March 3, 2016 BY CERTIFIED MAIL Dr. Ann Bolman, President Western Dakota Technical Institute 800 Mickelson Dr. Rapid City, SD 57703-4018 Dear President Bolman: This letter is formal notification of action concerning Western Dakota Technical Institute (“the Institute”) by the Higher Learning Commission (“HLC” or “the Commission”) Board of Trustees (“the Board”). At its meeting on February 25, 2016, the Board placed the Institute on Probation because the Institute is 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 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 report the Institute submitted, the report from the comprehensive visit team, the report of the Institutional Actions Council (IAC) Hearing Committee, institutional responses to these reports, and other materials relevant to this evaluation. The recommendation to impose Probation is subject to the requirements outlined in this letter. The Board required that the Institute file a plan by June 1, 2016 outlining how it will demonstrate it meets the Assumed Practices identified in this action by the end of the Probation period. The Board also required that the Institute file an Assurance Filing no later than July 2017, or eight weeks prior to the comprehensive evaluation, providing evidence that the Institute has ameliorated the findings of non-compliance identified in this action that resulted in the imposition of Probation and providing evidence that the Institute meets the Criteria for Accreditation, the Core Components, Federal Compliance Requirements, and the Assumed Practices; while the Institute must address all of these requirements, its particular focus should be on those areas of non-compliance identified in this action. The Institute will host a comprehensive evaluation no later than early September 2017. The Board will review the team report and related documents at its February 2018 meeting to determine whether the institution has demonstrated that it is now in compliance with all Criteria for Accreditation and whether Probation can be removed, or if the Institute has not demonstrated compliance, whether accreditation shall be withdrawn. If the findings of non-compliance and other concerns identified in this action have not been fully ameliorated or if the institution is unable to demonstrate that it fully meets the Criteria for Accreditation and Assumed Practices such that Probation may be removed, the Commission shall withdraw accreditation. The Board based its action on the following findings made with regard to the College:

The Institute is 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:

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•   The Institute’s responses to the IAC Hearing Committee’s questions indicated a lack of clarity regarding assessment of student learning and program review, with both incorporated in the new “book” and thus projected to be conducted at the same time; the institution seemed to conflate these processes, and as a result the strategies and goals for each process have considerable overlap;

•   There was no evidence that the Institute’s assessment practices have resulted in improvement of student learning; moreover, there was very limited documented evidence that assessment had resulted in improvement of rigor or relevance for the Institute’s students on a broad institutional scale;

•   Neither program review nor assessment is systematically or regularly linked directly or indirectly to strategic planning and budget development, and the isolated examples expressed during the hearing are not indicative of systematic or regularized links;

•   The IAC Hearing Committee concurred with the visiting team’s conclusions that there is consistent lack of institutional clarity regarding competencies, course SLOs (Student Learning Outcomes), PLOs (Program Learning Outcomes) and core abilities;

•   Although the Institute has done hard work to develop competencies and outcomes and to express that work in both the self-study report and the institutional response through use of the pyramid schematic, both the institutional response and the hearing testimony indicated that there is not clarity throughout the Institute on the relationship between the various outcomes and competencies;

•   As noted in Commission documents, the visiting team documents, and briefly in the Institute’s self-study report, the Institute has been monitored on assessment of student learning since the 2008 comprehensive visit, and that visit resulted in a seven-year renewal of accreditation and a required progress report on assessment; moreover, the Institute’s initial progress report was not accepted and the follow-up progress report was found inadequate but accepted due to the timing of the next comprehensive visit; and

•   The Institute received advance notice after the last progress report that assessment of student learning would be an important component of the 2014-2015 comprehensive evaluation visit; however, the Institute, in both the self-study report and in its subsequent institutional response to the team report, noted that a change of leadership resulted in an assessment gap from 2007 to 2010.

The Institute is out of compliance with Criterion Four, Core Component 4.C, “the institution demonstrates a commitment to educational improvement through ongoing attention to retention, persistence and completion rates in its degree and certificate programs,” for the following reasons:

•   The Institute does not have systems to regularly collect or use data broadly across the institution; •   The lack of consistent and systematically collected data regarding all aspects of the institution is a

major obstacle in the Institute’s commitment to quality improvement, particularly related to retention, persistence and completion;

•   The IAC Hearing Committee examined the self-study report, the Institute’s website, and the institutional response and consistently found limited data points, limited performance indicators (other than those set by the State of South Dakota), and an absence of data; in addition, during the hearing, institutional representatives were asked about the systematic collection and application of academic data, but no clear answers or compelling evidence was provided;

•   The Institute provides compliance data to the State of South Dakota, HLC and the U.S. Department of Education; yet beyond these data sets, there was no evidence that further data are systematically collected for program reviews, budget decisions, allocation of resources, and institutional improvement; and

•   The Institute still needs comprehensive and systematic data collection for improvement of

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student learning, resource development, and rigorous academic changes, most likely centralized, to achieve its goals.

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

•   The Institute is not regularly collecting data to measure progress in achieving the goals of the

strategic and enrollment plans; •   In its response to the comprehensive evaluation team report, the Institute acknowledged that the

2012-2015 strategic plan did not include key performance indicators and that the 2012 enrollment plan was not implemented, which indicate that the core component is not met;

•   Data presented at the IAC Hearing on assessment and program review were primarily anecdotal and limited to a small number of programs, leaving unclear to the IAC Hearing Committee how the data are being used to make changes in curriculum and instruction across the institution or in the budgeting process; and

•   Although institutional effectiveness measures such as retention and completion rates are required by the South Dakota Department of Education, no evidence was presented indicating that these data are also used to improve institutional effectiveness.

