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July 9, 2018 VIA ELECTRONIC MAIL Dr. M. Wasi Khan, Chancellor East-West University 816 S. Michigan Ave. Chicago, IL 60605 Dear Chancellor Khan: This letter is formal notification of action taken by the Higher Learning Commission (HLC) Board of Trustees (“the Board”) concerning East-West University (“the institution”). This action is effective as of the date the Board acted, June 28, 2018. In taking this action, the Board considered materials from the recent Notice Evaluation, including, but not limited to: the Notice Report, the report from the Notice Evaluation team, the Staff Analysis of the Notice Report, and the institutional responses to these reports. Summary of the Action: The Board determined that the institution is no longer at risk of noncompliance with the Criteria for Accreditation and removed the institution from Notice. The institution meets Core Components 2.C and 5.B with concerns. The institution is required to host a Focused Visit, as outlined in this letter, no later than May 31, 2019. Board Rationale The Board based its action on the following findings made with regard to the institution: The institution meets Criterion Two, Core Component 2.C, “the governing board of the institution is sufficiently autonomous to make decisions in the best interest of the institution and to assure its integrity,” but with concerns for the following reasons: The institution formalized in its bylaws, and indicated in its Notice Report, that the boards would have separate spheres of influence and responsibilities. The Board of Directors would become the Foundation Division and the Board of Trustees would be the Governing Division; The institution changed the bylaws so that authority for governing the institution resides with the Board of Trustees; the Board of Directors has ceded authority for governing the institution to the Board of Trustees; The Board of Trustees meets apart from the Board of Directors, which represents a change from the practice of having joint meetings;

VIA ELECTRONIC MAIL East-West University 816 S ......July 9, 2018 VIA ELECTRONIC MAIL Dr. M. Wasi Khan, Chancellor East-West University 816 S. Michigan Ave. Chicago, IL 60605 Dear

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Page 1: VIA ELECTRONIC MAIL East-West University 816 S ......July 9, 2018 VIA ELECTRONIC MAIL Dr. M. Wasi Khan, Chancellor East-West University 816 S. Michigan Ave. Chicago, IL 60605 Dear

July 9, 2018 VIA ELECTRONIC MAIL Dr. M. Wasi Khan, Chancellor East-West University 816 S. Michigan Ave. Chicago, IL 60605 Dear Chancellor Khan: This letter is formal notification of action taken by the Higher Learning Commission (HLC) Board of Trustees (“the Board”) concerning East-West University (“the institution”). This action is effective as of the date the Board acted, June 28, 2018. In taking this action, the Board considered materials from the recent Notice Evaluation, including, but not limited to: the Notice Report, the report from the Notice Evaluation team, the Staff Analysis of the Notice Report, and the institutional responses to these reports. Summary of the Action: The Board determined that the institution is no longer at risk of noncompliance with the Criteria for Accreditation and removed the institution from Notice. The institution meets Core Components 2.C and 5.B with concerns. The institution is required to host a Focused Visit, as outlined in this letter, no later than May 31, 2019. Board Rationale The Board based its action on the following findings made with regard to the institution:

The institution meets Criterion Two, Core Component 2.C, “the governing board of the institution is sufficiently autonomous to make decisions in the best interest of the institution and to assure its integrity,” but with concerns for the following reasons:

• The institution formalized in its bylaws, and indicated in its Notice Report, that the boards would have separate spheres of influence and responsibilities. The Board of Directors would become the Foundation Division and the Board of Trustees would be the Governing Division;

• The institution changed the bylaws so that authority for governing the institution resides with the Board of Trustees; the Board of Directors has ceded authority for governing the institution to the Board of Trustees;

• The Board of Trustees meets apart from the Board of Directors, which represents a change from the practice of having joint meetings;

Page 2: VIA ELECTRONIC MAIL East-West University 816 S ......July 9, 2018 VIA ELECTRONIC MAIL Dr. M. Wasi Khan, Chancellor East-West University 816 S. Michigan Ave. Chicago, IL 60605 Dear

Chancellor Khan, July 9, 2018 2

• The Board of Trustees is comprised of individuals with deep historic commitments to the institution and of newer members who are deeply impressed by its mission and who bring new and needed expertise to the Board. The Board of Trustees has nominated a short list of individuals who are being actively recruited for the Board;

• Nevertheless, in the view of the Notice Visit team, the institution has not fully realized its new structure and the Board of Trustees needs to mature in three areas that are critical to its new role as the Governing Division.

