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Report of a Follow-Up Compliance Review of
Taylor Business Institute  New York, NY

 

August 7-8, 2006

          On August 7-8, 2006, a review team conducted a two-day follow-up visit to Taylor Business Institute, 23 West 17th Street, Manhattan, New York, to assess its compliance with the recommendations made by the New York State Education Department following visits in February 2004 and March 2005, which also assessed the Institute’s compliance with laws, rules, and regulations governing degree-granting institutions in New York State.  Following the Department’s review visit of March 2005, the Deputy Commissioner for Higher Education and for the Professions determined that the programs at Taylor Business Institute, and the Institute as a whole, had not come into substantial compliance with laws, rules, and regulations governing degree-granting institutions in New York.  In a letter dated October 4, 2005, the Deputy Commissioner directed Taylor to cease the conduct of its registered programs at the close of the fall 2005 term.  Areas of significant deficiency and non-compliance were consolidated and presented under the following six areas:

Area 1

Inadequate equivalency of course work in rigor, level and content with courses offered by other degree-granting institutions, including four-year institutions, to which Taylor students might seek to transfer [§§50.1(o); 52.1(b)(3); 52.2(c)(1), (3) and (5); 52.2(e)(4)].

Area 2

Unsatisfactory provision for, and assessment of, the effectiveness of, interventions and services to support student persistence and attainment [§§52.2(b)(2) and (3); 52.2 (a)(2) and (3); 52.2(b)(2) and (3); 52.2(d)(2); 52.2(e)(1) and (5)].

Area 3

Absence of sustained and effective academic leadership by appropriately trained college-experienced professionals in the areas of academic programs and related educational services, including tutoring [§§52.2 (a)(2) and (3); 52.2(b)(1), (2), (6) and (7); 52.2(e)(1), (2) and (3)].

Area 4

Insufficient conduct by the faculty of academic governance responsibilities for curriculum and student achievement and development [§§52.1(b)(3); 52.2(b)(1), (2), (3), (6) and (7)].

Area 5

Inadequate library resources to support all curricula, and their use in the instructional program [§§52.2(a)(4)].

Area 6

Absence of conceptualization of, planning for, and establishment of an arm’s-length governing board with broad responsibilities for oversight of institutional functioning including compliance with New York State standards and those of the institution’s voluntary accrediting agency [§§52.2 (a)(1); 52.2(e)(1) and (2)].

In accordance with the procedures set forth in the Commissioner’s Regulations, Taylor Business Institute appealed this decision and on December 30, 2005 provided documentation in support of its position that it had come into substantial compliance with applicable regulations. Following a review and discussion with representatives of Taylor Business Institute, and after receiving further assurances from the Institute, the Deputy Commissioner determined to hold in abeyance the termination of program registrations and Taylor’s authorization to conduct courses leading to credit and degrees, pending the outcome of any on-site examination by a peer review team.  The terms of such agreement were set forth in a letter dated April 11, 2006, signed by all parties. 

The review team’s charge was to determine whether the Institute had, in fact, come into compliance with applicable laws, rules, and regulations, with particular attention to the six areas of substantial non-compliance cited in the October 4, 2005 letter of the Deputy Commissioner for Higher Education and for the Professions to the President of Taylor Business Institute.  The findings from the first of these reviews on August 7-8, 2006 are described in this report. 

          In the April 11, 2006 letter, the Institute agreed that, absent a finding of substantial compliance with the Commissioner’s Regulations, after any site visit through the summer of 2007, the Department could immediately terminate registration of all degree-granting programs at Taylor Business Institute.  The Institute agreed that any such determination would be final and binding, and waived any and all legal rights to challenge the determination by administrative or judicial appeal or litigation in any forum. 

            The August 7-8, 2006 team took into account the reports of the Department’s February 2004 visit, and March 2005 visit, the Institute’s responses to them, and the Department’s determination letter of October 4, 2005.  However, this report’s findings and observations are based principally on observations, conversations with faculty, staff, trustees, and students, and review of materials on-site during the visit on August 7-8, 2006 and the documentation submitted by the Institute on December 30, 2005.   

Review Team Members:

Josephine Braneky
Professor
Computer Systems Technology
CUNY - New York City College of
Technology
Brooklyn, NY

Louis deSalle
Associate Dean for Curriculum and
Instruction
School of New Resources
College of New Rochelle
New Rochelle, NY

Thomas Finch
Vice President, Academic Affairs
North Country Community College
Saranac Lake, NY
Warren Rosenberg
Provost
Iona College
New Rochelle, NY

Donald Simon
Dean of College Relations
Monroe College
Bronx, NY
Rajen Tibrewala
Professor, Quantitative Analysis
New York Institute of Technology
Old Westbury, NY

Thomas Travis
Vice President for Adult and
Professional Education
St. Joseph’s College
Brooklyn, NY

Elena Vranich
Director, Higher Education
Opportunity Program
Lincoln Center Campus
Fordham University
New York, NY

Kate Gulliver
Associate in Higher Education
NYS Education Department
Office of College & University Evaluation
Albany, NY

Robert McHugh, Site Visit Coordinator
Associate in Higher Education
NYS Education Department
Office of College & University Evaluation
Albany, NY

Team Findings in Six Areas of Non-Compliance

Each of six areas of non-compliance discussed below includes: (1) a statement of the deficiency or matter of non-compliance and citation of pertinent Regulations of the Commissioner of Education; (2) a summary of the Institute’s December 30, 2005 documentation supporting a position of compliance; (3) Department’s findings based on review of the December 30, 2005 documentation; and (4) the findings of the August 7-8, 2006 review team and the Department.

