An experienced, high-level executive with a demonstrated and diverse history of working in complex educational environments, Heather F. Perfetti, Ed.D., J.D., became President of the Middle States Commission on Higher Education on July 1, 2020. Over the course of her career, she has made an impact in numerous areas of higher education, including academic and student affairs, faculty affairs, legal and regulatory affairs, strategic planning, policy development, and innovative, organizational change management. She joined the Commission in January 2015 and served in positions of increasing responsibility before being named as President-Elect in June 2019 to begin her transition to President. Dr. Perfetti earned her Doctor of Education degree with specialization in Higher Education Leadership from Northcentral University (CA), the Juris Doctor degree from the University of Mississippi School of Law, the Master of Science degree in Criminal Justice from Troy University (AL), and a Bachelor of Arts degree in English from Frostburg State University (MD).
Significant transformation will continue to define the higher education landscape. As an accreditor for domestic and international institutions, the Middle States Commission on Higher Education (MSCHE) holds student-centered standards, requirements, policies, and procedures as the foundations from which we, and our institutions, must approach change.
It is important that institutions and the public understand the accreditor’s role in helping the higher education community navigate significant changes. Whatever form the change takes, it must be approached with integrity. Mergers, acquisitions, and closures reflect complex and difficult changes where the most advice and assistance are needed to help institutions best understand how to approach them. The institutional accreditor also positions the change appropriately within the regulatory triad, which reflects the accreditor, the United States Department of Education, and state authorities. As a result, accreditors can share with institutions the diversity of experiences amidst these types of changes, which are governed by state and federal regulations as well as Commission policy and procedures, specifically in what is referred to as substantive change. Perhaps most importantly, institutions commit to the Commission’s standards, and they cannot abandon those during any moment in the many stages of change. In particular, the standard on Ethics and Integrity remains paramount when undertaking these changes and executing them.
A substantive change can impact the fabric of an institution, including the quality of education, and changes like these require approval ahead of the implementation of the change for that reason. Our Commission has a separate category for complex substantive changes, which require even more in-depth review and analysis before the change can be undertaken. Changes in legal status, form of control, or ownership are all specific kinds of complex substantive changes. These changes tend to be emotionally significant, impacting constituents and communities, and the challenges often sit beyond the legal form of the transaction.
Changes can, and do, impact an institution’s accreditation status, and that gets conveyed to the public through our Commission’s institution directory where each Statement of Accreditation Status, or SAS, can be found. In circumstances of mergers or acquisitions, if approved by the Commission, the transaction can result in an institution no longer being independently accredited as the institution becomes part of the surviving institution.
Institutional sustainability requires the consideration of many factors, and both public and private institutions are being tested in a changing higher education environment as a result. Institutional leaders must attend to their data and face the reality of the status of their institutions. We expect these important discussions about institutional sustainability, driven by data, to be drivers of sound decisions. When data shifts institutional thinking toward partnerships with others, with whatever term institutions may use – consolidation, affiliation, partnership, among others – the next best step is some time with the Commission in order to receive critical advice sooner rather than later. While an accreditor will not dictate the type of legal transaction undertaken, staff should be seen as partners in any next steps. Institutional accreditors do provide the kinds of advice and support that help institutions avoid the usual pitfalls that we see, and that can be done before any signed document incorporates what may not be permissible. Institutional accreditors hold expertise and experience in this area and can share what has worked best for institutions as they prepare to guide the legal, regulatory, and emotional aspects of the work among constituents directly impacted.
These are certainly difficult decisions for institutional leadership to face and implement, and when institutions do decide to pursue a partnership like a merger or acquisition, they must also consider what may happen through a failed attempt. Sometimes, failed attempts result in institutional closure.
This is perhaps where even more significant challenges need to come into clarity. All institutions, whether initially pursuing a merger or acquisition, or simply determining it is best to close, must plan for closure with integrity and a student-centered focus. It should go without saying that students need both time and reliable information to make informed decisions about how to complete their education following closure.
Closures reflect perhaps the most challenging times across the higher education community. The Commission has witnessed planned closures done well, and we applaud these institutions. However, more recently, unplanned closures have proven that they present unique and even more difficult circumstances for students and all constituents, including regulators.
Closing with integrity cannot happen overnight or within days. Our Commission has now defined a planned institutional closure as one that provides a minimum of six months’ notice, although we recognize that our closures done best have stretched far beyond six months. Anything less than six months is simply far too insufficient to provide students, faculty, staff, and communities the time needed to prepare for their futures. Too often inadequate information accompanies a closure that is imminent. Much like everything done in an institution’s name, it should be well-planned, and well-executed, with ethics and integrity driving decisions, even when closure may be necessary.
Institutional accreditors recognize that institutions may need to decide to close. In these situations, it is critical that institutions remain transparent with the Commission and are honest with their constituents about the status of the institution. When institutions decide to close, they often fail to understand how time is truly a gift, for them and for their constituents. Time allows institutions to tend to the many details that must be considered with a closure. The hallmarks of closures done well have been defined by transparency for students and other constituents, an approvable and implementable teach-out plan with the widest range of teach-out agreements that benefit students in all programs and considers all modalities or locations, at least a year or several years of advance notice, ending new student enrollment so additional students are not brought to the institution, and staying focused on the enrolled students and their experiences throughout all phases of a closure. Closures are certainly challenging enough without approaching them poorly or without the recognition that closures should be student-centered. Closing with integrity is only possible when at the core of the institutional decision is service to students.
Institutional leaders and governing bodies must continue to honor the principles of the Middle States Commission on Higher Education at all times, including when pursuing complex legal transactions with others or when recognizing closure may be its only option. The Commission’s Standards for Accreditation and Requirements of Affiliation and all of its policies and procedures most holistically, represent the quality required for our institutional members. Our Commission not only strives for excellence as its mission; it stands upon it to protect the future of educational quality, guide our community for good, and set the standard of quality through honest reflection.
Accreditors are not only guided by these integral principles; we also offer experience and expertise to help institutions navigate complex realities with integrity. When institutional leaders lean on their accreditors to approach changes both with the gift of time as well as with integrity, students truly benefit, and they deserve nothing less.