This testimony from Robert Shireman, TCF senior fellow, is scheduled to be delivered to the National Advisory Committee on Institutional Quality and Integrity on June 23, 2016. Shireman urges the advisory committee to recommend against continued federal recognition of an accrediting agency that has approved many disreputable colleges. A summary of the testimony will be presented live at the committee meeting by Tariq Habash, TCF policy associate.

Madam chair and members of the committee, thank you for the opportunity to provide input into the question of the continued federal recognition of the Accrediting Council of Independent Colleges and Schools (ACICS). After the staff recommendation was released last week I was able to see the documents that were made available to you, and I was surprised that there were so few actual visiting team reports and letters from ACICS. So today I have brought copies of ACICS reports from seventeen California campuses, which were provided to us in response to a public records request we made to the veterans agency in that state.

As you have seen, the evaluation reports from ACICS consist of fifty to seventy pages of yes-no checkboxes and short-answer factual questions on hundreds of items, such as the contents of the catalog, the existence of a mission statement, the adequacy of staff training, and the resumes of administrators. It is as if the entire form was designed to eliminate any possibility of critical thinking: no curiosity or suspicion or nuance is allowed.

I would point your attention to the section about student recruitment. In 2010, ACICS had only yes-no questions asking about recruitment: whether recruiters were providing accurate information about tuition and campus policies, and whether the job titles of recruiters are appropriate. In 2011, a question was added asking the team to “describe the process for the recruitment of new students,” and then to declare whether the practices are ethical, or not. It was still an exceedingly simplistic approach, but it at least created the opening for an evaluator to look into a possibly problematic area. By 2011, of course, there was no shortage of reasons to be suspicious about the marketing strategies of for-profit colleges. An investigation by a U.S. Senate committee had found that ITT Tech’s training manual for its recruiters to use emotionally manipulative “pain funnel” techniques to get students to enroll.1

Three months after that revelation, ACICS teams were at three ITT campuses in California. The team visiting the Rancho Cordova campus committed all of two sentences to the topic of student recruitment, with the team blandly reporting that “The campus seeks to attract students with the motivation and ability to complete the career-oriented educational programs offered by the ITT Technical Institutes.” No analysis whatsoever, except perhaps the answer to the next question: Are the recruiting practices ethical?


The campus in San Dimas had a longer description of the recruitment process that can be summarized as:

  • There is an initial contact with a student.
  • An interview
  • A tour
  • A Wonderlic admissions test
  • Financial aid information.
  • Ethical? Yes.

Interestingly, the San Diego description was similar in structure and content:

  • Contact with student
  • Campus visit
  • Interview
  • Wonderlic exam
  • Ethical? Yes.

Then, a year later, there are three more ITT campuses up for review,2 and all the visiting team descriptions of the recruiting process are, again, remarkably similar. In fact, one of them even answers the question with a bulleted list: contact, tour, interview, financial aid, Wonderlic exam. Ethical? Yes!

Excerpt from the ACICS evaluation team report of the ITT Tech campus in San Bernardino, California, January 2012.
Excerpt from the ACICS evaluation team report of the ITT Tech campus in San Bernardino, California, January 2012.

And it is not just the teams visiting ITT that seem to notice precisely the same things about the structure and content of the recruiting process at every campus. The visiting team at Le Cordon Bleu in Pasadena, in September 2012, described the recruitment process in the same way: a person shows interest, he or she is interviewed, takes a tour, learns about financial aid, and takes the Wonderlic exam. Ethical? Yes!

That very same month, September 2012, ACICS held an accreditation workshop in Chicago. All of the campus presidents from the Kaplan Higher Education chain were in attendance. While their campuses had been using other accreditors, the company had made the “strategic decision to seek ACICS accreditation for selected campuses.”3 Coincidentally, Kaplan was the other company, besides ITT, that had been found the previous year to be using the “pain, fears and dreams” training material for its recruiters, a revelation that ITT had somehow been able to weather in its reviews by ACICS (which might be why Kaplan liked the idea of switching to ACICS, but I cannot attest to the company’s motivations).

Four months later, an ACICS evaluation team visited the Kaplan College campus in Vista, California. The team members reported that the process for student recruitment is that, after a student makes contact, there is an interview, a tour, a Wonderlic exam, and then financial aid. Are these recruiting practices ethical? Yes! One month later, at the Kaplan campus in Riverside, California, the same thing: student interest, interview, tour, Wonderlic, financial aid. Ethical? Yes.4

Just last year, when the ITT campus in Vista came up for review by ACICS, the visiting team, again, described the same basic pattern in the recruiting process: student inquiry, an interview, a tour, and financial aid. Ethical? Yes!5

I do not know whether ACICS is poorly run, or a corrupt organization, but it is clear from this sampling of evaluation reports, and from the staff report you have already reviewed, that ACICS is not a reliable authority on the quality of postsecondary education. It is evident from these documents that the ACICS accreditation process is not a serious attempt to promote quality in higher education. It is not even a serious effort to prevent bad quality. The federal recognition of ACICS should not be renewed.

Thank you for the opportunity to provide input today.


  1. Chris Kirkham, “For-Profit College Recruiters Taught To Use ‘Pain,’ ‘Fear,’ Internal Documents Show,” Huffington Post, February 8, 2011 (updated May 25, 2016),
  2. San Bernardino in January 2012 (excerpt shown), and Sylmar and Torrance in October.
  3. The materials submitted by Kaplan to the California Veterans Agency includes a brief description of the “ACICS Accreditation Initiative” that had been launched by Kaplan Higher Education.
  4. The Vista visit was January 28-29; Chula Vista, February 18-19; Riverside, February 27-28.
  5. September 2015.