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The Faculty of the Theological School Alerts the Archbishop about Losing Accreditation

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BOSTON – The faculty of the Holy Cross School of Theology wrote a letter dated March 8, 2019 addressed to Archbishop Demetrios of America and to the chairman of the Board of Trustees in which it expressed its great concern regarding three ‘notations’ imposed on the School by The Board of Commissioners of the Association of Theological Schools Commission on Accrediting.

The professors wrote to the Archbishop “these three notations is of great concern to the faculty of Holy Cross.”

They are also asking for a financial audit: “The first steps to address this notation would be to conduct a transparent audit, by outside experts, of the structural budgetary operation of the institution. This audit should be shared with administration, faculty and staff as well as trustees. We also recommend the immediate recruitment of highly qualified past and new high impact board members, either to serve on the board of trustees, or even as part of a presidential financial advising committee to assist in the strategic planning process with the board.”

The faculty’s letter is printed in its entirety below:

“A Letter of Concern from the Faculty of Holy Cross regarding the
Imposition of Notations by the Association of Theological Schools
Addressed to His Eminence Archbishop Demetrios, Geron of America,
Chairman of Hellenic College Holy Cross Board of Trustees

March 8, 2019
Your Eminence,

We greet you in the spirit of humility and forgiveness associated with the beginning of the Lenten season. It is with our deepest respect for your ministry to the Church of Christ and our acknowledgement of your love and concern for Holy Cross that we ask for your archepiscopal blessing and provide you with this letter.

The recent decision (February 7-8, 2019) by the Board of Commissioners of the ATS Commission on Accrediting to impose three notations is of great concern to the faculty of Holy Cross. The imposed notations highlight three significant areas of concern, namely, finances, governance and institutional planning. These decisions are based upon the comprehensive evaluation conducted by peers from ATS Schools who visited Holy Cross from November 12-15, 2018, for which Holy Cross produced a detailed self-study.

In response, the faculty has met several times (Nov. 20th, 2018; Dec. 11th, 2018, Jan 8th, 2019; Jan 29th, 2019; Feb. 26th, 2019), in regular and special faculty meetings, to discuss the November 2018 visit, and to carefully examine both the ATS Report of a Comprehensive Evaluation Visit for

Reaffirmation of Accreditation 11/12/18-11/15/18 (Visitation Report) and the decisions of the ATS Board of Commissioners (ATS Commission Letter) dated February 15, 2018.

Based on our understanding of the assessment and accreditation process, we recognize the seriousness of the three notations we have received as an institution (N1.b; N7.a; and N8.b). As a faculty we are committed, as Your Eminence is, to the success of the School and recognize that these ATS notations require immediate and comprehensive action. Per the ATS Report, failure to immediately and properly address these notations within the next 19 months (no later than November 1, 2020) will result in “an adverse action [i.e., withdrawal of accreditation]” (ATS Commission Letter, p. 3).

A Letter of Concern from the Faculty of Holy Cross March 8, 2019

We are alarmed because we do not see proper and appropriate steps being taken by the leadership of HCHC and the board of trustees to respond to these notations in a manner consistent with the expectations of ATS and best practices in higher education. We have yet to see the administration provide a plan of action to address these compliance issues and we are frustrated due to the lack of communication between the administration and faculty on common issues related to the ATS report. Further, we are disheartened in that Holy Cross had previously received a notation from ATS on insufficient institutional strategic planning processes in 2012 that ATS removed in 2014 only to have it reinstated in 2019. We are concerned that we do not repeat the very practices and mistakes that ATS has identified as insufficient and ineffective.
We understand that the current administration is under enormous pressures to attend to the immediate financial concerns of the School, also noted by ATS (ATS Commission Letter, p. 2, no. 7a). These immediate and urgent financial stresses have the potential to distract us from the important and urgent issues raised by ATS. Based on our years of work with ATS, we know that we can implement a comprehensive process of responding to the important issues raised by ATS. A proper response to the issues raised by ATS is the most effective means of addressing the immediate financial concerns of the School.