Area 1:  Curriculum rigor, level, content

(1)       Matter of non-compliance:  Inadequate equivalency of coursework in rigor, level and content with courses offered by other degree-granting institutions, including four-year institutions, to which Taylor students might seek to transfer [§§50.1(o); 52.1(b)(3); 52.2(c)(1), (3) and (5); 52.2(e)(4)].

(2)      Actions and conditions Taylor reported in December 2005 documentation:  Taylor reported the following:  Nine courses cited as deficient for the credits assigned to them have been modified.  According to the response, grading rubrics for courses have been established.  A standard format for mid-term and final exams has been established; short-answer tests have been replaced by an exam format that is principally essay based.  All courses are now reported to require a five-page research paper with bibliography.  Taylor reports that, in general, writing has become a “core academic process.”  According to the response, the librarian provides an introduction to research methodologies in all classes.  Course texts are reported to have been upgraded in level in some courses.  All course syllabi have been reviewed and are reported to include a statement of objectives, expected outcomes, and pre- or co-requisites.  The Institute has in place articulation and transfer of credit agreements with the following colleges:  Nyack College (Adult Degree Program), St. Joseph’s College, Mercy College, and Monroe College.  Faculty are expected to have at least 15 graduate credits in each subject of instruction. 

(3)      Department findings on December 2005 documentation:  Staff cannot attest to substantial compliance based on the scope or depth of documentation provided by the institution.  Although a number of changes intended to strengthen learning expectations and course rigor have been reported, they do not demonstrate that the compliance standards in this area are met either through full implementation of stated policies or, if implemented, through compliance in practice with college-level performance standards.

The syllabi provided for courses, including those modified, are, for the most part, generic templates and do not include sufficient information on content, assignments, and measures to assess content, level and rigor for particular courses.  The indicated use of just one assessment formula to determine the final grades in all courses, given the diversity of the course offerings and their requirements, is generally not appropriate practice. 

Appeal materials indicated some changes in texts; however, the scope and depth of resulting changes in learning standards are not indicated.  Materials provided in this area did not document substantial compliance with respect to rigor, level and content. 

The Department is not prepared to accept the articulation agreements with other colleges as documentation of adequacy since staff have not examined the documentation underlying these agreements.

(4)      Findings of August 2006 Team in Area 1:  Taylor has made a number of the changes cited in its December submission.  Some courses have been modified by changing credit allocations; institutional level syllabus templates have been developed; texts have been changed in some courses, and writing requirements have been increased through a mandated research paper in all courses and more writing on exams.  The Institute has adopted a single formula for determination of student grades for all courses in an initiative to establish consistency and perhaps raise student performance expectations through increased emphases on attendance and writing in this course grading formula.

The review team concluded, following extensive review of course materials, interviews and class observations, that, while these and other initiatives may have been well intentioned and possibly have had some positive effects, they have not brought the Institute into substantial compliance in the area of curriculum rigor, level and content.

The Institute remains in significant non-compliance in this area.

  • The Institute’s generic syllabi or templates for syllabi, while an improvement over past practices, do not provide sufficient information on objectives, implementing content, or assessment.  These generic syllabus templates are not satisfactory for use as course syllabi.  At the discipline level, the Institute has not developed syllabi that satisfactorily include learning outcomes, implementing content, assignments, or assessment beyond the generic, institutional formula.  For example, in general education subjects, syllabi typically lacked learning objectives, grading rubrics specific to the course, or significant out of class assignments.  At the individual instructor level there appeared to be very wide and unsatisfactory variations in syllabus content, level of detail, and pertinence to the course.  Some suggested supplemental readings were quite unrelated to content and to the skill levels of students.  In general, the team concluded that initiatives to systematize and upgrade syllabi were insufficiently embedded in instructional practice.  This seemed particularly significant because of the rapid turnover in faculty, their inexperience, and the adjunct status of most of them.


  • Textbooks routinely are not provided in a timely or adequate manner, commonly arriving two or three weeks after the start of the 10 week term.


  • The 5-10 page research paper required of each student in each course is uneven in execution and in efficacy.  Students are not prepared for research; sufficient materials are not available; instruction in research is inadequate; and research papers are unrelated to course objectives and content. Reviews of papers indicated insufficient mentoring and preparatory instruction, inflated or inconsistent assessments, and lack of adherence to stated MLA format requirements.  The quality of instructor correction and comment varied greatly, (e.g., good in English Literature and poor in Earth Science and Psychology).  In general, research papers reflected unrealistic expectations and insufficient support and services for the Institute’s ability-to-benefit population to meet this requirement satisfactorily.  The mandated research papers reviewed by the team appeared not to consistently contribute to learning in the subject area or to the attainment of course objectives.  It seemed to be, in the team’s view, “an over-reaction to criticism and a splash-dash remedy.”


