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Higher Learning, State Approval, and Accreditation in the U.S. and WISR

Here we explore WISR’s history and distinctive mission within the larger context of some of the themes in the long history of American higher education, and in terms of current trends in US higher education. Included as part of this discussion is the role of both accreditation and California State approval* [*under current State law, Approved” means, “approval to operate” which means compliance with state standards as set forth in the California Private Postsecondary Education Act of 2009 (California Education Code, Title 3, Division 10, Part 59, Chapter )], , as well as a consideration of some issues and questions in the quest for quality education for learning and constructive social change.

The following topics are discussed below:

**History of WISR’s State Approval and Non-Accredited Status

**WISR’s Current State Approval* Status [*under current State law, Approved” means, “approval to operate” which means compliance with state standards as set forth in the California Private Postsecondary Education Act of 2009 (California Education Code, Title 3, Division 10, Part 59, Chapter )]

**WISR’s role in helping to create the Association for Private Postsecondary Education in California (APPEC)

**Themes and Issues in US Higher Education, Today and in History

**How WISR’s distinctive approach combines many themes from higher education’s history, to break new ground today and to provide a worthy model

**Issues and Questions pertaining to Accreditation, and its role in higher education, in history and today

**The history and current role of California State Approval* [*under current State law, Approved” means, “approval to operate” which means compliance with state standards as set forth in the California Private Postsecondary Education Act of 2009 (California Education Code, Title 3, Division 10, Part 59, Chapter )]

**WISR’s history is the stories of our students successfully building bridges to the significant things they next want to do in their lives

History of WISR’s State Approval and Non-Accredited Status

WISR was incorporated in 1975. In 1977, the Institute was granted Approval for all of its degree programs by the California State Superintendent of Public Instruction, after a self-study by the Institute and a site visit by an Ad Hoc Committee appointed by the State. WISR’s State Approval status has been continued since that time, based on periodic reviews by the State of California.

In April 1987 a team of educators evaluated WISR’s academic programs in light of legislation requiring that State-Approved programs be “comparable in quality to accredited programs.” The team unanimously recommended renewal of WISR’s Approved status. The team’s report said, in part: “The Committee commends the institution on providing students with an excellent educational program and maintaining the wonderful community work carried out by the students and staff.

A WISR Graduation Ceremony

A WISR Graduation Ceremony

During 1995, WISR was evaluated by the State Council on Private Postsecondary and Vocational Education (CPPVE) according to the new statutes and guidelines. WISR received unconditional re-approval of all of its degree programs according to a State Education Code which stated that the Council (CPPVE) determined and certified that an approved institution meets minimum standards established by the Council for integrity, financial stability, and educational quality, including the offering of bona fide instruction by qualified faculty and the appropriate assessment of students’ achievement prior to, during and at the end of its program.

WISR is by design a very small institution, and has an intimate scale of instruction and operation that enhances the personalization of education. We are too small to even be evaluated by the regional accrediting agency, the Western Association of Schools and Colleges. Fortunately, the State Approval process has been developed, in part, to evaluate the integrity of institutions which offer small and/or nontraditional programs such as ours.

Currently, WISR is approved* [*under current State law, Approved” means, “approval to operate” which means compliance with state standards as set forth in the California Private Postsecondary Education Act of 2009 (California Education Code, Title 3, Division 10, Part 59, Chapter )] by the new State of California Bureau for Private Postsecondary Education through June 30, 2015. Shortly before then, WISR will be re-evaluated as part of the periodic review process that WISR has undergone since it was first State approved in 1977.

Beyond WISR’s long-standing State-approval status, the Board, faculty and staff of WISR are continually working to enhance WISR’s visibility and credibility. We are always eager to provide others with evidence of the quality of our students’ learning and accomplishments. For example, in 1987, we received a grant from the Association for Community Based Education and the Ford Foundation for documenting our students’ learning to demonstrate the quality of our non-traditional approach in terms that can be appreciated by mainstream agencies.