At this time, the faculty has put in place a process for responding to those aspects of the ATS Visitation Report and the ATS Commission Letter that fall directly under our responsibility. Specifically, we have taken the following actions in response to the Commission’s decisions regarding assessment of student learning and program assessment:

1. Adoption of a summative exercise to incorporate into the MTS program along with
review of MTS program goals and learning outcomes. Report on adoption of a MTS
summative exercise is due, October 1, 2019 (ATS Commission Letter, p. 2., no. 7.a).
Additionally, we will review program goals and learning outcomes for the ThM
program along with consideration of additional summative tools for the ThM. A
report on MTS and ThM program goals and leaning outcomes is due, April 1, 2020.
2. Establishment a committee to develop a timeline for faculty to address educational
assessment (Educational Standard, section ES.6) to complete the work of the Faculty
regarding learning outcomes, assessment tools, rubrics and benchmarks, and
evidence of assessment-based changes within each degree program (ATS
Commission Letter, p. 2, no. 7.c). Report due, April 1, 2020. Further, we intend to
procure the assistance of an assessment consultant who can provide clarity as to the
best practices and assist faculty in developing appropriate benchmarks and
measures for formative and summative student learning outcomes.

We acknowledge that the responsibility for addressing the imposed notations (N1.b; N7.a; and N8.b) falls upon all of us who are invested in the institution: the faculty, the administration, and A Letter of Concern from the Faculty of Holy Cross March 8, 2019
the board of trustees. ATS understands the process of responding to notations to be a collective response by the major stakeholders that must include the board of trustees. Below are some of our thoughts concerning the three notations issued by ATS and some of the parameters within which the School’s response ought to be undertaken.

Notation N1.b:“The Institution’s planning processes are insufficient or ineffective.”

In the Visitation Report, ATS identifies their expectations for proper strategic planning as well as their concerns about our insufficient and ineffective institutional planning processes.

“The Institution is encouraged to develop an institutional strategic plan including relevant, prioritized, and measurable goals that are linked with a long-term financial plan, and a revised system of ongoing institutional evaluation that will assist administration and board of trustees in the effective decision-making processes essential to the future success of the institution.” (Visitation Report, Section 1)

Further, the report indicates our intent to develop a 2019-2024 strategic plan which is “under consideration by the board of trustees who will appoint a steering committee as well as subcommittees responsible for new strategic initiatives and goal structures.” (Visitation Report, Section 1) We see little or no evidence that a strategic planning process has been initiated either by the president, the administration, or the board of trustees.
We, as a faculty, are alarmed because a process of developing a strategic plan should have been initiated in 2016. The previous 5-year plan was for 2013-2018, and a proper process for developing a new strategic plan requires an 18-24 month process of active involvement of the board of trustees, faculty, and administration through a deliberative process that reflects best practices.

Properly responding to this notation would consist of initiating a strategic planning process that reflects best practices, and engages the faculty, administration and the full board of trustees. This would require, initially, such things as the establishment of a genuine steering committee, in-depth conversations with the faculty regarding current and future academic programming, the hiring of a strategic planning consultant, the establishment of subcommittees, and the development of a time-table for a proper strategic plan.
I

nformation on the process of strategic planning can be found at the website of In Trust, an organization focusing specifically on developing board of trustee leadership for theological schools (http://www.intrust.org/Topics/Strategic-planning). A Letter of Concern from the Faculty of Holy Cross March 8, 2019

Notation N7.a“The institution does not adequately or appropriately define, exercise, or implement the roles, responsibilities, and structures of authority and governance.”

