DOCUMENT RESUME

ED 274-244 HE 019 678

T/TLE Eligibility for Institutional Participation in theCal Grant Program.. A Report to the Legislature andGovernor in Response to Senate Bill 362 (Chapter6772, Statutes of 1985). Commission Report 86-21.

INSTITUTION California State Postsecondary Education Commission,Sacramento.

PUB DATE Jun 86NOTE 26p.AVAILABLE FROM California Postsecondary Education Commission, 1020

Twelfth Street, 3rd Floor, Sacramento, CA 98514.PUB TYPE Legal/Legislative/Regulatory Materials (090) --

Reports - Descriptive (141) -- Tests/EvaluationInstruments (160)

EDRS PRICE MF01/PCO2 Plus Postage.DESCRIPTORS Accreditation (Institutions); *Eligibility;

Evaluation Criteria; *Grants; *InstitutionalEvaluation; *Law Schools; Postsecondary Education;*State Aid; *Student Financial Aid; UndergraduateStudy

IDENTIFIERS *California

ABSTRACTEligibility criteria for institutional participation

in the Cal Grant awards program was assessed by the CaliforniaPostsecondary Education Commission in cooperation with the StudentAid Commission. Attention was directed to alternatives to thesecriteria that would permit the use of these awards by bothundergraduates enrolled in nonaccredited, state-approvedpostsecondary institutions, and by students enrolled in law schoolsaccredited by the California Committee of Bar Examiners. Thepotential costs and other demands that could accrue to the Cal Grantawards program as a result of using alternative eligibility criteriawere also evaluated. Five alternative eligibility criteria wereconsidered in the context of maintaining the state's policy ofutilizing state funds to supplement federal student financial aid. Inaddition to distinguishing the three parts of the Cal Grant program,information is provided on four classifications of institutionalrecognition (accreditation, approval, authorization, andauthorization for Schools of Theology). Seventy nonaccreditedinstitutions that haw been approved as of January 1986 are listed,along with 34 law accredited law schools. The text of Senate Bill 362is appended, along with the questionnaire used to study eligibilitycriteria. (SW)

************************************************************************ Reproductions supplied by EDRS are the best that can be made *

* from the original document. *

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ELIGIBILITYFOR INSTITUTIONAL PARTICIPATION

IN THE CAL GRANT PROGRAM

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ne people ot the State ol California do enact as 1

SECTION 1. (a) The California PostseconiCommission, in cooperation with the Student Aid Cconduct an assessment of eligibility criteriaparticipation in the Cal Grant awards program (Article 3 (commencing with Section 69530) of Choof the Education Code. The assessment shall inclu(be limited to, an identification of alternatives tcriteria set forth in Section 69536 of the Education (permit participation by California postseconthinstitutions or programs that have full institutional

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CALIFORNIA POSTSECONDARYEDUCATION 1'5'N'; COMMISSION

"PERMISSION TO REPRODUCE THISMATERIAL HAS BEEN GRANTED BY

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TO THE EDUCATIONAL RESOURCESINFORMATION CENTER (ERIC)."

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U.S. DEPARTMENT OF EDUCATIONOfIce of Educational Research and Improvement

EDUCATIONAL RESOURCES INFORMATIONCENTER (ERIC)

fithis document has been reproduced asreceived from the person or organizationoriginating it

0 Minor changes have been made 10 improvereproduction quality.

Pointsotview or opimonsstated in this oc ument do not necessarily represent officialOERI position or policy.

Summary

In Senate 13111 362 (Carpenter, 1985), the Legislaturedirected the Commission to report by July 1, 1986,on alternatives to current eligibility criteria for col-lege and university participation in the Cal Grantawards program. The Legislature also asked theCommission to identify alternatives that would per-mit the use of these awards by undergraduates en-rolled either in nonaccredited State-approved insti-tutions or in law schools accredited by the CaliforniaCommittee of Bar Examiners.

Part One of this resulting report provides back-ground information on pages 3-7 about the CalGrant program and about existing criteria for deter-mining institutions eligible to participate. Part Twoconsiders alternative eligibility criteria for State-ac-credited law schools (page 9) and for State-approved,degree-granting colleges and universities (pages 9-12). Part Three on pages 13-14 presents five con-clusions about alternative criteria and a recommen-dation against any statutory changes at the presenttime in the current criteria.

The Commission adopted this report on June 9, 1986.on the recommendation of its Policy DevelopmentCommittee. Additional copies of the report may beobtained from the Publications Office of the Commis-sion. Further information about the report may beobtained from Suzanne Ness, the public informationofficer of the Commission, at (916) 322-0145.

ELIGIBILITY FORINSTITUTIONAL PARTICIPATIONIN THE CAL GRANT PROGRAM

A Report to the Legislature and Governorin Response to Senate Bill 362

(Chapter 6772, Statutes of 1985)

CALIFORNIA POSTSECONDARY EDUCATION COMMISSIONThird Floor 1020 Twelfth Street Sacramento, California 95814

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COMMISSION REPORT 86-21JUNE 1986

THIS report, like other publications of the California Postsecondary EducationCommission, is not copyrighted. It may be reproduced in the public interest, butproper attribution to Report 86-21 of the California Postsecondary Education Com-mission is requested. 5

Contents

Preface 1

Purpose of the Report 1

Methods of the Study 1

1. Background on Institutional Eligibility 3

State Licensure of Degree-Granting Institutions

Origins of Senate Bill 362

2. Alternative Eligibility CriteriaAlternative Eligibility Criteria for State-Accredited Law Schools

7

9

9

Alternative Eligibility Criteria for State-Approved Institutions 8

3. Conclusions and Recommendation 13

Appendix A: Senate Bill 362 15

Appendix B: Survey Instrument 17

References 19

6

DispZays

1. Scope of the Three Parts of the Cal Grant Program, 1980-81Through 1984-85 3

2. Provisions for Degree-Granting Authority in California by PrivatePostsecondary Education Institutions as of January 1986 4

3. Approved Institutions as of January 1986 5

4. Law Schools Accredited by the California Committee of BarExaminers as of January 1986 6

Preface

Purpose of the reportSenate Bill 362 (Carpenter, Chapter 772, Statutes of1985) which is reproduced in Appendix A), directsthe California Postsecondary Education Commis-sion, in cooperation with the Student Aid Commis-sion, to assess the eligibility criteria for institutionalparticipation in the Cal Grant awards program, andto:

1. Identify alternatives to these criteria that wouldpermit the use of these awards by undergraduatesenrolled in nonaccredited, &ate-approved postsec-ondary institutions:

2. Identify alternatives to these criteria that wouldpermit the use of these awards by students enrolledin law schools accredited by the Committee of BarExaminers of the State Bar of California; and

3. Analyze "the potential costs and other demandsthat could result to the Cal Grant awards programfrom the implementation of the alternative eligibihity criteria."

SB 362 stated legislative intent that students notrely exclusively upon Cal Grant awards for financialassistance, and that the assessment be submitted tothe Legislature no later than July 1,1986. With thisreport, the Commission responds to that directive.