WISR enthusiastically supports a strong State oversight process. At WISR, we believe that consumer protection, preservation of student rights, and sound educational quality are important to a healthy and diverse postsecondary education system in California. WISR has an impeccable history of perfect compliance with state law since we were first approved in 1977, and there have been no complaints against us in that entire time.

Furthermore, in order to promote consumer protection, high quality education, and institutional integrity and credibility among State-approved institutions of private postsecondary education, WISR has taken a leadership role with about a dozen other institutions to form the Association for Private Postsecondary Education in California (APPEC). A further goal of APPEC is to be a constructive, pro-active representative for private postsecondary education in Sacramento as well as statewide. APPEC’s mission statement is:

  • APPEC provides needed assistance and services to California’s (non WASC accredited) private colleges and universities as they interact with the state and other agencies that oversee them.
  • APPEC informs all stakeholders of the important educational and economic roles private colleges and universities play in California.

US Higher Education Today and in History

More and more today, higher “education” in the United States is a story of students paying increasingly expensive tuition in order to obtain the degrees and credentials necessary to professional advancements, securing jobs, and in the understandable quest for financial survival for oneself and one’s family (present or future). In the midst of all this, many important qualities are often lost–including the quest for personal meaning in learning and in life and the opportunity to pursue an intellectually rigorous and stimulating education that is also relevant to improving one’s immediate community and the larger society and world. Indeed, WISR’s history grew out of student demands in the 60s for both personal and societal “relevance.” WISR’s ambitious mission is to do more than simply give a “relevant” alternative to the more traditional academic institutions on the one hand, or a more “personalized” option to the convenient, new online institutions and programs for the masses, on the other hand.

At WISR, we are striving to affirm some of the best of several important traditions in American Higher Education while also addressing some of the limitations of those traditions. The liberal arts colleges of the late 18th and early 19th century were founded partly on the wave of enthusiasm about the 17th and 18th century enlightenment philosophers–the notion the education and ideas can matter in life–for individuals and for the entire society–and even lead to social revolutions as was the case in the US and France. This tradition was limited in that it was Euro-centric in its origins and assumptions, and mostly accessible only to an elite class.

The Land Grant movement in the mid-19th century attempted to create greater access (even if still very, very limited in excluding many because of race and income) and with a view to the importance of practicality in education. This resulted in the creation of state universities, and especially in the development of curricula in technical and agricultural fields of endeavor. Unfortunately, this practical emphasis did not extend to studies aimed at bringing about social changes which might result in greater equality and social justice, and certainly not in the study and pursuit of environmentally sustainable methods in the fields of technology and agriculture.

WISR alumnus, Dr. Osahon Eigbike, and WISR alumnus and Board member, Dr. David Yamada

WISR alumnus, Dr. Osahon Eigbike, and WISR alumnus and Board member, Dr. David Yamada

At about the same time, many US universities were trying to emulate the scholarly rigor of the German university. The ideal here was to pursue knowledge for its own sake, in a very rigorous and specialized way. WISR takes very serious the importance of focusing attentively on the building of new knowledge, but we see limitations to over-specialization of the German university tradition, which has often resulted in esoteric and narrowly conceived scholarship, at the expense of truly imaginative, interdisciplinary and creative scholarship. Furthermore, that tradition discounts the serious and important knowledge building that can be and often is pursued by “ordinary” people in their everyday lives. At WISR our commitment is to collaborate with people, as learners, so we can all improve upon the quality and solidity of our knowledge-building efforts.

WISR as a Center and Model for Experimentation in US Higher Education

Consequently, WISR’s approach to contributing to improvements in Higher Education in the US is modest in scale (our numbers are tiny) but very, very ambitious in the ways in which we aim to model and pursue a distinctive approach to higher education. WISR’s distinctive approach draws on many themes in the history of American higher education, and it also attempts to break new ground and provide a worthy model, by combining commitments to:

  • personalized education
  • theory-action integration
  • inquiring approach to learning
  • multiculturality
  • professional study that is mindful of personal growth and values, along with comunity involvement
  • education for community involved adults from many walks of life
  • progressive social change for equality, justice, human development and a sustainable world
  • helping students to build bridges for themselves to fulfill their plans for the future.