ATS has demonstrated a respect for the unique relationship between the School and the Greek Orthodox Archdiocese. From our vantage point and that of the ATS Visitation Report, this notation indicates that we as an institution have failed to clearly define and adequately implement the roles of the board of trustees, the president, the deans and the faculty within the overall context of shared governance (see Section 7 of the Visitation Report).
ATS has expressed concerns, that “…the board may not be exercising its authority only as a group (Standard 7, section 7.3.1.8), and found inadequate evidence that the board has created and employed adequate structures for assessing the performance and accountability of chief administrative leadership (Standard 7, section 7.2.1.6)” (Visitation Report, Section 7). In Trust provides guidelines on how to effectively evaluate an institution’s chief executive officer (http://www.intrust.org/Portals/39/docs/presidential-evaluation.pdf). In addition, ATS noted their concern that the board of trustees did not exercise “adequate financial oversight” of the School (Visitation Report, Section 7).

The ATS evaluation committee recommended “the institution would benefit from a review of the operative structure of governance to ensure it is clear where the authority for maintaining the integrity and vitality of the school resides, and how that authority is exercised in actual practice” (Visitation Report, Section 7). We as a faculty welcome such a review and encourage that such a review would incorporate the review of the Faculty Handbook which Hellenic College and Holy Cross faculty began in Fall 2017. Further, we encourage the board of trustees to read carefully Section 7 of the Visitation Report.

Properly addressing these concerns would include such things as: an assessment of board membership to ensure adequate depth and expertise on the board to guide the work of the School; detailed reports informing the board on all aspects of the issues currently facing the institution (ATS notations, Massachusetts Department of Higher Education, NEASC/NECHE, etc.); and special meetings of the entire board to address the immediate and long-term issues facing the school (Bylaws of Hellenic College, Inc., 2014, Article 2, Section 10).

These initial steps related to the expansion, education, and engagement of the board represent significant and critical first steps in addressing all imposed notations. We fear that failure to implement even these basic steps is evidence of repeated poor practices.

Notation N8.b.“The institution’s financial resources are not adequate for long-term institutional viability and there is no credible plan to address this in a timely and effective manner.”

While the administration is taking action to address the short-term financial issues at this time there is no evidence of any steps toward long-term financial viability. ATS explicitly identified A Letter of Concern from the Faculty of Holy Cross March 8, 2019
the failure of the board regarding the long-term finances of the school: “Although the president has implemented austerity measures to bring expenditures in line with revenue, the team saw little evidence of board actions to address the long-term viability of the institution” (Visitation Report, Section 7). As Your Eminence is aware, this particular issue is not new. This was identified more than a year ago by former members of the board of trustee and reaffirmed by the ATS review committee.

The first steps to address this notation would be to conduct a transparent audit, by outside experts, of the structural budgetary operation of the institution. This audit should be shared with administration, faculty and staff as well as trustees. We also recommend the immediate recruitment of highly qualified past and new high impact board members, either to serve on the board of trustees, or even as part of a presidential financial advising committee to assist in the strategic planning process with the board. ATS expects that we would recruit, in addition to clergy with pastoral experience, experts from various fields, committed to the life and ministry of the Church and School, who possess expertise at taking vision and mission and laying out an operational plan to meet those goals (ATS Standard 8.2.3). These individuals would have expertise in, for example, finance, strategic planning, real estate, higher education, administration and operations.
Conclusion

ATS has indicated that they are keenly aware of our inadequate processes and our pattern of failing to engage in best practices, or take proper steps, specifically regarding strategic planning, governance, and finances. Any deviation from their expectations of real and appropriate action, at this point, will most likely result in the withdrawal of accreditation, independent of the shortterm efforts currently underway. These simple and basic first steps, at this time, represent the critical steps necessary to respond to ATS.
The faculty is prepared to participate in, and contribute to, an appropriate, open and transparent process of responding to the ATS notations. Time is of the essence. We would welcome a meeting with Your Eminence to discuss any of the issues we have identified.

Respectfully,
The Faculty of Holy Cross Greek Orthodox School of Theology
cc Vice-Chair, HCHC Board of Trustees
Executive Committee, HCHC Board of Trustees
Full-time Faculty of Holy Cross.”


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