Methods of the study

To assist with the study, the Commission convened atechnical advisory committee with the followingmembers:

Victor Bertolani, Acting PresidentConsortium of State Accredited Law Schools

W. Eric Collins, DeanSan Francisco Law School

Sumner Gambee, Associate DeanEducational Support ServicesThe California State University

William H. Gaylor, Jr., ChairmanCouncil for Private Postsecondary

Educational InstitutionsPresident, William Lyon University

John A. Gorfinkel, ConsultantCommittee of Bar Examiners

of the State Bar of California

Kate NI. Jeffrey, Assistant DirectorStudent Financial Aid and LoansUniversity of California

A. William May, ConsultantPrivate Postsecondary Education DivisionCalifornia State Department of Education

an Murray, Director of Student Financial AidDominican College of San Rafael

Peter D. Prentiss, Program ManagerCal Grant A ProgramCalifornia Student Aid Commission

Alvin Ross, Executive SecretaryCalifornia Association of State Appro ved

Colleges and UniversitiesPresident, Ryokan College

Daniel Rubalcava, DirectorFinancial AssistanceRancho Santiago College, Santa Ana

Lucy Sands-Berger, The ChancelloryCalifornia Community Colleges

Andrew Smolich, DeanLincoln Law School of Sacramento

With the assistance of members of the committee,Commission staff developed the survey instrumentreproduced in Appendix B regarding enrollment inCalifornia's State-approved institutions. Data onenrollment of students who have not yet obtained abachelor's degree in law schools accredited by theCommittee of Bar Examiners were provided by thatCommittee, which also supplied tuition and fee in-formation on these schools.

The Commission acknowledges with thanks the as-sistance of the technical advisory committee, theCommittee of Bar Examiners, and the respondentsfrom State-approved institutions in the completionof this report.

8 1

I Background on Institutional Eligibility

CALIFORNIA'S Cal Grant program, by which theCalifornia Student Aid Commission awards funds topostsecondary students in three separate categories-- Cal Grants A, B, and C -- is the State's largeststudent financial aid activity. (Descriptive informa-tion about the three parts of the program appears inDisplay 1 below.)

Any California postsecondary institution enrollingundergraduates is eligible to participate in the CalGrant program if (1) it participates in at least two ofthe federal government's three campus-based stu-dent aid programs, arid (2) its students participate inthe federal Basic Educational Opportunity (Pell)Grant Program. The Legislature adopted this policy

in 1980 in order to maximize financial aid resourcesfor students by requiring that institutions partici-pate in the full range of federal assictance programs,with State student aid funds used to supplement,rather than supplant, federal funds.

One implication of this policy, however, is that Cali-fornia, like such other states as Florida, New Jersey,New York, Ohio, Pennsylvania, and Texas, hastherefore adopted the federal eligibility requirementthat institutions either be accredited or candidatesfor accreditation by a nationally recognized accred-iting agency or have their credits accepted on trans-fer by at least three accredited institutions -- ratherthan using State recognition to determine eligibility.

DISPLAY I Scope of the Three Parts of the Cal Grant Program, 1980-81Through 1984-85

Applicants as New Freshmena Percent of Recipients as aHigh School Percent ofHigh AverageGraduates School Graduates AwardPur2ose and Student Eligibility

Cal Grant AAssist low- and middleincomeundergraduates with tuition and feecosts. Student eligibility criteria forthis program include fin andal needand high grade-point average

Number of FreshmenAcademic Year Applicants Recipients

1980-81 69,027 9.119 24.5% 3.2% $1,6171981-82 92,180 8,588 34.0 3.2 1,637198283 87,236 8,506 31.6 3.1 1,5461983-84 90,998 7,908 33.3 2.9 1,5561984-85 94,569 9,885 35.1 3.7 1,726

Cal Grant BAssist disadvantaged students whohave a potential for college successand community leadership. Studenteligibility criteria for this programinclude level of parental education.family size, and other indicators ofstudent potential.

Cal Grant CProvide skilled workers forcritical occupations by supplyingoccupational educational aid toneedy and talented students.

Source: Governor's Budgets.

Academic Year>lumber ofApplicants

Number ofAwards

AwardWinners asa Percent ofApplicants

AverageAward

1980-81 41,437 6.995 16.9 1.4311981-82 58,064 6.825 11.7 1.3811982-83 56.029 6.825 12.2 1.3421983-84 56,082 6.825 13.5 1.3791984-85 55.448 7,500 12.2 1,422

1980-81 14,934 1,374 9.2 1,4181981-82 19,916 1.337 6.7 1,1631982.83 20,140 1,337 6.6 1,327198384 21,972 1.337 6.1 1,2691984-85 22,390 1,420 6.3 1,393

93

State licensureof degree-granting institutions

In California, accreditation is only one of severalmeans that the State uses to recognize non-State-supported colleges and universities. The PrivatePostsecondary Education Act of 1977, as amended,which governs the licensure process in order to "en-courage privately supported education and protectthe integrity of degrees and diplomas conferred byprivately supported as well as publicly supportededucational institutions," grants independent andprivate institutions the authority to award academicdegrees if they meet one of its four requirements:

1. Accreditation by a national accrediting associa-tion recognized by the United States Secretary ofEducation, by the Western Association of Schools

and Colleges, or by the California Committee of BarE xaminers;

2. Approval by the State Superintendent of PublicInstruction;

3. Authorization by the Superintendent, based oncompliance with specified standards; or

4. -- for schools of theology which award degrees pri-marily in religious study -- authorization by the Su-perintendent without an assessment of quality.(Display 2 below presents summary informationabout these four classifications of recognition.)

Approval of nonaccredited institutions

Approved institutions are reviewed by the Private

DISPLAY 2

Provision

Provisions for Degree-Granting Authority in California by Private Postsecondary EducationInstitutions as of January 1986

Accreditation Approval). Authorization=

Authorizationfor Schools of

Theology

AgencyResponsiblefor Oversight

Type of Review

Components of theReview Process

Length of TimeRecognition Grantedby the Agency

1. A nationally recognizedaccrediting association;

2. Western Association ofofSchools and Colleges;

3. California Committeeof Bar Examiners

Institutional

Self study; peer evaluation;quality assessment throughthe use of standards develop-ed by member institutions

Ten years

California StateDepartment of Edu.cation. for the Super.inte odent of PublicInstruction

Institutional

Self study:peer evalu-ation; quality assess.ment through use ofspecified practicesand standards

Three years

CalArmo StateDepartment of Edu-cation, for the Super.intendent of PublicInstruction

Institutional

Compliance withspecified standardsin 12 areas, includ-ing curriculum. in-struction and faculty.The review processis conducted by athree-member visit-ing committee

California StateDepartment of Edu-cation, for the Super-intendent of PublicInstruction

Institutional

Verification of thetruthfulness andaccuracy of theinstitution's -fulldisclosure" statement.but no evaluation orquality assessment

Five years Three years

Number of 177 institutions are current- 70 institutions are 136 institutions areInstitutions ly accredited currently approved currently author-Involved ized

Two schools oftheology arecurrently authorized

1. The new approval process was implemented in 1984, and prior to July1,1986, tht Superintendent is expected to review allinstitutions under this provision.