Accreditation in American Higher Education: History, Current Issues and Questions

Accreditation in American Higher Education

In the history of American higher education, accreditation has been with us for less than half of this country’s history. It grew largely out of a need for colleges and universities to have some procedures to facilitate students transferring credit from one institution to another, toward the end of the 19th and the beginning of the 20th century. Eventually, accreditation grew to be a peer review process by which faculty at institutions who were members of an accrediting association would visit and evaluate the educational quality at another institution.

This peer review process certainly has provided many opportunities for faculty and institutions to critically reflect on and strive to improve the quality of their educational offerings. And, to an extent, it has “weeded out” the most blatant instances of diploma mills, which are nothing more than excuses to make money from people who would gladly pay “tuition” to do little or no serious work, in order to achieve a degree that they could use for seeking jobs and promotions, and in some cases, for gaining status with others. On the negative side, many educators feel that accreditation has also resulted in restrictive, procedural standardization, which to an extent has thwarted some creative educational reforms that would have contributed importantly to the health and diversity of American higher education. Some leaders in the accrediting agencies themselves are aware of these difficulties, but still many worthwhile educational innovations face enormous obstacles created by accreditation policies and procedures, and diploma mills continue to flourish.

That diploma mills can even thrive speaks to the pressures in our society—which have been accelerating every year and every decade since World War II, that place greater and greater emphasis on degree attainment and the resulting financial rewards, sometimes to the detriment true learning and scholarly engagement. Indeed, this is a problem that affects accreditation institutions. Even as early as the 1950’s, sociologist Howard Becker’s study of undergraduate education noted this trend, in his book, Making the Grade. As he pointed out, and as many have observed since, many students exert great energy and exercise considerable ingenuity in figuring out how to do “just enough” to get their degree. Faculty in the most prestigious institutions are all too aware that student motivation for learning (in contrast to the motvation to “make the grade”), or lack thereof, is a very important variable that determines the actual “learning outcomes.”

During the past several decades in dramatically increasing numbers, mature adults have been seeking further graduate education. Much more than was the case 40 or 50 years ago, adults embark on careers, start families, and want to “go back to school,” often for doctoral degrees. Sometimes, their main motivation is financial reward and career advancement, sometimes it is for learning and developing more knowledge to better help others and the society, and of course oftentimes, it is for both reasons.

Former WISR Board Member, Dr. John Bear and WISR President, Dr. John Bilorusky, at Annual Conference

Former WISR Board Member, Dr. John Bear and WISR President, Dr. John Bilorusky, at Annual Conference

During this period, a number of very large, often profit-making, institutions have been founded to respond to these motivations. And the very large, well-financed institutions are very good at navigating the accrediting process. At least two, very well known, and very enormous institutions with doctoral programs were so resourceful that they moved—one from the East Coast and one from the West Coast—to the North Central Region, in order to obtain a more favorable accrediting review. Apparently, accreditation reviews are not as perfectly “objective” or “standardized” as one might think, nor are they always so indicative of educational quality as one might wish.

Indeed, accrediting agencies can even have criteria (e.g., institutional size)–some stated in their written policies, and at other times only informally stated in conversations–as to whether or not they will even consider an institution’s application. Furthermore, if accrediting agencies are questioned about their standards and procedures, they respond that they are “voluntary associations”—they remind us that they are private and not public, and if an institution doesn’t wish to be accredited by their criteria, it’s the institution’s “choice” since they are voluntary associations and no one is compelling an institution to join their association.

