The impact of accreditation on Intensive English Programmes in the US

Two years have passed since full implementation of law requiring that all Intensive English Programmes (IEPs) in the US be accredited in order to enrol F-1 student visa holders. Despite a few bumps along the way, the implementation seems to have been mostly successful but it has also had some notable effects on the English language training market in the US. First signed into law by President Barack Obama in December 2010, the legislation specifies that, following a three-year transition period which ended in December 2013, only English programmes and institutions with accreditation granted by an agency recognised by the US Department of Education can be authorised to issue the documents – the I-20 form in particular – that international students need to acquire an F-1 student visa. Among the full list of recognised accrediting agencies are those that are primarily concerned with IEP accreditation:

• The Commission on English Language Program Accreditation (CEA), the only accreditor specialising in the work of Intensive English Programmes;
• The Accrediting Council for Continuing Education and Training (ACCET), a national accrediting agency that deals with a wide range of institutional types including career and vocational schools;
• Any of the six regional accrediting bodies for higher education institutions in the US.

Less commonly involved are accreditation bodies for other types of institutions, such as the Accrediting Commission of Career Schools and Colleges (ACCSC) which mainly oversees vocational and technical schools, some of which might have English programmes developed to help support international students enrolled in vocational programmes.

Different perspectives on the process

Proponents of accreditation argue that the law has been beneficial on several fronts. Keith Boswell, director of the Embry-Riddle Language Institute in Florida, said that the law "has done a lot to make IEPs more similar across the country and the world. We still have differences, but by meeting the same standards, students can know that they are getting good value for their time and money." Mr Boswell added that a bonus of accreditation has been the value added to ESL graduate degrees, in that "it helped us MA TESOL (Master of Arts in Teaching English to Speakers of Other Languages) people because before we were competing with people who had [graduate degrees] in all kinds of fields, many unrelated to TESOL" but that accreditors now check that qualified instructors are in the classrooms and leadership positions. Commission on English Language Program Accreditation (CEA) Executive Director Mary Reeves said that the organisation keeps reams of data including feedback gathered after completing the process, and that one common refrain from schools is the comment, "We didn’t enjoy doing it but we’re so much better for it." The accreditation process for bodies such as CEA or ACCET is not easy, and going through the cycle of self-studies, materials reviews, and site visits never assures success. ACCET provided us with statistics from 2011 showing that only 59 of 80 applicant institutions that year were granted accreditation, with 16 denials and five withdrawals. Ms Reeves adds that from 2012 forward, CEA has denied accreditation for 32 programmes. The two organisations have different timelines and benchmarking points but with either, the process takes a minimum of three years with a direct cost of around US$10,000 plus annual sustaining fees. (Both agencies also have shorter timelines and lesser fees to accredit newly opened branches of already-accredited IEPs.) The process is also demanding in terms of the time and energy needed for the school to prepare data and background information for the accreditation process. While the two organisations have separate sets of standards, CEA and ACCET each cover a wide range of operational areas, including mission, governance, financial status, and facilities along with many aspects of programmes and services, including admissions and recruiting policies, faculty qualifications, curriculum, student support, and assessment (of students, staff, and programmes). CEA currently has 44 standards in 11 areas while ACCET’s process examines 33 specific criteria across nine major areas. A curriculum director at a privately owned Midwestern ESL institute mentioned that the accreditation process "can be challenging for a small IEP like ours, since we don't have the resources of money, time, or personnel to dedicate to the process that many other schools do." But at least existing schools have been able to draw on ongoing, revenue-generating operations to support their participation in the process. The accreditation requirements represent a more significant challenge for new IEP centres. The main hindrance for new start-ups is that accrediting bodies require schools to be in full operational mode for a specified period of time (one year for CEA, two for ACCET) prior to beginning the lengthy accreditation process. But language schools are hard-pressed to enrol international students without the ability to issue the F-1 student visa documents, and they need to be accredited before they can do so. "The workarounds, when we started, included offering classes to part-time students on F-2 visas (visas for dependents of F-1 student visa holders) or residents," said Noelle Vance, managing director of the Mountain Language Institute in Colorado, which was founded in 2011. "The problem, of course, is that F-2 students and residents do not typically require the same kind of training as those who would attend an Academic English Programme designed for students who want to attend university in the US, so it is difficult to get enough students to be financially sustainable." Even though her programme gained accreditation through CEA in summer 2013 and is now able to enrol F-1 visa holders, the long delay put the Mountain Language Institute in quite a bind. Ms Vance said that "we have had several people call us during the last five years to ask us for advice on how to start a school, and we have always told them to not even try because the current regulations and agreements make it next to impossible." She adds that the best way for an operator to enter the US market may be to buy an already-accredited school. The site can keep its accreditation by merely going through a change of ownership process, which reduces the cost and risk of starting a new school. This aspect of US accreditation requirements may be a factor in some of the recent acquisition activity in the US market. In July 2015, for example, UK-based Cambridge Education Group acquired three centres in San Francisco, San Diego, and Chicago from Intrax English Programs. A month earlier, the Australia-based Holmes Group added centres in Boston and New York to its growing Oxford House College network. And the year started in a similar fashion when UK-based Oxford International Education Group added Eurocentres San Diego as the first US centre under its UIC English brand.