2. The new authorization process was implemented in 1984, and prior to J uly 1,1987, the Superintendent is expected to reviewall institutions operating under this provision.

Source: Private Postsecondary Education Division, California State Department of Educa tion.

4 i 0

Postsecondary Education Division of the State De-partment of Education. The approval process in-cludes an assessment of the institution's facilities, fi-nancial resources, administrative capabilities, facul-ty and other educational expertise and resourcesnecessary for the degree programs. Education CodeSection 94310(b) states that the Superintendent ofPublic Instruction shall determine that "the curricu-lum is consistent in quality with curricula offered by

appropriate established accredited institutions," andthat "the course for which the degree is grantedachieves its professed or claimed academic objectivefor higher education, with verifiable evidence of aca-demic achievement, comparable to that required ofgraduates of other recognized" accredited institu-tions.

The 70 institutions currently approved by the Su-perintendent are listed in Display 3. Approximately

DISPLAY 3 Approved Institutions as of January 1986

Full institutional approvalAcademy of Art College, San Francisco2Academy of Arts and Humanities, SeasideThe American Academy of Family Studies, Scotts ValleyAmerican Armenian International College, La %%erneBay City College of Dental Medical Assistants. Sa n FranciscoCalifornia American University. EscondidoCalifornia Christian College, FresnoCalifornia Christian Institute, OrangeCalifornia Coast University, Santa AnaCalifornia Graduate Institute, West Los AngelesCalifornia Graduate School of Marital and ramily Therapy, San

RafaelCalifornia Institute for Clinical Social Work, BerkeleyCalifornia Institute of Transpersonal Psychology, Menlo ParkCalifornia Missionary Baptist Institute and Seminary, BellflowerCalifornia Pacific University, San DiegoCambridge Graduate School of Psychology, Los AngelesCenter for Psychological Studies. AlbanyCenter Graduate College. SaratogaCharles R. Drew Postgraduate Medical School. Los Angeles3Cleveland Chiropractic College, Los AngelesColumbia College. HollywoodEuropean University of America, San FranciscoGlendale University College of Law, GlendaleGraduate Center for Child Development and Psychotherapy,

BristolHuman Relations Center, Inc., Santa BarbaraInstitute for Advanced Study of Human Sexuality. San FranciscoInstitute for Creation Rasearch. El CajonInternational School of Theology, San BernardinoKoh-E-Nor University, Inc., Santa MonicaLaurence University, Santa BarbaraLincoln University, San FranciscoMelodyland School of Theology, AnaheimMusic and Arts Institute, San FranciscoThe National Hispanic University, OaklandNational Technical School, Los AngelesNational University, San Diego'New College for Advanced Christian Studies. Berkeley3New School of ArchitectureNewport University, Newport BeachOakland College of Dental Medical Assistants, OaklandPacific Coast Baptist Bible College

Pacific Graduate School of Psychology, Menlo Park2Pasadena College of Chiropractic, Pico RiveraThe Professional School of Psychological Studies. San DiegoThe Professional School of Psychology, San FranciscoRosebridge Institute, Walnut CreekRyokan College, Los AngelesThe Simon Greenleaf School of Law. Orange3Southern California Psychoanalytic Institute. Beverly HillsSysorex Institute. CupertinoUniversity Associates Graduate School of Human Resource

Development. San DiegoWalden University. Inc.. West CovinaWestern Graduate School of Psychology, Pa lo AltoWestern Institute for Social Research. BerkeleyWestern Sierra Law School, San DiegoWilliam Lyon University. San DiegoWright Institute Los Angeles, Los AngelesYeshiva University of Los Angeles, Los Angeles

Candidates for full institutional approvalAnaheim Christian College, AnaheimCalifornia Graduate School of Theology. GlendaleColumbia Pacific University, San RafaelHumphreys College, Stockton2International College, Los AngelesLinda Vista Baptist Bible College and Seminary. El CajonMagna Carta University School of Law, South San FranciscoPacific States University, Los AngelesSierra University: A University without Walls. Santa MonicaUniversity for Humanistic Studies, The, Del MarWilliam Carey International University, PasadenaWorld University of America, Ojai

1. Accredited by the Western Association of Schools and Colleges(WASC).

2. Candidate for w.k.sc accreditation.

3. Eligible for wasc application for candidacy, as determined byWASC.

Source: California Postsecondary Education Coinmission staffanalysis.

ii5

80 percent of them olTer graduate degrees, and ap-proximately 60 percent offer doctoral degrees. Abouthalf of them are single-purpose institutions, offeringdegrees only in one area, such as theater, theology,or transpersonal psychology. An additional quarteroffer multiple degree levels in a single general areaof study, and the remaining quarter offer several de-grees in a variety of subject areas.

Accreditation of law schools

Law schools in California may be categorized intothree types: those accredited by the American BarAssociation (16 institutions): those accredited solelyby the Committee of Bar Examiners for the State ofCalifornia (18): and nonaccredited law schools (16).Law schools that are either provisionally or fullyaccredited by the American Bar Association are au-tomatically accepted as fully accredited by the Com-mittee of Bar Examiners. Consequently, 34 of theschools are technically accredited by that Commit-

tee. These 34 are listed in Display 4 below, whichidentifies those with additional accreditation fromeither the American Bar Association ABA) or theWestern Association of Schools and Colleges (WASC).Only eight State-accredited law schools do not havea second institutional accreditation from either theABA or WASC, and one of them -- San Joaquin Collegeof Law -- has recently achieved eligibility statuswith the Accrediting Commission for Senior Collegesand Universities of WASC.

This report concerns the eight law schools that areaccredited solely by the Committee of Bar Exami-ners. To achieve this accreditation, a law schoolmust "establish that its paramount objective is toprovide a sound legal education and that it is ac-complishing that objective." Institutions are expect-ed to comply with eleven standards, including provi-sions for an adequate library and physical plant, asound educational program and admission policy,and a competent administrative head and faculty.The standards also include the statement that "pre-

DISPLAY 4 Law Schools Accredited by the California Committee of Bar Examiners as of January 1986

California Western School of Law, San Diego 3Empire College School of Law. Santa RosalGlendale College of La w, GlandalelGolden Gate University School of Law, San Francisco3Hurnphreys College of Law, Stockton!John F. Kennedy University School of Law!Lincoln Law School of Sacramento,SacrarnentolLoyola Law School. Los Angeles"Monterey College ()Maw, Monterey:National University School of La% San Diego2New College of California School of Law, San Francisco2Northrop University School of Law. Inglewood2Pepperdine University School of Law. Ma libu3San Fernando Valley College of Law. Sepulveda2University of San Francisco School of Law.San Francisco,'San Francisco Law School. San FranciscolSan Joaquin College of Law, Fresno',Santa Barbara College of Law, Santa BarbaralSouthwestern University School of Law, Los Angeles3Stanford Law School, Stanford3University of California Hastings College of Law. San Francisco3University of California School of Law, Berkeley3University of California School of Law, Davis3

University of California School of Law. Los Angeles3University of La Verne College of Law, La Verne, 2University of San Diego School of Law. San Diego3University of Santa Clara School of Law, Santa Clara3University of Southern California Law Center, Los Angeles3University of the Pacific McGeorge School of Law. Sacramento3Ventura College of Law, Ventura'

niversity of West Los Angeles School of Law. Los Angeles"!Western State University College of Law of Orange County.