California State Approval*

[*The meaning of, and standards for, State approval have changed over the years. Under current Caliornia law, Approved” means, “approval to operate” which means compliance with state standards as set forth in the California Private Postsecondary Education Act of 2009 (California Education Code, Title 3, Division 10, Part 59, Chapter )] In the midst of this landscape, California State approval came on to the scene as an alternative to accreditation—in the 1970s—at a time when such an alternative was very much needed—there were many solid, small and often nontraditional institutions starting up and there was also a proliferation of diploma mills. Previously, the State of California, like virtually States only had a procedure for the “licensure” or “authorization” of degree-granting institutions. A new institution would make a statement of purposes and operating procedures—in effect disclose their educational and business practices—pay a fee and get licensed with the authority to grant academic degrees. Historically, in the US, the authority to grant degrees is not bestowed by accrediting agencies, nor by the federal government, but by the state governments.

In the experience of those of us at WISR, the wisdom of the California legislature in the 1970s—in providing the legislative and administrative sanction for the State approval process—was that licensure (i.e., legal authority to operate) is no guarantee of quality, and lack of accreditation is no guarantee of lack of quality. Many professionals in the field of higher education also argue with good evidence that accreditation is also no guarantee of quality). The State of California stepped in with its approval process—requiring institutional self-study, much like accrediting agencies do, visiting teams (peer review) much like accrediting agencies do, and also a culture of fair-mindedness and open-mindedness, nurturing of pluralism and diversity, the latter being very much unlike accrediting agencies.

California provided for “State approval”—initially as an option beyond “authority” or licensure, and eventually as a requirement in addition to licensure, and the foresight behind this provision resulted in a blossoming of needed diversity of high quality options for higher learning in California. And of course, this diversity is very much needed in the landscape of our increasingly diverse state.

It was in this context that WISR first obtained State approval in April, 1977, and we have been reviewed by several different State oversight agencies since then—always favorably, and admittedly, some reviews have been more thoroughgoing than others. Also, we have observed that in the 70s and 80s, and perhaps into the early 90s, the review process was more attentive to issues of educational quality than has been the case of subsequent reviews. In the past 15 or so years, issues of consumer protection, certainly exceptionally important, have been given greater attention (and indeed, we would add that accrediting agencies, and accredited institutions, should be more cognizant of the importance of consumer protection), and matters of educational quality, while not at all ignored, have not been addressed with quite the same attention to detail. We suspect that this is due in part to budgetary constraints and the resulting staff limitations.

It certainly would be worthwhile for State licensed programs to work with the State in setting up a fair- and open-minded peer review process to provide for constructive evaluation and continued improvement of the educational programs offered by approved colleges and universities. Furthermore, it educational improvements and constructive innovation might be promoted if educators would join together to study and critically examine the strengths and limitations of the evaluation methods employed by accrediting agencies. Because of their long (100+ year) history and their well-established reputations, accrediting agencies hold a privileged position in the hierarchy of institutional and academic evaluation. And as private, rather than public, agencies they are accountable only to themselves—to their membership. Indeed, more than a few nationally known and respected educators have long maintained that accrediting agencies, for all the good they sometimes do, are a major obstacle to constructive innovation in American higher education. At the same time, it is worth noting that some accrediting agencies are now actively exploring and experimenting with ways that they might support responsible and quality innovations.  One such example is the increased interest in the use of faculty judgements based on evidence in student learning portfolios, and competency-based measures of education as alternative approaches to awarding academic credit–instead of relying on hours spent in a classroom where there is little further documentation of the resulting student learning.

