Council for Education

13337 South St., 416 Cerritos, CA 90703

v. 800-307-1076 x 101 | f. 877-459-7907
e. director@CforED.com
w. https://CforED.com

August 13, 2017 Office of Postsecondary Education

U.S. Department of Education
400 Maryland Avenue SW.
Room 6C115, Washington, DC 20202

VIA E-MAIL ThirdPartyComments@ed.gov

PUBLIC COMMENTS TO DELAY THE WESTERN ASSOCIATION
OF SCHOOLS AND COLLEGES, SENIOR COLLEGES AND
UNIVERSITY COMMISSION (WASC) APPLICATION FOR
RENEWAL OF RECOGNITION
Please accept these comments in response to the July 25th Notice in the Federal
Register requesting third party written comments in response to accrediting agencies
currently undergoing review for purposes of recognition by the Department of
Education. Specifically, these comments are in reference to the review of the Western
Association of Schools and Colleges, Senior Colleges and University Commission
(“WASC”).

The Council for Education (“CED”) is a public interest advocacy organization for
borrowers of federal student loans. The CED believes that the WASC has not been in
compliance with state and federal laws and, as a result, should have its application for
renewal delayed and/or denied.

The CED believes there is sufficient evidence that links WASC's membership fees to
a racketeering enterprise for the purpose of not certifying ineligibilities in the
administration of the FFEL program, which is in violation of Title VI of the Civil
Rights Act of 1964 (Title VI) of the HEA as amended (HEA). See, 34 C.F.R. Part 100
(implementing regulations); Criteria for Recognition 602.10 (a): "If the agency
accredits institutions of higher education, its accreditation is a required element in
enabling at least one of those institutions to establish eligibility to participate in HEA
programs," (Emphasis Added).

1
The CED believes that WASC conspired with state officials to breach a contract with
the U.S. Department of Education by committing fraud in the administration of the
student assistance programs authorized by subchapter and part C of subchapter I of
chapter 34 of title 42 of the U.S. Code (20 U.S.C. § 1099a). They did this by violating
Section 602.13 of Subpart B of the Criteria for Recognition of an Accrediting Agency
in failing to review a university grievance hearing transcript1 as required by the
Handbook of Accreditation, and Standards of Accreditation.

Conclusion

For the above reasons, CED urges NACIQI and staff to recommend to the Senior
Department Official (SEO) that WASC’s review be delayed until they can
demonstrate that they are no longer in violation.

Sincerely,

_________________________
Council for Education
Director, Council for Education
v. 800-307-1076 x 101
f. 877-459-7907
s. 562-273-3768
e. director@CforED.com
w. https://CforED.com

1University of California at Santa Barbara, Grievance Hearing Transcript, April 8,

1994, available at https://ts.cforedu.com
2