Dupage Policy Journal

While applauding the College of DuPage’s current board of trustees for its more "proactive" approach to potential issues, a public advocacy group says it was probably the school’s previous leadership that has earned it a meeting with the Higher Learning Commission (HLC), the region's higher education accreditor, in light of its new fraud and abuse rules.

"I think it’s a safe bet that the College of DuPage was the poster child for this action stemming from the events exposed during the Breuder era, although clearly not the only institution of higher learning in this country that had serious problems with Fraud and Abuse," the Edgar County Watchdogs said on its Illinois Leaks website.

The Edgar County Watchdogs speculate that the meeting will cover the college's accreditation status and the HLC’s new fraud and abuse policy. The policy took effect in late February through an expedited process. Until then, the HLC did not have a specific policy on fraud and abuse and did not identify those factors as a consideration for accreditation.

The new policy makes fraud and abuse much larger concerns for institutions accredited through the HLC. Previously, any instances of fraud or abuse would have been handled internally or in criminal court. While such charges might have affected an institution’s compliance with the Commission’s integrity requirements under Core Component 2.A, they were not likely to affect accreditation.

Allegations of fraud or abuse are now a much larger concern for institutions certified by the HLC. Under the new policy, the commission will perform its own investigations, the results of which are directly tied to an institution’s compliance with Core Component 2.A.

“In recent communications, the Department (of Education) indicated it expects recognized accrediting agencies to have a policy on fraud and abuse,” the HLC said in February. “The adopted policy provides some context around fraud and abuse and sends a clear message that fraud and abuse is unacceptable and would constitute grounds for a finding that Core Component 2.A is not met.”

Under the new policy, the Commission will investigate and report allegations of fraud whether received from the federal government, state entities or other parties, and then determine whether the allegations amount to a violation of the HLC’s accreditation criteria.

“In considering any allegation of fraud and abuse, the Commission may consider the nature of the allegation, whether the alleged fraud and abuse appears to meet the Commission’s understanding of fraud and abuse as outlined in this policy or in federal or state definitions of fraud and abuse, and whether the source of the allegation has provided any evidence of such fraud and abuse,” the policy states.

The Edgar County Watchdogs interpret this to mean that once the policy is triggered, the HLC will conduct its investigation regardless of the institution’s actions. Under the leadership of former President Robert Breuder, College of DuPage was racked by a series of controversies. If the new policy was not written in response to the college’s actions – plenty of other higher education institutions in the region have their own checkered pasts – it certainly could have been.

That said, it is concerning to the Edgar County Watchdogs that the new policy’s investigations will be universally applied. The report highlights the college’s new, proactive board of trustees, who by all appearances would take any allegations of fraud or abuse seriously and take the proper steps to address them.

Under the new policy, it seems that the HLC would independently investigate those allegations, putting the college’s accreditation on the line despite any actions its board might be taking to remedy the situation.