  • A number of courses do not merit the credit assigned to them, in the team’s judgment, following extensive reviews of syllabi, exams and graded student work.  For example, most courses in computing are only partially college-level and should yield fewer credits than are currently assigned to them.  The College Seminar merits about one Carnegie Unit credit, or at best two quarter credits, not the four quarter credits now assigned. Earth Science, Business Writing, and credit bearing Mathematics courses also should yield fewer credits.  The team noted significant gaps in the expected and attained exit skills in developmental Mathematics and English and the expected entry level skills for college-level instruction in these disciplines. The combination of Developmental English and Business Writing as taught is insufficient to prepare students adequately for college-level writing, including the mandated research paper.  Reviewers in the field of Business concluded that Personal Finance merits no credit and Business Law and Marketing should yield less credit than is now assigned. The required externship has seriously insufficient documentation of learning objectives, related tasks, and reflective assessments of experiences and attained learning to merit 12 quarter credits.


  • The team noted that class time appears to be ineffectively used in a number of courses.  The presentation of “12 week” syllabi for 10 week terms requires either significant adjustments or significant reduction in coverage of course content.  There appears to be insufficient use of class time to cover adequately the stated course content (e.g., one week of review preceding each test and also the final exam; reading of course assignments during class time; and ending of assignments (as in Psychology I) as early as the seventh week of a ten week term.  Consistently, too much time is spent on review and oral reports (25 percent of grade) rather than coverage of essential content.  In Business Law only 20 percent of the content appears to be covered, in addition to inefficiencies in execution.  This widespread inefficiency is compounded by the extensive absenteeism of students (about 50 percent on average) and also by the absenteeism (or departure during a term) of faculty and their replacement by substitutes lacking the expertise to pick up on content.


  • Outside study assignments appear to be consistently too limited (20-30 minutes per night according to students interviewed by the team) to meet the requirements of the Carnegie Unit.


  • The quality and effectiveness of teaching was mixed in the team’s observations of classes.  In Developmental courses and Accounting I, and Internetworking and Integrated Computer Applications, instructors appeared to be competent in their instruction.   It seemed likely to the team that for a small population of students in some courses, Taylor was providing a solid skill development and learning.  In other courses instructors were very simplistic, uninformed, or confusing in presentation.  Some instructors were effective in the classroom although teaching outside of their areas of formal training and expertise, but most of this instruction was at a very basic skill and knowledge level.  In general, observations of instruction were at a pre-collegiate skill and knowledge level.  Students were being prepared for the high school equivalency diploma, but not through courses that were clearly college-level.  One example of this was Earth Science.  The team observed an elementary geography session spent on identifying the oceans and seas and the assignment due the next week was to identify the seven seas, which had just been covered in class.  Another observed example was a class in College Math in which students were learning how to calculate the volume of solids.  As noted, the quality of student research papers suggested inadequate mentoring and assessment, and inadequate academic support services for the attainment of college-level performance.  The team was told, parenthetically, that faculty did not have ready access to plagiarism checking programs.


  • The team was concerned that the general grading template for all courses (25 percent for the final and mid-term exams, 25 percent for the research paper, 25 percent for the oral presentation, and 25 percent for class participation) did not sufficiently relate to mastering course content.  The team noted that in practice there are some variations on this formula.  For example, the mandated mid-term exam is not given in some courses according to interviewees.  More generally, a student could receive grades of zero on both the mid-term and final exams and, if the oral participation and research components were at the top level, a student could attain a 75 term average without having any knowledge of course content.  (The research paper can be, and sometimes is, quite peripheral to the course content.)


  • Although the Institute reports that about 80 percent of its faculty have at least a master’s degree, review of data on educational backgrounds shows that a much lower percent have master’s degrees in fields they are teaching (perhaps as low as 35 percent in one count).  Many faculty do not have the 15 graduate credits in each field in which they are teaching, which is the Institute’s stated standard.  The Institute’s expectation of a master’s degree is not necessarily in the field of instruction.  The Institute’s advertisement for new faculty states that “experience” is not required, and, in fact, many faculty do not report prior or current college teaching experience.  Given these limited backgrounds in advanced study and college teaching, it is not surprising that the general level of instruction was observed to be basic and generic, the rigor and quality of assessments was very uneven, and course syllabi varied greatly in detail and coherence.


  • The very rapid turnover in faculty also makes satisfactory quality assurance in instruction difficult and unlikely.  In the computing area, only one of 14 faculty had been at Taylor Business Institute for at least two years, at the time of the visit.  Continuity, including management faculty and chairs, was not much greater in the Business or General Education Department.


  • Two of the four transfer and articulation agreements with other colleges, cited in the Institute’s December 30, 2005 appeal have been discontinued by the other colleges, and a third is under review by the partner institution.