Fullerton2Western State University Cullege of Law of San Diego, San Diego2Whittier College School of Law, Los Angeles 3

I. Accredited solely by the Comntittee of Bar Examiners.

2. Accredited by both the Committee of Bar Examiners and theWestern Association of Schools and Colleges.

3. Accredited by both the Committee of Bar Examiners and theAmerican Bar Association

Source: California Postsecondary Education Commission staffanaly4is.

6 1 2

ferably, the school shall not be operated as a com-mercial enterprise or for private profit. In no eventshall a school permit profit considerations to dictatethe quality of education the school provides. . .."(Standard A, Section 182).

Origins of Senate Bill 362

The basic issue raised by SB 362 that called for thisreport is the appropriateness of current State policyto determine institutional eligibility for participa-tion in State-funded student assistance programs byadopting existing federal criteria for institutionaleligibility. Any inequities in the federal criteriahave therefore become inequities in the State cri-teria, and since federal policies limit participationprimarily to accredited institutions, State funds arealso limited in a similar manner.

This policy issue was discussed by the Student Fi-nancial Aid Policy Study Group in its report to theCalifornia Legislature in 1980. From 1975 to 1980,students attending nonaccredited, State-approvedinstitutions were eligible for Cal Grant awards, al-though the institutions, and therefore their stu-dents, were ineligible for participation in the feder-al student assistance programs. The Study Groupconcluded that "where institutions participate inCal Grants but do not participate in the full range offederal programs, State funds supplant availablefederal aid; students receive limited financial ser-vices and limited financial aid packages" (p. 83).Accordingly, the Study Group recommended chang-ing State eligibility criteria so that only institutionsthat participate in the federal Basic Grant, Sup-plemental Grant, and at least one of the "self-help"programs (College Work/Study or National DirectStudent Loan) would be eligible to participate in theState's program.

In response to the suggestion that the Statecontinue to allow participation by State-approvedinstitutions, the Study Group rejected it, stating:

(1) the new approval process has not been inplace long enough to br yoven an acceptablealternative to accreditatik. (2) administra-tion of the approval process is dependent upon

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funding available to admi -lister veteran's cer-tification, which may not 'oe a steady source ofrevenue; and (3) our concerns for increased stu-dent service, funding availability, and max-imum utilization of federal funds outweigh theproblems associated with accreditation" ( p.83).

The Postsecondary Education Commission also con-sidered this issue in its 1984 report, Public Policy,Accreditation, and State Approval in California. TheCommission concluded that the State policy ofrelying on accreditation to determine institutionaleligibility for participation in State-funded studentassistance programs has resulted in the anomalythat some institutions that meet the highest existingState standards for licensure to award degrees can-not benefit from these programs because they havenot applied for or have been denied recognition bynongovernmental accrediting associations.

The Commission suggested that the State shouldcontinue to utilize accreditation as one indicator ofinstitutional quality, but not include accreditationas a mandatory condition for participation in State-funded aid programs. The Commission thereforerecommended that the Student Aid Commission ex-amine "the State criteria utilized to determine insti-tutional eligibility for participation in State-fundedundergraduate and graduate student assistance pro-grams," with the examination to "consider the im-pact of modifying the criteria ... so that institutionsqualitatively reviewed and approved by non-governmental accrediting associations or having in-stitutional-wide programmatic approval from theState oversight agency . . . are eligible for parti-cipation in the State programs if they meet all otherState requirements" (p.55).

SB 362 implemented this Commission recommenda-tion, while also (1) directing the Commission toidentify alternative criteria to permit law schooisaccredited by the Committee of Bar Examiners toparticipate in the Cal Grant program, and (2)expressing legislative intent that the Committee ofBar Examiners seek approval from the federal Secre-tary of Education as a nationally recognized ac-crediting agency.

7

Alternative Eligibility Criteria

THE following analysis of alternative eligibilitycriteria for i:aAitutional participation in the CalGrant program consists of two parts. The first con-siders alternative eligibility criteria for State-ac-credited law schools, while the second discusses al-ternative criteria for State-approved, degree-grant-ing colleges and universities.

Alternative eligibility criteriafor State-accredited law schools

As noted on page 6 above, only eight of the 34 lawschools accredited by California's Committee of BarExaminers do not also hold accreditation by eitherthe Western Association of Schools and Colleges(WAX) or the American Bar Association. The Com-mittee of Bar Examiners advises that approximate-ly 30 percent of the students admitted each year tothese eight schools are admitted prior to earning abachelor's degree, and that none of the eight hasany law program other than a part-time eveningoffering.

Students attending these eight schools are in-eligible for the State's Graduate Fellowships or CalGrants for two reasons:

1. Students receiving a Graduate Fellowship mustbe engaged in full-time graduate study. Each of theeight law schools offers only a part-time program.

2. Cal Grant awards may only be used for under-graduate study. Law school programs are consider-ed graduate or professional programs, and all stu-dents enrolled in these programs share the samecurriculum and status, regardless of whether or notthey have earned their bachelor's degree prior to ad-mission.*

* State law specifically limits institutiona 1 eligibility for theGraduate Fellowship program to institutions accredited by theWestern Association of Schools and Colleges ( wAsc ). theCalifornia Committee of Bar Examiners, the American Osteo-pathic Association, and the National Architec:ural AcQreditingBoard. In practice, the Student Aid Commission has also includ-ed institutions which are candidates for wAsc accreditation.

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These two reasons exist independent of the institu-tion's accredited status, and are a reflection of Staterather than federal policy. Moreover, student ineli-gibility is not a result of the institutional eligibilitycriteria utilized for the Cal Grant program, as sug-gested in Senate Bill 362. Therefore, the Commis-sion proposes no alternative criteria for theseschools.

(SB 362 directed the Committee of Bar Examiners"to report to the Legislature no later than June 1,1986, regarding its efforts to attain approval by thefederal Secretary of Education as a nationally rec-ognized accrediting agency or association," and theCommission offers no opinion about the relevance ofthis legislative mandate in terms of the Cal Grantprogram.)