State Regulations Requiring WISR and All Approved Schools to Obtain Accreditation by July 2020

The New Regulations:

Students; Institutions with Existing Approvals to Operate.
(a), An approved unaccredited institution enrolling a student in a degree program shall, prior to execution of an enrollment agreement, provide the student with the following notice, which shall be in at least 12-point type in the same font as the enrollment agreement:
Notice to Prospective Degree Program Students

This institution is approved by the Bureau for Private Postsecondary Education to offer degree programs. To continue to offer degree programs, this institution must meet the following requirements:
• Become institutionally accredited by an accrediting agency recognized by the United States Department of Education, with the scope of the accreditation covering at least one degree program.
• Achieve accreditation candidacy or pre-accreditation, as defined in regulations, by July 1, 2017, and full accreditation by July 1, 2020.
If this institution stops pursuing accreditation, the following will happen:
• The institution must stop all enrollment in its degree programs, and
• Provide a teach-out to finish the educational program or provide a refund.
An institution that fails to comply with accreditation requirements by the required dates shall have its approval to offer degree programs automatically suspended.
Institutional Representative Initials: __________ Student Initials: __________13
Date: ___________ Date: ___________”
(b) The student and an institutional representative shall initial and date the notice prior to executing an enrollment agreement. An initialed copy of the notice shall be given to the student and the original shall be retained in the enrolled student’s records.
(c) The notice shall also be posted immediately adjacent to wherever an institution’s degree granting programs are described and shall include, at a minimum, the following locations:
(1) The institution’s catalog.
(2) The institution’s website.
(3) The institution’s degree program brochures.
(d) This section shall remain in effect until July 1, 2021, and as of that date is repealed.
NOTE: Authority cited: Sections 94803, 94877, 94885 and 94885.1, Education Code. Reference:
Sections 94885, 94885.1, 94897, 94900, 94900.5, 94909, 94927.5 and 94932 Education Code.

What does this mean for WISR and for WISR students?

  • Prior to this new law and regulation, WISR had already decided to pursue national accreditation (see below)
  • With all accreditation efforts, there can never be a guarantee that an institution will be successful.
  • The information here is to provide updates on the concerted efforts and steps that we at WISR are taking to achieve national accreditation by 2020. For legal and ethical reasons, we cannot promise that we will obtain accreditation, but we will be transparent in disclosing our progress—to the State of California as required by law, and to students, prospective students and interested members of the general public, as well, because such disclosures to the State must be made public. 

    WISR Board, faculty, alumni and students are strongly committed to obtaining accreditation, and will keep students, prospective students and the State informed of our progress (see update below). If WISR does not obtain accreditation by July 2020, WISR will apply for a two-year extension from the State (as allowed for be an amendment to the original law), and if for any reason, WISR fails to get accreditation on a timetable acceptable to the State (July 2020 or later if there is an extension), WISR faculty will do a teach out with all WISR students, and those students will be able to receive an academic degree that is fully approved by the State of California.

40th Anniversary w-out 2015


Update on WISR’s steps in our progress toward National Accreditation, as of November 2018:

Prior to the creation of this new State regulation, WISR’s Board decided in early 2014 that WISR should pursue national accreditation from a national accrediting agency, the Accrediting Council of Independent Colleges and Schools (ACICS), which is recognized by the US Department of Education and by the Council on Higher Education Accreditation (CHEA). In June 2014, WISR was visited by the senior staff person of that agency, who is in charge of their accreditation process, and following that visit, the accreditation representative shared observations and suggestions with Dr. John Bilorusky, WISR President.  Following this conversation, WISR faculty and Board made a decision that WISR should pursue further the next steps involved in seeking accreditation from that agency.  In October 2014, Dr. John Bilorusky, attended the initial, and required, accreditation workshop for CEOs of institutions seeking accreditation from that agency.

Since July 2014, WISR’s Board, faculty, students and alumni have been taking a number of steps as part of the accreditation process . . .

  • In Spring 2016, ACICS formally invited WISR to submit formal application for accreditation. WISR did this by submitting our initial application fee to ACICS, the required information and paperwork about our institutional enrollment and status, and recent audit of our financials by a CPA.
  • In Spring 2016, we began the data gathering and self-study required by ACICS, including work on the Campus Accountability Report (CAR) and the Campus Effectiveness Plan (CEP).