Area 2:  Student support services

(1)      Matter of non-compliance:  Unsatisfactory provision for, and assessment of, the effectiveness of, interventions and services to support student persistence and attainment [§§52.1(b)(2); 52.2(a)(2) and (3); 52.2 (b)(2) and (3); 52.2(d)(2); 52.2(e)(1) and (5)].

(2)      Actions and conditions Taylor reported in December 2005 documentation:  Taylor reported the following:  Upon admission, a student meets with the chair or lead instructor of his/her program to discuss academic expectations and provide a writing sample.  Orientation includes presentation of academic and behavioral standards and discussion of adjustments to college life.  According to the report, all new students are required to take developmental English and Math (with possible test-out in first week).  Students below “C” in a course at mid-term must agree to a “learning contract” for the remainder of the course.  Taylor reports that there is personal contact by phone and mail for non-attendance.  Taylor also reports expanded provision for peer tutoring by work-study students with 3.0 GPA and tutoring center hours have been expanded.  According to the report, a librarian is available as a resource person for instruction in library-related skills development; and there is enhanced faculty availability, including office hours.  Taylor reports that student services have been placed under the Academic Vice President.  Additionally, according to the report, Taylor has tightened facility security and monitoring of student behavior.   

(3)      Department findings on December 2005 documentation:  While the services Taylor reports to have put in place are important, the recent changes in this area are limited.  According to the report, changes put in place since the last visit include structured office hours, expanded tutoring hours, and placement of student services under the Academic Vice President.  However, Taylor provides little information on the scope, and particularly on the outcomes, of intervention services such as tutoring or use of learning contracts.

The steps reported to have been taken by Taylor to raise academic performance standards, including more writing for entering students who are principally admitted on the basis of attaining a minimum pass score on an “ability-to-benefit” federally approved test for purposes of financial aid eligibility, suggest a need for substantial additional intervention and support services. 

It is not evident from the report that mentoring and intervention services are sufficient in scope or operation to support student achievement and persistence.  Examples of student writing at the point of admission, provided in the appeal documentations, show very limited skill levels and suggest the need for rich remedial and support interventions.  Examples of the mid-term learning contracts for students who are performing poorly seem more like counseling reports than clear contracts with stated performance expectations, and provision for frequent follow-ups.  Assessments as late as mid-term may be too late in a semester to identify problems and provide interventions.  The office hours and teaching hours of a number of faculty appear to be disconnected (e.g., classes one day and office hours another).  Grade distribution sheets provided in the appeal indicated a high failure and withdrawal rate, indicating insufficient admissions and academic support criteria, processes, and resource commitments. 

 

(4)      Findings of August 2006 Team in Area 2:  The team concluded that despite several initiatives, including contacting students who are absent, involving faculty in student contacts and individual tutoring and advising, use of learning contracts with subsequent contacts for students who fail courses, and substantially improved security and decorum, the Institute is not in substantial compliance in this area.  The services and resources provided to students, and their coordination and timing, do not satisfactorily address the learning needs of its high risk student body. 

          The team made the following observations:

  • Academic support is essentially provided by a faculty that is essentially part-time, most of whom teach four courses, service upward of 60 students, monitor absentees, guide individual research projects, mentor students on “at-risk” learning contracts, and provide tutoring for those who request this service.  This degree of reliance on part-time faculty is unlikely to address satisfactorily the students’ needs.


  • There is no functioning academic resource center with tutoring service, much less one with walk-in and on-demand capability.  Students in need of tutoring are expected to individually seek out faculty.  In general, seeking out such help is undertaken more by the better students seeking a high grade than by seriously “at-risk” or low performing students.  Faculty are expected to provide tutoring to students who request it in particular courses.  This is to be done during a scheduled one hour weekly office visit, which may not match student schedules, although some faculty were observed providing individual instruction and assistance at times other than scheduled office hours.


  • The financial aid office provides little assistance to students.  The Institute ignores personal expenses in calculations of unmet need.  Institutional grants to students are conditional on meeting academic requirements, rather than being simply non-renewable for failure to meet academic requirements.  Some students report not being continuously or well informed about accumulating debt based on their enrollment in Taylor Business Institute.  The exclusion of personal expenses in calculating unmet need and the conditional nature of institutional grants are not consistent with college practices.  A number of students cited lack of funds for public transportation to classes as a reason for non attendance, yet the team was not aware of any support for such students to strengthen attendance, and presumably retention and learning.  In contrast, the team noted that the Institute’s financial reports showed a very strong cash flow and very high profit margin.


  • All non-academic support was provided by a single person, the Director of Student Services, at the time of the visit.  In higher education counselors are widely acknowledged as a critical component to a supportive environment that fosters responsibility, growth, and acculturation to higher education.  The Institute is far from providing adequate counseling services.  Reliance on a single staff member to deal with over 500 students is woefully inadequate, particularly for an essentially “at-risk” population.  Many students enroll in Taylor Business Institute for training and education because their five-year maximum term for public assistance support is running out and thus they are in need of quite immediate, continuous and rich counseling and support services.  The Institute did not provide any documents showing its methods of appraisal, intervention, consulting, research, and referral techniques – all of which have been proven to facilitate academic judgment and career goal clarification.