Alternative eligibility criteriafor State-approved institutions

The Commission and its technical advisory commit-tee have considered a variety of alternatives regard-ing institutional criteria that might facilitate theparticipation of nonaccredited, State-approved insti-tutions in the Cal Grant programs. In the followingpages, the Commission discusses Five alternatives inthe context of maintaining the State's policy of uti-lizing State funds to supplement federal student fi-nancial aid funds and adhering to the requirement ofSenate Bill 362, that the alternatives "recognize theintent of the Legislature that students not rely ex-clusively upon Cal Grant awards for financial assis-tance for educational purposes . . . ." The first threeof these alternatives would require change in exist-ing statute, while the latter two would not.

1. Modify the institutional eligibility criteria ofthe Education Code so that State-approved in-stitutions are eligible to participate in Cal Grantprograms without the prerequisite of partici-pating in federal student financial aid pro-grams.

This expansion of institutional eligibility would not

9

conform to California's stated purposes for its stu-dent financial aid programs because it is not con-sistent with the State's policies of maximizing therange and diversity of resources available to stu-dents, enhancing the effectiveness of State funds,and ensuring that State financial aid monies com-plement and not supplant federal student financialaid funds. Moreover, this alternative does not com-ply with the Legislature's intent, as stated in SB362, "that students not rely exclusively upon CalGrant awards for financial assistance for educa-tional purposes."

Creating the opportunity for students to apply forand receive Cal Grants to assist in meeting the costsof attending a State-approved institution may ex-pand students' access to and choice among a greaternumber and variety of institutions, but becausethese institutions do not participate in the federalfinancial aid programs, they generally have severelylimited financial aid resources. Encouraging accessand choice through the expanded use of Cal Grantsat these nonaccredited institutions could potentiallyput their students in the position of having lessrather than more access to total student financialaid resources.

In addition, permitting institutions that cannot par-ticipate in federal student financial aid programs torely exclusively, or nearly exclusively, on CalGrants could create increased demand on Cal Grantresources that are already insufficient to meet cur-rent demands, unless the number of Cal Grantawards and corresponding appropriations were in-creased accordingly.

Finally, permitting these institutions to participatein the Cal Grant programs without participating infederal programs would enable these institutions togain the benefits of State funds without having toexpend the institutional resources necessary to par-ticipate in the federal programs.

2. Modify the institutional eligibility criteria sothat State-approved institutions are eligible toparticipate in Cal Grant programs when theyhave been determined by the Western Associa-tion of Schools and Colleges (WAsc) to be eligi-ble to apply for candidacy for accreditation.

In accordance with WASC procedures, an institutioninterested in seeking either candidacy or accredita-tion status must file a Report of Eligibility demon-strating the extent to which the institution meets

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each of WASC's 14 eligibility criteria. After receivingthis report, WASC establishes a Committee on Eligi-bility to review the report and visit the institution todetermine "if the institution demonstrates substan-tial promise of meeting .Commission standards forcandidacy" (Accrediting Commission for Senior Col-leges and Universities, Western Association ofSchools and Colleges, Handbook of Accreditation, p.5). If the Committee concludes that the institutiondoes not meet the eligibility criteria, the institutionhas the opportunity to appeal the decision to the ac-crediting commission.

Three State-approved institutions have recentlygained this WASC eligibility status -- Charles R.Drew Postgraduate Medical School (Los Angeles),New College for Advanced Christian Studies (Berke-ley), and The Simon Greenleaf School of Law(Orange). The San Joaquin College of Law in Fres-no, accredited by the Committee of Bar Examiners,also has eligibility status.

Alternative 2 would maintain the State's current fi-nancial aid policies and is consistent with legislativeintent as expressed in SB 362. Because institutionsthat have been determined eligible by WASC to applyfor candidacy for accreditation have, according to theWASC Handbook, a reasonable expectation of obtain-ing accreditation, it may be feasible to consider de-veloping a process for them to become eligible tobegin participation in the Cal Grant program priorto participating in the federal student financial aidprograms. Continued participation, however, wouldbe dependent upon (1) their achieving first candida-cy and then full accreditation by WASC, (2) participa-tion in two of the three federal campus-based aid pro-grams, and (3) student participation in the PellGrant Program. Additionally, a policy would beneeded for resolving the issue of a student receivinga Cal Grant but being enrolled in an institution thatdoes not progress in a timely fashion to candidacyand full accreditation.

An advantage of this approach is that it would pro-vide .both a financial incentive and financial assis-tance to institutions seeking the benefits of nongov-ernmental accreditation. A disadvantage of this ap-proach is that it would increase State reliance uponthe policies and practices of a nongovernmental ag-ency in determining institutional eligibility to re-ceive public funds. In addition, many approved insti-tutions do not intend to apply for accreditation, andthis approach might force them to do so.

3. Modify the institutional eligibility criteria sothat State-approved institutions that provide aspecified level of institutional financial aid tostudents would be eligible to participate in theCal Grant programs.

The institutional matching program might havethese requirements:

a. The student financial aid resources provided bythe institution might be in proportion to thepresent ratio of federal campus-based funds allo-cated to California to Cal Grant funds allocatedby the State (that is, three-to-one).

b. The institutior. might be required to provide thestudent financial aid through several types ofprograms such as grants, scholarships, employ-ment, loans, and tuition and fee waivers.

c. The Student Aid Commission would be requiredto develop the detailed requirements for thematching program. In addition, it would be re-quired to establish a management system, in-cluding staffing, for approving, verifying, andmonitoring the institutional student financialaid program.

This alternative is consistent witY State's goalsof providing access to and choice ah. g institutionsfor students with demonstrated financial need, andmaximizing the range of resources and scope of fi-nancial aid services provided to students. It is alsoconsistent with legislative intent expressed in SB362, that students not rely exclusively upon CalGrant awards for financial assistance for educa-tional purposes. This alternative would correct theanomaly in current law that institutions which meetthe highest existing State standards for licensurecannot benefit from the Cal Grant program becausethey are not members of a nongovernmental accredi-ting association. However, this proposal is contraryto existing State policy that State funds supplementrather than supplant federal funds. In addition, amajor disadvantage would be the added cost to theStudent Aid Commission to monitor the financial as-sistance operations of these institutions and to ad-minister the Cal Grants received by students choos-ing to ehroll in them. While the number of theseawards would probably be limited, the monitoringand administrative costs per grant would be rela-tively high in comparison with the current costs forthe grant program.

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4. The California State Department of Edu-cation could initiate an effort to gain recogni-tion from the U.S. Department of Education forthe State's approval process as a viable proce-dure to identify educational institutions eligibleto participate in the federal student financialassistance programs.

California has historically maintained a separateyet complementary relationship between the twoprocesses of State licensure of institutions and non-governmental accreditation of institutions. State li-censure, such as aproval and authorization in Cali-fornia, is a governmental regulatory activity bywhich the State grants institutions the authority tooperate and award degrees and diplomas, and bywhich it determines that institutions have met mini-mum acceptable standards of educational qualityand consumer protection. Accreditation adds theprocess of ongoing peer and professional review of in-stitutional operations that an institution may utilizeas a means of improving its effectiveness and qualityby assessing its quality against standards mutuallyestablished by member institutions. During the pastdecade, California has enacted several statutorychanges designed to strengthen the licensure processfor private degree-granting institutions. In 1984,legislation was enacted directing the approval pro-cess to provide assurance that institutions maintaincurriculum and academic standards which are con-sistent in quality with curricula offered by estab-lished, accredited institutions.

