will work with Dr. Solomon to create a smooth transition. The Board action resulted in changes to the affiliation of the University. These changes are reflected on the Institutional Status and Requirements Report. Some of the information from that document, such as the dates of the last and next comprehensive evaluation visits, will be posted to the Commission’s website. Information about the sanction is provided to members of the public and to other constituents in several ways. Commission Policy INST.G.10.010, Management of Commission Information, anticipates that the Commission release action letters related to the imposition of a sanction to members of the public. The Commission will do so by posting this action letter on the Commission website. Also, the enclosed Public Disclosure Notice will be posted to the Commission’s website not more than 24 hours after you receive this letter. Commission policy INST.E.10.010, Notice, subsection Disclosure of Notice Actions, requires that an institution inform its constituencies, including Board members, administrators, faculty, staff, students, prospective students, and any other constituencies about the sanction and how to contact the Commission for further information. The policy also requires that an institution on Notice disclose this status whenever it refers to its Commission accreditation. The Commission will monitor these disclosures to ensure they are accurate and in keeping with Commission policy. I ask that you copy Dr. Sweeney on emails or other communications with campus constituents regarding the sanction as required and provide her with a link to information on your website and samples of related disclosures. In addition, Commission policy COMM.A.10.010, Commission Public Notices and Statements, requires that the Commission prepare a summary of actions to be sent to appropriate state and federal agencies and accrediting associations, and published on its website. The summary will include the Commission Board action regarding the University. The Commission will also simultaneously inform the U.S. Department of Education of the sanction by copy of this letter.

Rev. Robert L. Niehoff, March 9, 2015 5

If you have questions about any of the information in this letter, please contact Dr. Sweeney. On behalf of the Board of Trustees, I thank you and your associates for your cooperation. Sincerely,

Barbara Gellman-Danley President Enclosure: Public Disclosure Notice cc: Chair of the Board of Trustees, John Carroll University Evaluation team members

Dr. Jeanne Colleran, Provost and AVP, John Carroll University Dr. Anthea M. Sweeney, Vice President for Accreditation Relations, Higher Learning Commission Dr. Karen J. Solomon, Vice President for Accreditation Relations and Director, Standard Pathway,

Higher Learning Commission Ms. Karen L. Solinski, Vice President for Legal and Governmental Affairs, Higher Learning

Commission Mr. Herman Bounds, Accreditation and State Liaison, Office of Postsecondary Education, U.S.

Department of Education