In addition, the Institute meets with concerns Criterion Two, Core Component 2.A, “the institution operates with integrity in its financial, academic, personnel, and auxiliary functions; it establishes and follows policies and processes for fair and ethical behavior on the part of its governing board, administration, faculty, and staff” because, although there has been progress in developing new policies and structures, the mere existence of polices does not ensure that they will be followed, and the Institute has not yet demonstrated that the policies are implemented and regularly monitored to assure that they are effective.

The Institute meets with concerns 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” because, although it appears that the Board executes its appropriate role in terms of leading the institution but not involving itself in the day-to-day operations of the Institute, there remain at present insufficient communication channels between the Board and the Institute and the Institute’s community to ensure that the Board is sufficiently informed and can make decisions in the best interest of the institution.

The Institute meets with concerns Criterion Two, Core Component 2.D, “the institution is committed to freedom of expression and the pursuit of truth in teaching and learning” because, although the Institute has in place a new policy on Academic Freedom and Faculty Responsibilities, there has not been sufficient time to demonstrate that these changes are effective in encouraging staff to raise questions and concerns with the knowledge that, should their opinions and recommendations be in opposition to those expressed by administration, there will be no retaliation.

The Institute meets with concerns Criterion Three, Core Component 3.B, “the institution demonstrates that the exercise of intellectual inquiry and the acquisition, application and integration of broad learning and skills are integral to its educational programs” because, although the Institute has made recent changes to strengthen its General Education and improve student learning, the process is not sustained broadly throughout the institution in that the inter-relationships among Core Abilities (seven essential workplace skills), Program Outcomes, Student Learning Outcomes, and Competencies are numerous and multi-faceted yet improvements are slow and insufficiently widespread.

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The Institute meets with concerns Criterion Three, Core Component 3.C, “the institution has the faculty and staff needed for effective, high-quality programs and student services,” because, although there have been changes to the Curriculum Committee and accompanying improvements to policies and communication related to faculty and staff, the Institute has not yet demonstrated that these approaches are effective in assuring high-quality programs. The Institute meets with concerns Criterion Four, Core Component 4.A, “the institution demonstrates responsibility for the quality of its educational programs” because, although the Institute has addressed many aspects of this issue, there remain concerns about the current status and sustainability of the newly implemented program review process in that there are still no means by which to assess the program reviews for the Institute given that no complete reviews, including data points, are available under the new “book,” and there was no evidence of use of data, review of outcomes, or linkages to budget.

The Institute meets with concerns 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” because, although significant changes have taken place since the May 2015 visit and following the arrival of the Institute’s new president to encourage collaboration, inclusion and transparency along with a strategic planning process inclusive of faculty, staff, external partners, and the Board, there remain, as the new president acknowledged, climate issues for the community.

The Institute meets with concerns Criterion Five, Core Component 5.C, “the institution engages in systematic and integrated planning” because, although the Institute presented evidence of appropriate links between budgeting and strategic planning, there was no evidence of how either program review or assessment is linked directly or indirectly to strategic planning and budget development; as such, the Institute must still demonstrate how recent policy changes and expanded Board engagement are resulting in systematic and integrated planning.

The Institute does not meet Assumed Practices C.6 regarding assessment data and D.4 regarding institutional information systems.

The Board action resulted in changes to the affiliation of the Institute. These changes are reflected on the Institutional Status and Requirements Report. Some of the information on that document, such as the dates of the last and next comprehensive evaluation visits, will be posted to the HLC website. At this time, the Commission will reassign the Institute from its liaison Dr. Eric Martin, to Dr. Anthea Sweeney. If you have any questions or concerns about the information in this letter, please contact Dr. Sweeney. Please be assured that Dr. Martin will work with Dr. Sweeney to create a smooth transition. Information about the sanction is provided to members of the public and to other constituents in several ways. HLC policy INST.G.10.010, Management of Commission Information, anticipates that HLC will release action letters related to the imposition of a sanction to members of the public. HLC will do so by posting this action letter to its website. Also, the enclosed Public Disclosure Notice will be posted to HLC’s website not more than 24 hours after this letter is sent to you. In addition, HLC policy COMM.A.10.010, Commission Public Notices and Statements, requires that HLC 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 HLC Board action regarding the Institute. HLC will simultaneously inform the U.S. Department of Education of the sanction by copy of this letter.

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HLC policy INST.E.20.010, Probation, subsection Disclosure of Probation 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 HLC for further information. The policy also requires that an institution on Probation disclose this status whenever it refers to its HLC accreditation. HLC will monitor these disclosures to ensure they are accurate and in keeping with HLC policy. I ask that you copy Dr. Sweeney on emails or other communications regarding sanction and provide her with a link to information on your website and samples of related disclosures. 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 Chair of the Board, Western Dakota Technical Institute Mr. Steve Buchholz, Vice President for Institutional Effectiveness and Advancement, ALO Dr. Eric Martin, Vice President and Chief of Staff, Higher Learning Commission Dr. Anthea M. Sweeney, Vice President for Accreditation Relations, Higher Learning Commission Ms. Karen L. Solinski, Executive 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