Based on this self-study and the ongoing dialogue among faculty, Board, students and alumni, we have identified: 1) areas of strength at WISR that must be sustained; 2) areas of needed improvement; 3) a high level of satisfaction by students and alumni, as well as by coworkers and employers of students and alumni—in terms of WISR’s contributions to student learning. Further, we have developed a plan and a timetable for making concerted and continued progress in working on the areas of needed improvement, including budgetary projections that will support the accomplishment of these improvements, and that will sustain WISR as a vital, high quality institution of higher learning for many, many years into the future.

  • However, in early 2017, we learned that we cannot count on ACICS retaining the US Department of Education recognition that they lost in late 2016, and in any case, ACICS has decided to no longer consider for accreditation those institutions offering a doctoral degree. As a result, we decided to pursue accreditation with a different, and highly legitimate agency. We will report on that progress in due time, and in compliance with that agency’s policy on what can be stated about such progress, in what terms and when. As noted above, with all accreditation efforts, there can never be a guarantee that an institution will be successful.
  • As of November 2018, we plan to submit our self-study to this nationally recognized accreditation agency by March 2019, and will move forward with this agency based on the feedback and instructions that they give us.
  • We reiterate that for legal and ethical reasons, we cannot promise that we will obtain accreditation, but we will be transparent in disclosing our progress—to the State of California as required by law, and to students, prospective students and interested members of the general public, as well, because such disclosures to the State must be made public.
  • As part of our ongoing efforts to develop WISR toward accreditation over the past four years, we have taken, and will continue to take the following steps (among others as needed):
    • An annual CPA audit of our finances
    • A fund-raising campaign to seek donations to help with the considerable expenses associated with accreditation—with about $90,000 having been raised in the past three years.
    • Conducting annual surveys of students, faculty, Board and alumni—to identify WISR’s strengths and areas of needed improvements, and to gather data on the evidence of student learning outcomes.
    • The development of a Strategic Plan (soon to be completed)
    • Monthly meetings of Faculty, (administrative) Executive Committee, and Curriculum Committee—to aid the development of an institutional self-study, and to make needed improvements that build on WISR’s 43-year history and experience in providing quality, learner-centered education for professional and community leadership.
    • Frequent Board meetings, and meetings of Board subcommittees that also involve faculty and students.
    • Use of the WISR annual conference and the semi-annual All School Gatherings and other special meetings at WISR to plan the next steps toward a sustainable and productive future for WISR.
    • Continuing work with faculty and staff to support their professional development.
    • Development of WISR’s onsite library, with the help of a part-time professional librarian, including the cataloging of the library (in progress), as well as extending student access to online resources, through a combination of purchases of access by WISR, and identification of low-cost and free learning resources for students.
    • Refining WISR’s curriculum and putting WISR courses online in a Learning Management System using Google Education Suite (in progress, to be completed March 2019).
    • All WISR seminars are now available on site and by video/audio conference, using Zoom, and most seminars are recording for later viewing by students.
    • Addition of several new core faculty members.
    • Recruiting and involving an academic advisory committee—academicians, professionals and community leaders who can give us feedback and advice as we continue our concerted efforts to develop and improve WISR further.

WISR’s Institutional Representative and the Enrolling Student certify with their initials, below,

That the student has read, and indicates that they understand the above information—regarding

1) The State’s requirement that all approved schools like WISR obtain accreditation by July                      2020, or 2) that WISR will provide a teach out so that students can receive a State approved

degree, as initially promised.  Also that, 3) Although WISR is working toward national

accreditation with great diligence, there is never a guarantee that an institution will be successful

in such a pursuit, no matter how great the quality of student learning or faculty instruction.

Institutional Representative Initials: __________  Date: _____________

Student Initials: __________ Date: ___________

For now, at WISR we continue to build on our more than 40 years of history of showing how learning can take center stage, and to show how many WISR students use relevant, high quality learning. Our students find that they can design and pursue learning activities, and earn a State approved degree from WISR–in order to build bridges for themselves–to pursue quite successfully the next significant life-endeavors and challenges they have chosen and planned for themselves. Read more.

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