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Dear Commission Representative, I am writing on behalf of President Ronald Thomas and the faculty, staff, and students of the University of Puget Sound, in my capacity as Accreditation Liaison Officer, with our responses to the invitation to comment on Draft 5.0 of the revised NWCCU standards. Most of the comments were provided by members of the Puget Sound faculty and staff at an open campus meeting on Monday, September 21. Before turning to specific comments on the standards, it is important to note that there were some sentiments of concern expressed about the new seven-year process. o The current approach (ten-year self-study/five-year interim report) designates significant momentsin-time for taking stock. The campus gets a sense, from such a cross-sectional examination and comprehensive “dashboarding,” of its specific and holistic work. With the new approach, there is concern that there is never opportunity to truly step back from the ongoing work of meeting NWCCU expectations to get a sense of perspective. The potential “fatigue” of reporting assessment for reaccreditation on an ongoing basis will potentially cause campus participants to lose the ability to “see” needs, gains, and accomplishments and will make “benchmarking” a difficult task. o At least one meeting participant familiar with the AQUIP model, an option in the North Central region, noted the similarity to the proposed seven-year process and how this approach makes reaccreditation a constant burden of higher education life. Several voices, while affirming the “show your work” approach to demonstrating that a culture of evidence and assessment in fact is pervasive on the campus, wondered “who is going to do all of the work?” On a campus where we already have comprehensive five-year curricular reviews, five-year program reviews, and three- and five-year faculty evaluations, where does a lean faculty and staff get the time to add on the mandated reaccreditation work of a continuous, every two year, reporting cycle? o A thoughtful staff leader asked: Is this shift in practice beneficial for our students? If faculty and staff spend considerably more time reporting then will they be spending less time educating students? With respect to strengthening the region’s knowledge of assessment tools and practices, our meeting participants suggested that NWCCU should consider hosting professional development workshops on best practices in assessing student learning outcomes. It was noted that in the Northwest everyone seems to be floundering without best practice guidance. Such guidance would be especially helpful if institutions of similar type could come together efficiently to learn/share best practices. We understand that this may be a conflict of interest for the NWCCU—the need is there but the remedy may need to come from alternative sources. With respect to Draft 5.0 of the Revised Standards, we forward the following observations for your consideration: 1. There is considerable variation in the level of detail among the standards. There is very broad, global language in some standards and very specific language in others; the reason for this unevenness is unclear. The broad language allows institutions to be more creative and allows for more flexibility among different types of institutions; however, the juxtaposition with the areas of specific language makes framing difficult. We note that, for some areas (e.g., finance), the consolidation is nicely framed. 2. Since the new tax returns required for private colleges have been expanded, could the NWCCU see their way to accepting the tax return(s) and audited financial statement(s) as the required documentation—rather than requiring that the same information be reconfigured into an accreditation-specific format (which requires much extra labor from staff)? 3. Specific input on standards: a. b. c. d. e. f. g. 4.B.1/4.B.2 – What is the definition of “appropriate constituencies?” Does each school decide, or is there an external mandate that constituencies might include the general public, US News, etc.? 2.A.10 – Similarly, how does one discern what “appropriate” means? 4.A.3 – Conceptually, does the “sum” of accomplishment of every course objective mean one has met major objectives? Does the “sum” of major objectives and core (general education) objectives necessarily mean institutional educational goals are achieved? 3.A.1 – What does “planning results” mean? 2.A.23 – Please state the last sentence of this section in the affirmative. As it currently reads, institutions must affirm a “negative” or null hypothesis (“It makes no statement regarding possible future accreditation status…”). 2.B – Delineate a “staff” section under 2.B (Human Resources); perhaps move 2.B.2 under the staff heading. 2.C – Add faculty resources to this section? Currently, faculty resources are not addressed. Thank you for the opportunity to comment on the revised standards.