  • Although, following admissions, students provide a writing sample and discuss factors related to persistence and success, there is no follow-up with individualized support services and placements.  All students simply take the same package of courses.  Not until after the mid-term exam (if given) when there is a real prospect of academic failure, does the institution’s academic monitoring and counseling come into play.  This effort appears quite limited and ad hoc for some students.  In general, assessments and interventions are too little, too late.


  • The lines of communication between administrators, faculty and students are not clear.  There is apparent absence of coordination of support services, which is viewed by professionals in the field as critical to “at-risk” student perseverance and academic success.


  • Although faculty have the major responsibility for advising, tutoring and other services related to student persistence and support, faculty accommodations for these services remain poor.  Most faculty do not have private or shared offices, but share a common space with one large table and a few open carrels, and limited and sometimes non-operational duplicating and computing equipment (including a single antiquated computer).  The Institute’s top administrators had not been responsive to requests for improved space and equipment for the advising, tutoring and other services assigned to faculty prior to the visit.

Area 3:  Academic leadership

(1)      Matter of non-compliance:  Absence of sustained and effective academic leadership by appropriately trained, college-experienced professionals in the areas of academic programs and related educational services, including tutoring [§52.2(a)(2) and (3); 52.2(b)(1), (2), (6) and (7); 52.2(e)(1), (2) and (3)].

(2)      Actions and conditions Taylor reported in December 2005 documentation:  Taylor reported hiring an experienced Academic Vice President just before the March 2005 visit and, since the last visit, chairs of three major program areas.  Taylor also reported designating lead teachers for each major program area, and expanding student services staff.  Additionally, Taylor reports it has developed a faculty primarily credentialed at the master’s degree level.

(3)      Department findings on December 2005 documentation:  Based upon materials submitted by Taylor, the institution appears to have made progress on the “front end” of appointments since the March 2005 review visit.  However, sustained and effective academic leadership, as expressed in the operation of Taylor as a college community of disciplined learning and reflection, has not been demonstrated. 

(4)      Findings of August 2006 Team in Area 3:  Taylor responded to a serious deficit in educational leadership by hiring an Academic Affairs Vice President (AAVP), a person with substantial prior academic and administrative experience.  Chairs for each of the three academic departments have been appointed.  Seven faculty, designated as management, have been appointed as coordinators and lead teachers.  The AAVP has been at Taylor Business Institute since the prior Department visit in March 2005; other appointments are more recent, some within several months prior to this visit.       

The team concluded, however, that the Institute has not achieved sustained, effective leadership through these and other reported actions.  This is evidenced by sustained and significant deficiencies in the scope and quality of services and unsatisfactory definition and practice of administrative responsibilities.  These include lack of collaborative focus on student achievement and development; absence of clear, ongoing budget allocations; inadequate levels of investments; ad hoc and subjective decision-making; poor communication; and an authoritarian, top-down non-inclusive management style and practice.  The Institute’s owners and administrative leaders have not succeeded in establishing a college community of disciplined learning and reflection.  The Institute is far from the statement in its Faculty Handbook that “a college is a community of teachers and learners in which collegial, cooperative and collaborative relationships prevail.”  The Institute is not in substantial compliance in this area. 

The team made the following observations. 

  • All expenditures appear to be personally determined by the owners despite their absence of backgrounds in college administration.  There is apparent lack of budgets for major departments.  This deficiency undermines the capacity of the Academic Affairs Vice President and other officers to plan, administer effectively, and implement change on an educationally sound basis.  Levels of investment in critical services, including teaching, academic facilities and equipment, library, and student support have been and are inadequate to support practices at a level of substantial compliance.  There has been a continuous and significant under-investment in educational services for the promotion of strong student attainment and development.


  • Significant policies are not satisfactorily communicated to the instructional and other staff, based on team conversations with faculty and staff.  For example, the chair of the Business Department had no knowledge of a recent curriculum change proposed to, and approved by, the State Education Department in his area of responsibility.  Policies also are misstated.  For example, Faculty Handbook statements on faculty rank are inaccurate and a major misrepresentation.  Other basic information is missing.  For example, the catalog did not list faculty with their degrees.


  • The chairs marginally or inadequately meet professional standards for appropriately trained, college-experienced program leaders.  In terms of both training and experience and in terms of content knowledge and pedagogical experiences, compliance is marginal at best in their academic backgrounds.  None of the Departmental chairs reported prior experience as a chair; one had no college teaching experience.  The backgrounds of these appointees do not suggest an institutional commitment to strong academic leadership.


  • Many Taylor Business Institute faculty are in effect “full-time” adjuncts.  Many adjunct faculty teach at least four courses (a full-time load in most colleges) and, on paper, have the advising, governance and professional development responsibilities of full-time faculty; however they have no benefits or assurance of continuity.  These adjuncts receive new contracts each quarter, but they are essentially “at-will” employees.  In interviews, faculty were unaware of what full-time status meant, and more generally their roles and responsibilities at Taylor for governance and other responsibilities.  The “at-will” employment environment and the designation of a few faculty as “management” is not conducive to academic leadership in a collegial spirit.  It is instead conducive to divisiveness and a marginalized role for faculty.