Given these legislative efforts to strengthen the li-censure process in California so that approved insti-tutions meet higher standards, the State Depart-ment of Education could initiate efforts to informfederal officials about the process, and seek their re-cognition of State-approved institutions as eligible toparticipate in the federal student assistance pro-grams. This recognition would place the State-ap-proved institutions on an equal level with accreditedinstitutions in gaining access to both federal andState financial assistance, and would not require achange in California policy or statute.

5. State-approved institutions can work withaccredited institutions to become eligiblethrough the "three letter" route.

1

Under federal regulations, nonaccredited institu-tions may be declared eligible to participate in thefederally funded student assistance programs by theU.S. Department of Education, based upon its verifi-cation of the acceptance of at least three studentsand their academic credits by each of three accred-ited institutions.

In the United States, each postsecondary institutionis responsible for determining its own policies andpractices with regard to the transfer of academiccredit, but WASC-accredited institutions in Califor-nia have adopted the guidelines prescribed in the"Joint Statement on Transfer and Award of Aca-demic Credit," as adopted in 1978 by the AmericanCouncil on Education, the American Association ofCollegiate Registrars and Admissions Officers, andthe Council on Postsecondary Accreditation. This

12

statement does not preclude accredited institutionsfrom accepting the credits of students transferringfrom nonaccredite.:1 institutions, but it urges accred-ited institutions to "take special steps to validatecredits previously earned" because nonaccredited in-stitutions "cannot provide a reliable, third-party as-surance that they meet or exceed minimum stan-dards" (Accrediting Commission for Senior Collegesand Universities, Western Association of Schoolsand Colleges, Handbook of Accreditation, p. 141).

Implementing this fifth alternative would requirenonaccredited institutions to take the leadership indevolopiog cooperative relationships with accreditedinstitutions, but it would provide a mechanism forthem to become eligible for participation in federalstudent financial aid programs as well as the CalGrant program.

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3 Conclusions and Recommendation

IN considering the five alternatives described inPart Two, the Commission offers the following gen-eral conclusions and recommendation:

1. Many nonaccredited approved institutions ob-serve academic calendars that involve starting datesscattered throughout the year, rather than at onlytwo or three dates. The application deadline for theCal Grant program is in February of each year forstudents beginning or continuing study the follow-ing fall. This application deadline is appropriate forstudents enrolling in many accredited institutions,but it would not be appropriate for many of the po-tentially eligible students seeking to enroll in ap-proved institutions. Consequently, if the decision ismade to change the institutional eligibility criteriato open the Cal Grant program to approved institu-tions, some revision would also be needed in the ap-plication process operated by the Student Aid Com-mission to facilitate the participation by studentsseeking to enroll in these institutions.

2. The current level of competition for the State'sCal Grant program is intense, with at least three eli-gible applicants turned away for each grantawarded. In addition, the number of applications forCal Grants has increased 10 percent this year overlast year. On the federal level, representatives ofthe California Student Aid Commission estimatethat funding reductions required by the Gramm-Rudman balanced-budget amendment and theshortfall in the Pell Grant Program mean that Cali-fornia will likely lose $30 million in federal financialaid in the 1986-87 academic year. Given these factsconcerning both State and federally funded studentassistance programs, any decision to expand thenumber of institutions eligible to participate in theCal Grant program should be accompanied by anincrease in the number of grants awarded and addi-tional funding to support the new grants.

3. As discussed above on page 7, in 1980, when theStudent Financial Aid Policy Study Group recom-mended against including approved institutions

within the group of those eligible to participate inthe Cal Grant program, it offered three reasons: (1)the new approval process had not been in place longenough to prove an acceptable alternative to accredi-tation: (2) funding available to administer veteran'scertification may not be a steady source of revenue:and (3) increased student service, funding availabil-ity, and maximum utilization of federal funds out-weigh the problems associated with using accredita-tion as a criterion to determine institutional eligibil-ity. At least the first two of these reasons still exist.

In 1984, the State approval process was revisedthrough legislation from a programmatic-reviewprocess to an institutional-review process, and theSuperintendent of Public Instruction was given athree-year period in which to review all existingand new institutions seeking approval status. Itis anticipated that all approved institutions cur-rently operating in California will undergo thisrevised process prior toJune 30, 1987.

Funding for the operations of the Private Postsec-ondary Education Division of the State Depart-ment of Education, which has the responsibilityfor implementing the approval process, is provid-ed from two sources: (1) the federal government,for the administration of veteran's certification,and (2) school licensure fees. The Department re-ceives no State General Fund support for monitor-ing and licensing private postsecondary institu-tions. Uncertainties about the level of federalfunding, which result from the Gramm-Rudmanlegislation, raise questions about the stability ofthis funding source.

If a decision is made to change the institutional eligi-bility criteria to open the Cal Grant program to ap-proved institutions, consideration should also begiven to State General Fund support for the opera-tion of the Division, in order to assure an adequateresource base for its operations.

4. Whether the State-approval process is sufficient-ly rigorous to permit the licensure of only qualityinstitutions is a question that should be answered

18 1 3

before a decision is made to implement one of the al-ternatives described above. This issue is beyond thescope of this study. In the Commission's 1984 report,Public Policy. Accreditation. and State Approval inCalifornia, the Commission concluded that "theState should maintain a sufficiently thorough quali-ty review and approval process for all independentand private institutions so that the public in generalas well as other State agencies can rely upon thisprocess in identifying institutions with worthwhileeducational programs ..." (p. 50).

The Commission therefore recommended efforts tostrengthen the approval process, specifically callingfor the process to "continue to be programmatic ap-proval, but it should be revised to stipulate that aninstitution cannot advertise itself as having Stateapproval status until all of its degree programs havebeen qualitatively reviewed and approved by theState's oversight agency" (Recommendation 3, page51).

Despite the Commission's recommendation , legisla-tion was enacted following publication of the Com-mission's report to change the approval process fromprogrammatic to institutional approval. Since thenew process has not yet been either fully implement-ed or reviewed for its thoroughness, it is prematureto judge whether the conclusions and recommenda-tions made by the Commission in 1984 should be re-vised. An opportunity should be provided for thenew approval process to be implemented fully andthen reviewed for its thoroughness. Existing statutedirects the Commission to review the State's proce-dures for licensing all private postsecondary institu-tions prior to September 1, 1989, and this issue willbe considered as part of that study.