The institution has demonstrated that it now meets without concerns Criterion Two, Core Component 2.E, “the institution’s policies and procedures call for responsible acquisition, discovery and application of knowledge by its faculty, students and staff,” for the following reasons:

• The institution recently established an Institutional Review Board (IRB) that follows the guidelines and requirements established by federal statute;

• The members of the IRB represent institutional areas and needed expertise; and • The IRB representatives were able to describe the educational training that has been

provided to faculty at the institution to create an understanding of the role of the IRB in the protection of human subjects and to begin establishing a culture in which the review of research would occur.

The institution has demonstrated that it now meets without 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,” for the following reasons:

• The institution has remained solvent through the contributions of its non-academic investments despite enrollment declines;

• The institution is proactively addressing its reliance on non-academic revenue through a number of strategies;

• Significant investments have been made in Enrollment Management, in the use and storage of student data, and with Information Technology to enhance the public website and marketing;

• The institution shared plans for investing in new positions or restoring lost positions when enrollment targets are reached on the academic and administrative sides; and

• Positions now appear to be appropriately staffed, with few individuals identified as filling multiple roles.

The institution meets 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,” but with concerns for the following reasons:

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Chancellor Khan, July 9, 2018 3

• The organizational chart appropriately divides responsibilities and the description of positions aligns with the organizational chart;

• However, the Chief Financial Officer/Provost acknowledges that she is not responsible for academic matters, which contradicts the meaning of the term “provost” in common usage;

• The Chief Academic Officer/Associate Provost does not report to the Provost, which contradicts conventional job titling practices;

• A clarification of titles in the Provost’s role needs to be aligned with the institution’s Policy IO3.02, which describes the Faculty Council as the deliberative body for all academic matters as chaired by the Provost. This clarification aligns with the title Provost only if the Provost is the Chief Academic Officer; and

• While HLC is not dictating how to title the positions, it is requiring that the titles align with responsibilities in ways that are customarily understood in higher education.

The institution has otherwise demonstrated that it is in compliance with the Criteria for Accreditation, Assumed Practices, and Federal Compliance Requirements and it is no longer at risk of being out of compliance with the Criteria for Accreditation.

Next Steps in the HLC Review Process Focused Visit: The Board required that the institution host a Focused Visit regarding Core Components 2.C and 5.B no later than May 31, 2019. The Board required the institution submit a Focused Visit Report no later than four weeks prior to the visit, demonstrating that the institution has addressed the concerns identified in the Board’s action. This Focused Visit will specifically address the following:

• Establishment of a committee structure on the institution’s Board of Trustees so that expertise and resources can be effectively used;

• The institution’s Board of Trustees must provide evidence of its continued board development through participation in professional associations that support board advancement and succession planning; and

• The institution’s administration, its Board of Directors, and its Board of Trustees should review the new bylaws for possible areas of overlap that confuse the intention to have two separate boards. Specifically, the institution should address the Notice Visit team’s observations in this regard. (See pages 16-17 of the report of the Notice Visit team).

Comprehensive Evaluation: The institution has been maintained on the Standard Pathway with its next comprehensive evaluation for reaffirmation of accreditation in 2020-21. HLC Disclosure Obligations The Board action resulted in changes that will be reflected in the institution’s Statement of

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Chancellor Khan, July 9, 2018 4

Accreditation Status as well as the Institutional Status and Requirements Report. The Statement of Accreditation Status, including the dates of the last and next comprehensive evaluation visits, will be posted to the HLC website. Information about this action is provided to members of the public and to other constituents in several ways. In accordance with HLC policy,1 this Action Letter and the enclosed Public Disclosure Notice will be posted to HLC’s website not more than 24 hours after this letter is sent to the institution. HLC policy2 requires that a summary of Board actions be sent to appropriate state and federal agencies and accrediting associations. It also will be published on HLC’s website. The summary will include this HLC action regarding the institution. At this time, HLC will reassign the institution from its current HLC Staff Liaison, Dr. Anthea Sweeney, to Dr. Thomas Bordenkircher. Please be assured that Dr. Sweeney will work with Dr. Bordenkircher to create a smooth transition. On behalf of the Board of Trustees, thank you in advance for your cooperation. If you have questions about any of the information in this letter, please contact Dr. Bordenkircher. Sincerely,

Barbara Gellman-Danley President Enc: Public Disclosure Notice Cc: Chair of the Board of Trustees, East-West University Ekkehard-Teja Wilke, Associate Provost, East-West University Evaluation Team Chair Stephanie Bernoteit, Interim Deputy Director for Academic Affairs, Illinois Board of Higher

Education Thomas Bordenkircher, Vice President for Accreditation Relations, Higher Learning

Commission Anthea Sweeney, Vice President for Legal and Governmental Affairs, Higher Learning

Commission

1 INST.G.10.010, Management of Commission Information 2 COMM.A.10.010, Commission Public Notices and Statements