  • About 10 persons have been designated as chairs, lead instructors, and coordinators.  Classified as “management,” they conduct some of the functions of full-time faculty.  There are, however, no designated full-time faculty to carry out responsibilities.  The Institute has not put in place the core of 15 full-time faculty recommended by the Department.


  • Taylor’s faculty is not highly credentialed.  One of the several and varying lists provided by Taylor Business Institute showed that 34 percent of current faculty do not possess graduate degrees.  In addition, a number of faculty are teaching in areas in which they lack evidence of expertise through advanced study.  In one team member’s comparison of resumes and assignments, it appeared that about one-third of the faculty had a master’s degree in the field(s) in which they were teaching at the time of the visit.  Also, many new faculty do not have prior college teaching experience.  These data do not suggest effective academic leadership, fulfillment of stated commitments, or an institutional commitment to well qualified faculty.


  • There are virtually no experienced faculty to do mentoring, supervise or evaluate new faculty, or lead in the discussion and formulation of educational policy.  Only a small number (less than 20 percent of a faculty of about 40) have taught at Taylor for more than one year.  The team noted that one of the reasons given for terminating faculty under the current Academic Affairs Vice President was “lack of experience.”  However, the Institute appears to have moved toward a faculty with lesser rather than greater experience, even advertising that applicants for teaching positions need not have teaching experience.


  • The number of academically at-risk students needing remedial work and other interventions and support substantially exceeds current capacity.  The absence of a discrete remedial/developmental service center, well staffed by qualified professionals, is an indicator of inadequate academic leadership.  The faculty, although including some dedicated and caring persons, is not able to provide sufficient educational services for Taylor’s at-risk population.


  • In the area of professional development, faculty workshops were mentioned by faculty members, but none had any memory of attendance.  There appear to have been few meetings, formal or informal.


  • There appears to be little or no institutional research and assessment on program or institutional effectiveness. The Institute is required by Commissioner's Regulations to evaluate all curricula for effectiveness in meeting stated objectives.  Absence of such plans and implementing actions does not suggest substantial compliance.  The recent curriculum revisions and changes do not constitute a plan for the periodic evaluation of curriculum effectiveness.


  • The team did not see evidence of strategic planning or a strategic plan.


  • The absence of any substantial co-curricular activities is a sign of inadequate leadership commitment to student engagement and development.

Area 4:  Faculty roles and responsibilities

(1)      Matter of non-compliance:  Insufficient conduct by the faculty of academic governance responsibilities for curriculum and student achievement and development [§§52.1(b)(3); 52.2(b)(2), (3), (6) and (7)]. 

(2)      Actions and conditions Taylor reported in December 2005 documentation:  Taylor reported it has put in place a structure for faculty governance (Senate and Academic Committee).  According to Taylor, by-laws are under development and program leadership positions (chairs and lead faculty) have been established.  Taylor also reports to have conducted a review of courses and curricula, with upgrading of content and rigor in some courses.  According to the report, there has been recent standardization of formats for teaching, with greater emphasis on writing and library use in coursework and more structured availability of faculty for student advising and academic assistance.  These changes are recent. 

(3)      Department findings on December 2005 documentation:  Progress resulting from these reported actions is not yet evident.  While on paper these changes appear to have potential for progress, it is not clear that they are institutionally embedded or that they are sufficient in scope (e.g., a single Academic Committee is responsible for all academic governance responsibilities).  For example, appeal materials suggested faculty “approval” but not much faculty discourse over curriculum content, standards, or quality assurance processes.  It is not evident that the role and the practices of faculty are satisfactory with respect to academic governance and the promotion of quality in student achievement and development.

(4)      Findings of August 2006 team in Area 4:  Taylor Business Institute has made limited and incomplete actions toward faculty governance.  The team noted that within Departments meetings are scheduled among chairs, coordinators and lead instructors, and there is some formal and informal consultation and collaboration among faculty at the course level.  However, the Institute remains substantially out of compliance in this area.  Taylor has not demonstrated a commitment to building an academic community committed to the substantial practice of faculty governance. 

The team made the following observations.

  • There is no operational faculty governance body for the institution as a whole.  The Academic Senate and Academic Committee are without substance as deliberative bodies.  All faculty are designated as Senate members.  They are merely ratifiers of administrative decisions.  “Deliberation” consists of individual voting by mail on curricular changes proposed by the Academic Affairs Vice President (AAVP).  Similarly, the Academic Affairs Committee, which in theory is responsible for curriculum, academic standards and student development, simply endorses determinations of the AAVP.  Few faculty interviewed by the team had any knowledge or understanding of the academic governance structure or process.


  • The description of faculty governance in the Faculty Handbook is highly inaccurate.  It appears to be the document of some other institution and not formed through deliberation at Taylor.