5. The absence of data regarding the numbers ofundergraduate students enrolled in approved insti-tutions has placed limitations on the ability toanalyze the potential costs associated with changingthe institutional eligibility criteria so that approvedinstitutions could participate in the Cal Grant pro-gram. In an attempt to gather these data, Commis-sion staff surveyed all approved institutions. Based

1 4

on a 50 percent response rate to this survey, 12 ap-proved institutions that are currently ineligible toparticipate in the Cal Grant program enrolled a totalof 454 undergraduates in programs that satisfy thecourse length requirements for State student finan-cial assistance. Commission staff therefore made theassumption that a total of approximately 900 under-graduate students are enrolled in approved institu-tions in California. If all of these students appliedfor a Cal Grant, and were identified as eligible at thesame rate as the 1985 Cal Grant A applicants -- ofwhom 73 percent were eligible for a grant -- 657 neweligible applicants will be added. If the new eligibleapplicants received awards at the same rate as eli-gible 1985 Cal Grant A applicants -- 26 percent ofwhom received awards -- 170 would receive CalGrants. The cost of these grants, based upon an av-erage award of $3,100 (which represents the averagetuition and fees at the 12 institutions that respondedto the Commission's survey) would total $527,000 forone year.

This cost estimate should be used with considerablecaution, as it is based upon assumptions regardingboth the total student applicant pool and their poten-tial eligibility for Cal Grant awards. Moreover, ifthe approved institutions were eligible to participatein the Cal Grant program, it is not known how manyadditional students would chose to enroll in them.

Recommendation

Based upon the analysis and conclusions pre-sented above, the Commission recommends nostatutory changes at the present time to alterthe institutional eligibility criteria for participa-tion in the Cal Grant program. Alternative 5provides an existing route for nonaccredited in-stitutions to participate in the program, andthat alternative, as well as Alternative 4, shouldbe fully explored before consideration is givento the implementation of any of the other alter-natives.

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Appendix A Senate Bill 362 (1985)

Senate Bill No. 362

CHAPTER 772

An aci relating to education.

[Approved by Covernor September 18, 1985. Filed withSecretary of State September 19, 19851

LEGISLATIVE COUNSEL'S DIGESTSB 362, Carpenter. Cal Grant awards.Existing law authorizes the utilizatthn of Cal Grant awards for

tuition and student fees at any California postsecondary educationalinstitution or program that participates in 2 of the 3 federalcampus-based student aid programs and whose students participatein the Pell Grant Program.

This bill would direct the California Postsecondary Commission, incooperation with the Student Aid Commission, to report to theLegislature no later than July 1, 1986, regarding alternative criteriathat wouldadditionally permit the utilization of Cal Grant awards atspecified private postsecondary institutions and accredited lawschools, as specified.

This bill would also require the Committee of Bar Examiners of theState Bar of California to report to the Legislature no later than June1, 1986, regarding its efforts to attain approval by the federalSecretary of Education as a nationally recognized accrediting agencyor association.

The people of the State of California do enact as follows:

SECTION 1. (a) The California Postsecondary EducationCommission, in cooperation with the Student Aid Commission, shallconduct an assessment of eligibility criteria for institutionalparticipation in the Cal Grant awards program described underArticle 3 (commencing with Section 69530) of Chapter 2 of Part 42of the Education Code. The assessment shall include, but need notbe limited to, an identification of alternatives to the eligibilitycriteria set forth in Section 69536 of the Education Code that wouldpermit participation by California postsecondary educationalinstitutions or programs that have full institutional approval undersubdivision (b) of Section 94310 of the Education Code, or that arelaw schools accredited by the Committee of Bar Examiners of theState Bar of California, and an analysis of the potential costs aiv-1 otherdemands that could result to the Cal Grant awards program from theimplementation of the alternative eligibility criteria. The assessmentshall recognize the intent of the Legislature that students not relyexclusively upon Cal Grant awards for financial assistance foreducational purposes, and shall be submitted by the California

20 15

Ch. 772 2

Postsecondary Education Commission to the Legislature no laterthan July 1, 1986.

(b) It is the intent of the Legislature that the Committee of BarExaminers of the State Bar of California seek approval by the federalSecretary of Education as a nationally recognized accrediting agencyor association. On or before June 1, 1986, the Committee of BarExaminers shall report to the Legislature concerning its progress inthis respect.

0

2116

Appendix B Survey Instrument

CALIFORNIA POSTSECONDARY EDUCATION COMMISSIONStudy of Alternative Eligibility Criteria for the Participation

of State Approved Institutions in Cal Grant Programs

Institution Name:

Institution Address:

Your Name:

Your Title:

Telephone number: (

I. TOTAL ENROLLMENT

1. What was your full-time and half-time student enrollment for September 1985?

Undergraduate (B.A. or equivalent or less ):

Graduate (M.A., M.S, Ph.D., J.D. or equivalent):

II. UNDERGRADUATE ENROLLMENT

1. How many of your undergraduate studentshad established permanent residency in theState of California as of September 1985?

Full-time(12 or more units)

Half-time(6 to 11.9 units)

Full-time Half-time

Full-time Half-time

2. Do you provide any institutional student financial aid (that is,non-federal or non-state) to your undergraduate students? Yes: 0 No: 0If "yes," please describe your aid briefly below or on an attached sheet. Indicate the typeof institutional aid (such as fee waivers, discounts, loans, grants, or jobs), amounts offunds available and awarded, and number of undergraduate students receiving it.

'over. please

2217

3. Last September, how many of your undergraduatestudents were enrolled full-time or part-time in aprogram of study at least two years long?

Full-time Part-time(12 or more units) 16 to 11.9 units)

(As you probably know, Cal Grant A funds are available to students who are enrolledfull or part-time hi such programs. Full-time students must take at least 12 units persemester or quarter and part-time students must take at least six.)

4. Last September, how many of your undergraduatestudents were enrolled full-time or part-time in aprogram at least nine months long? (This includesany in two year programs.)

Full-time Part-time(Cal Grant B funds are available to students in programs of at least nine monthsduration.)

5. Last September, how many of your undergraduate stu-dents were enrolled full-time or part-time in a vocationalprogram of study from four months to two years long?

Full-time Part-time(Cal Grant C funds are available to students in vocational programs that are from fourmonths to two years in length.)

6. Please indicate your tuition costs and other fees, as appropriate:

Tuition: Quarter: $ Semester: $ Year: $

Other Fees: (please explain):

7. Do you admit students throughout the year on an "open"or "rolling" basis, rather than only one to three times a year? Yes: 0 No: 0

8. Of those students admitted annually,approximately what percent start in September? percent

If you have questions, please call Carol McKenzie at (916) 322-8013.

Otherwise, please return this completed questionnaire in the pre-addressed,stamped envelope no later than March 19.

Thank you very much.

2 3

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References

California Postsecondary Education Commission.Public Policy, Accereditation, and State Approval; inCalifornia: State Reliance on iVon.Governmental Ac-crediting Agencies and on State Recognition of Post-secondary Institutions to Serve the Public Interest.Commission Report 84-28. Sacramento: The Com-mission, July 1984.

Student Financial Aid Policy Study Group. A Re

port to the California Legislature from the StudentFinancial Aid Policy Study Group. Sacramento:California Postsecondary Education Commission,1980.