A different process for campus-based programmes

The lengthy and costly process that privately owned institutions must go through is quite different than the process required of university-based IEPs. After some early uncertainty about what university-based programmes needed to do to comply with the law, SEVP now requires only that university-based programmes produce documentation from the regional accrediting body verifying that the IEP is ultimately governed by their respective university administration. Most regional accrediting bodies have straightforward instructions for how campus-based IEPs can receive the proper documentation for the Department of Homeland Security’s Student and Exchange Visitor Program (SEVP). For example, the Southern Association of Colleges and Schools (SACS) requests a letter from the top administrative office of a university verifying that the IEP falls under university governance, then SACS will issue a verification that the university and all its programmes are accredited. Many proprietary language schools see a double standard here. "Schools owned by universities receive SEVP’s automatic blessing without genuine/targeted accreditation because the larger university accreditation umbrella protects them," said Ahad Shahbaz, president and CEO of INTERLINK Language Centres, which currently has three branches accredited by CEA. "Independent or tax-paying schools like ours have to undergo the long and expensive stand-alone accreditation process. This duality is very unfair because it favours colleges and universities, compromises standards, and punishes independent schools." University-based programmes that favour the status quo argue that even though the university accreditation process does not always delve deeply into the specifics of IEP centres, the affiliation with their university and the university governance structures in place provides assurance that the programme is financially supported, meets basic infrastructure needs, and has policies and procedures in place to meet standard business and educational requirements. Some IEP administrators point out that they were involved heavily in their university accreditation process. Gail Kellersberger, director of the IEP at University of Houston-Downtown said that her programme and many others she knows of are heavily involved in the accreditation processes at their universities, which she feels is as exhaustive as that of CEA or ACCET. However, the level of involvement and scrutiny of IEPs in the overall university accreditation process is not required in any way under current SEVP policy and clearly varies widely across the US. The different accreditation requirements in place make it difficult to even count the actual number of accredited US language programmes designed for students of university age and older. According to the Department of Homeland Security’s Study in the States website, there are 2,507 accredited language programmes in the US. However, that listing includes schools approved only for primary and secondary education students, which are not subject to the 2010 accreditation legislation. And since regional agencies for universities accredit entire institutions rather than specific IEPs, exact counts of university-based programmes are not easily determined either. As of the end of 2015, 273 institutions in the US (and 22 internationally) were accredited by CEA, which demands a separate accreditation process for each site of IEPs with branch locations. ACCET accredits branches within an institutional accreditation, and lists 332 sites spread among 99 institutions. Both accreditors keep lists of currently accredited schools on their websites, along with details of upcoming and recently completed accreditations.

The big picture

Accreditation for language programmes was long sought by most US ESL professionals, and both American professional membership organisations for English language programmes – EnglishUSA and University and College Intensive English Programs (UCIEP) - supported the passage of the 2010 legislation. "It was a huge shift for us," said Cheryl Delk-Le Good, executive director of EnglishUSA, who pointed out that association heavily revised its application process since many of its standards for membership are now met through schools simply verifying their accreditation. "It allows the organisation to focus on best practises with IEP directors and personnel, even though the standards of each accreditor are not exactly the same." The CEA’s Mary Reeves pointed out that even though UCIEP members do not need to undergo accreditation beyond the regional board’s approval, over 40 of the current roster of 76 UCIEP schools undertook the extra steps to earn CEA accreditation as well. Ms Reeves feels that the accreditation law has been successful in raising the overall level of programme quality across the nation. Of the 32 schools denied accreditation since 2012, 80% chose to re-apply immediately and every one of those eventually gained accreditation. "Those are the real successes. The process is so arduous, so the ones that struggle and have to come back again and again - because they have to now - survive and come out of it much better."