  • It is unrealistic to think that a largely part-time, at-will and transient teaching staff have the knowledge, vested interest and protection to raise substantive issues or challenge the status quo.  It is also unreasonable to think that an adjunct faculty member with as little as a one course teaching load, little or no prior experience at the institution, and no guarantee of continued employment, would either have the institutional knowledge or long-term commitment to make thoughtful and reasoned contributions.


  • Although the adjunct faculty are the academic backbone of the institution – students rely on them for advisement, tutoring, counseling, and general skill development – they are poorly compensated, have no benefits or job security, have no substantive responsibilities academically guiding the institution or input into academic governance or planning and are provided with little information on the operation of the institution.  They clearly are not regarded as the academic core of the institution by owners and senior administrators.


  • Faculty and administrators stated that the President determines academic policy, and that nothing could be approved without his consent. In particular all decisions regarding resources, equipment and support staff were said to be made by the President.  There are no Department budgets and no structure for academic planning or long-term resource allocations.  Conversely, interviewees stated that measures unacceptable to the faculty will be implemented if wanted by the President.  For example, he has denied addition of new computers for faculty, despite requests by faculty and department chairs.  Texts were reported to be chosen by the administration, not the faculty.

Area 5:  Library resources and their use

(1)      Matter of non-compliance:  Inadequate library resources to support all curricula, and their use in the instructional program [§§52.2(a)(4)].

(2)      Actions and conditions Taylor reported in December 2005 documentation:  Taylor has stated a commitment to developing the collection, starting with the ordering of about 350 new books and a commitment to use library resources and library based research in the curriculum.  According to the report, Taylor has employed a professionally credentialed librarian and subscribes to databases (including Lexis-Nexis, Cyber-Library, EBSCO and participation in METRO).

(3)      Department finding on December 2005 documentation:  Deficiencies in this area have been continuously reported to Taylor Business Institute since 2002.  The Institute has had several librarians since then, but has been unable to meet standards and expectations in this area.  Despite reported actions taken, the collection continues to be inadequate.  Resource development and use in the curriculum is embryonic at best.  The library instruction program appears to be more a basic “how to use a library” (i.e., more like grades 7-9) than information literacy.

(4)      Findings of August 2006 Team on Area 5:  Taylor Business Institute has consistently been alerted to the inadequacies of its library collection, services and use in the curriculum since the current owners assumed control in 2002.  At the Department’s recommendation professionally credentialed librarians have been successively engaged.  The small collection has been somewhat improved in organization and appearance.  Computer terminals have been added.  The Institute reports new membership in METRO, subscription to widely used databases, the allocation of $35,000 to add to the collection, the expenditure of $14,000, of the sum, and the recent purchase of 350 additional books. 

The team found that these actions are seriously insufficient to bring Taylor Business Institute into substantial compliance with the requirement of library resources adequate to support all curricula and their use in the instructional program.  The library remains peripheral and insufficient in resources and services. 

The team made the following observations.

  • Library space is inadequate for current demand.  The number of computer workstations is inadequate, particularly in view of the Institute’s research paper requirement.


  • The collection is too small to meet the demands of the curriculum, again including the research requirement.  The addition of 350 books (still in wrappers at the time of the visit) is inconsequential in relation to needs.  The current collection does not satisfactorily support particular courses or curricula, or general skill and knowledge development needs.  A number of volumes in the small collection are irrelevant to programs or superfluous and should be weeded out if the collection is to focus on institutional goals, curriculum and course needs, and be responsive to students’ capabilities and skill levels.  Library resources are inadequate to meet satisfactorily the research requirements of the Institute.  Students were very clear on the unavailability of databases needed for research on their required research papers and other course requirements.  In general, the collection may still be characterized as a fairly random assortment of titles.


  • The program of library services in support of instruction is inadequate.  The institutional outreach appears to consist of the librarian’s short presentation in Freshmen Seminar classes on MLA format requirements for the research paper.  There is no comprehensive information literacy program in accordance with the guidelines of ACRLS, as recommended, or apparent effort or plan to implement one.


  • The library did not lend books at the time of the visit.  Students could only use books in the library.  Some students do not have access to public libraries.  Few students have substantial resources at home.  There was no evidence that the EBSCO Host database, or other databases said to be subscribed by Taylor, were readily available for student use or that students would know how to use them.


  • There has been an unsettling turnover of librarians, each one of whom lacked clout or standing as a serious participant in the allocation of resources or as a manager/teacher in a program of information literacy instruction.  Contrary to statements in the appeal of December 2005, the librarian does not visit all classes.


  • There is no place for students to gather in group study, or sufficient computers for independent study.


  • The limitations of the library are especially unsettling because of the allocation of 25 percent of all course grades to the research paper.


  • Both faculty and students dismissed the library as useless in interviews.  As one student put it “to not have a good library is the same as not giving us a professor for one of the four classes we take each term and asking use to get the information by going to another college and sitting in on classes there.”


  • Insufficient investment in and use of the library suggests deficiency in academic and institutional leadership and its understanding of the attributes of a college.

Area 6:  Governance

(1)      Matter of non-compliance:  Absence of conceptualization of, planning for, and establishment of, an arm’s-length governing board with broad responsibilities for oversight of institutional functioning, including compliance with New York State standards and those of the institution’s voluntary accrediting agency [§§52.2(a)(1); 52.2(e)(1) and (2)].