Western Association of Schools and Colleges, Ac-crediting Commission for Senior Colleges and Uni-versities. Handbook of Accreditation. Oakland, Cali-fornia: The Commission, 1981.

2 41 9

CALIFORNIA POSTSECONDARY EDUCATION COMMISSION

THE California Postsecondary Education Commis-sion is a citizen board established in 1974 by the Leg-islature and Governor to coordinate the efforts ofCalifornia's colleges and universities and to provideindependent, non-partisan policy analysis and rec-ommendations to the Governor and Legislature.

Members of the Commission

The Commission consists of 15 members. Nine rep-resent the general public, with three each appointedfor six-year terms by the Governor, the Senate RulesCommittee, and the Speaker of the Assembly. Theother six represent the major segments of postsec-ondary education in California.

As of 1986, the Commissioners representing thegeneral public are:

Seth P. Brunner, Sacramento, ChairpersonC. Thomas Dean, Long BeachSeymour M. Farber, M.D., Los Altos HillsPatricia Gandara, SacramentoRalph J. Kaplan, Beverly HillsRoger C. Pettitt, Los AngelesSharon N. Skog, Palo AltoThomas E. Stang, Los Angeles, Vice ChairpersonStephen P. Teale, M.D., Modesto

Representatives of the segments are:

Yori Wada, San Francisco; representing the Regentsof the University of California

Claudia H. Hampton, Los Angeles; representing theTrustees of the California State University

Beverly Benedict Thomas, Los Angeles; represent-ing the Board of Governors of the California Com-munity Colleges

Jean M. Leonard, San Mateo; representing Cali-fornia's independent colleges and universities

Willa Dean Lyon, Newport Beach; representing theChairman of the Council for Private PostsecondaryEducational Institutions

Angie Papadakis, Rancho Palos Verdes; represent-ing the California State Board of Education

Functions of the Commission

The Commission is charged by the Legislature andGovernor to "assure the effective utilization of publicpostsecondary education resources, thereby elimi-nating waste and unnecessary duplication, and topromote diversity, innovation, and responsiveness tostudent and societal needs."

To this end, the Commission conducts independentreviews of matters affecting the 2,600 institutions ofpostsecondary education in California, includingCommunity Colleges, four-year colleges, universi-ties, and professional and occupational schools.

As an advisory planning and coordinating body, theCommission does not administer or govern any insti-tutions, nor does it approve, authorize, or accreditany of them. Instead, it cooperates with other stateagencies and non-governmental groups that performthese functions, while operating as an independentboard with its own staff and its own specific duties ofevaluation, coordination, and planning.

Operation of the Commission

The Commission holds regular meetings throughoutthe year at which it debates and takes action on staffstudies and takes positions on proposed legislationaffecting education beyond the high school in Cali-fornia. By law, the Commission's meetings are opento the public. Requests to address the Commissionmay be made by writing the Commission in advanceor by submitting a request prior to the start of ameeting.

The Commission's day-to-day work is carried out byits staff in Sacramento, under the guidance of its di-rector, who is appointed by the Commission. OnAugust 1, 1986, William H. Pickens assumed the di-rectorship from Patrick M. Callan.

The Commission issues some 30 to 40 reports eachyear on major issues confronting California postsec-ondary education. Recent reports are listed on theback cover.

Further information about the Commission, itsmeetings, its staff, and its publications may be ob-tained from the Commission offices at 1020 TwelfthStreet, Third Floor, Sacramento, CA 98514; tele-phone (916) 445-7933.

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Eligibility for Institutional Participation in the Cal Grant ProgramCalifornia Postsecondary Education Commission Report 86-21

ONE of a series of reports published by the Commis-sion as part of its planning and coordinating respon-sibilities. Additional copies may be obtained withoutcharge from the Publication:, Office, California Post-secondary Education Commission, Third Floor, 1020Twelfth Street, Sacramento, California 98514: tele-phone (916) 445-7933.

Other recent reports of the Commission include:

86-4 Expanding Educational Equity in California'sSchools and Colleges: Recommendations of the Inter-segmental Policy Task Force on Assembly Concur-ren".. Resolution 83 (March 1986)

86-5 Background for Expanding Educational Equi-ty: A Technical Supplement to the Report of the In-tersegmental Policy Task Force on Assembly Con-current Resolution 83, Expanding Educational Equi-ty in California's Schools and Colleges (March 1986)

86-6 Director's Report, March 1986: Overview ofthe 1986-87 Governor's Budget for PostsecondaryEducation in California (March 1986)

86-7 Standardized Tests Used for Higher EducationAdmission and Placement in California: A ReportPublished in Accordance with Senate Bill 1758(Chapter 1505, Statutes of 1984) (March 1986)

86-8 Feasibility Plan for a Comprehensive StudentInformation Study: A Report to the Legislature andGovernor in Response to Assembly Bill 880 (1984)(March 1986)

86-9 The Need for Statewide Long-Range CapitalOutlay Planning in California: An Issue Paper Pre-pared for the California Postsecondary EducationCommission by Frank M. Bowen. (March 1986)

86-10 High School-College Relations in Californiaand The Articulation Council: A Report to theCalifornia Postsecondary Education Commission byWilliam Chance (April 1986)

86-11 Update of Community College Transfer Stu-dent Statistics, University of California and the Cali-fornia State University, Fall 1985 (April 1980

86-12 Time and Territory: Phase H. A Report tothe Legislature in Response to Supplemental Lan-guage in the 1985-86 Budget Act. (April 1986)

86-13 Progress in Facilitating the Transfer of Com-munity College EOPS Students: A Report to the Leg-islature and Governor in Response to Assembly Bill1114 (Chapter 1586, Statutes of 1985) (April 1986)

86-14 A Permanent Site for Los Angeles M(ssionCollege: A Report to the Legislature and Governor inResponse to a Request for Capital Funds from the LosAngeles Community College District. (April 1986)

86-15 Student Financial Aid in California: TheFirst of Two Background Papers on Student Fir an-cial Aid Issues and Options Prepared for the California Postsecondary Education Commission, May 1916(May 1986)

86-16 Purposes and Effects of Student FinaAid: The Second of Two Background Papers on S .

dent Financial Aids Issues and Options Prepared tt. rthe California Postsecondary Education Commission.May 1986 (May 1986)

86-17 Director's Report, May 1986: EnrollmentTrends in California Higher Education, 1980-1985(May 1986)

86-18 Director's Report, June 1986: The MasterPlan After Twenty-Five Years. (June 1986)

86-19 Analysis of the State University's Criteriafor Approving Permanent Upper-Division and Grad-uate Off-Campus Centers: A Report to the Governorand Legislature in Response to Senate Bills 785.1060, and 1103 (1985) (June 1986)

86-20 Annual Report on Program Review Activities1984-85: The Tenth in a Series of Reports to the Leg-islature and Governor on Program Review by Com-mission Staff and California's Public Colleges andUniversities (June 1986)

86-22 Transforming Data into Information: Im-proving Student Performance Reporting: A Staff Re-port to the California Postsecondary Education Com-mission (June 1986)

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