(2)      Actions and conditions Taylor reported in December 2005 documentation:  Taylor reported to have established a board made up of four independent members and three senior administrators of Taylor.

(3)      Department findings on December 2005 documentation:  The formation of a board with a majority of independent members is appropriate.  However, the academic representation from the independent member group is minimal (one person) and perhaps insufficient.  The board had not yet formulated by-laws at the time of the appeal.  The scope of oversight responsibilities and authority of the trustees were not defined.  Again, this recommendation is not new.  Compliance in this area, as evidenced by definition of trustee responsibilities and their implementation, was not demonstrated as of December 2005.    

(4)       Findings of August 2006 Team on Area 6:  Taylor Business Institute has established a Broad of Trustees consisting of seven members, two of whom are the owners and one whom is a senior administrator.  The Institute established Trustee Bylaws, effective July 26, 2006.  The Bylaws of the Trustees are appropriate in description of the overall responsibilities of Trustees.  The Board of Trustees has met three times.   However, the team found that these actions do not constitute substantial compliance in this area, based principally on its interview with members of the Board other than owners/administrators.  The team made the following observations.  

  • The “outside” trustees have had no knowledge of trustee responsibilities as stated in the adopted Bylaws.


  • The “outside” trustees had no awareness of the purpose or significance of the review visit of August 2006 or the vulnerability of Taylor Business Institute to closure.  They had not seen prior documents from the Department.


  • The “outside” Board members have not been privy to financial statements of Taylor Business Institute.  There is no knowledge of finances and no involvement in strategic planning.


  • The Board has no role in approving the Institute’s budget, determining institutional policy, or confirming academic changes.


  • The composition of the Board does not at all reflect the population of the Institute.  There are no women, African Americans, or Hispanics.  The Board also does not include sufficient members having substantial expertise and knowledge of college culture and functioning.


  • The poor communication observed between senior management and middle management/faculty and students also applies to trustees.

Summary and Conclusion

The peer review team concluded that Taylor Business Institute is not in substantial compliance with the laws, rules and regulations applicable to degree-granting institutions in New York.  In making assessments individually in each of the six areas of non-compliance stated in the Department’s October 4, 2005 determination letter on the continued registration of the Institute’s programs (six areas x 8 “arm’s length” consultants = 48 assessments), team members concluded that Taylor was in substantial compliance in only two of the 48 individual assessments, for a compliance “score” of about 5 percent. 

Among the general points the team made and the Department endorses, were the following:

  • Areas of non-compliance with expectations of policy and practice have been identified numerous times to the Institute’s owners, starting in 2002.  Subsequent formal peer-based review reports following visits in 2004 and 2005 specified particular areas of weakness and set forth recommendations. The August 2006 team, including several members who also had been on prior visits, was surprised that the scope and degree of non-compliance was still so great. These observations suggest leadership incapacity to address and remedy satisfactorily areas of weakness and needed change and come into substantial compliance.


  • There were substantial differences in representations of policy and action in the appeal of December 30, 2005 and observed practices in the August 2006 site visit.  Examples are the organization and scope of tutoring and other services, and the involvement of faculty in governance and professional development.   The team also remarked on the disconnect between polices borrowed from other organizations, as in the faculty organization and in trustee organization and functioning, with actual practices at Taylor Business Institute.


  • There has been a consistent pattern of underinvestment in educational services in a number of areas, including faculty, library, equipment and support services.  Investments appear to be consistently minimal, piecemeal, and inadequate to establish substantial compliance. At the same time, the Institute appeared to have ample resources for investments to strengthen educational practices and outcomes. A review of the Institute’s financial statements of recent years indicates a strong cash flow and unusually high profit for the Benham Company, Inc. and its principal officers.


  • The Institute was observed, once again, to have an extremely centralized, personalized and authoritarian mode of operation.  There has been little substantive delegation of authority and responsibility.  For example, academic and other departments have no budgets.  The trustees have no involvement in reviewing or approving budgets, engaging in institutional planning, or reviews of financial condition and results of educational investments.  The faculty have no substantive role in the setting of educational policies, which are almost uniformly mandated by management.  These arrangements and practices provide a weak and unsatisfactory underpinning for serious, ongoing assessments and strategic planning, which were not in evidence at the time of the visit.


  • Communication among staff and faculty, and particularly between senior administrators, and faculty, staff and trustees, is poor.  Faculty are unaware of matters of basic interest beyond their immediate assignments.  Trustees who are not administrators are unaware of basic conditions at the Institute and of their responsibilities.


  • There is a continuing pattern of rapid turnover in staff and faculty, providing an insufficient basis for sustained collaborative engagement in governance and administration, particularly among faculty but also in administrative services.


  • Student support services are dramatically understaffed in relation to the needs of the Institute’s almost wholly “at-risk” student body.


  • Initiatives to strengthen practices are generally inadequate and ineffective.  Examples include the record of upgrading the credentials and expertise base of faculty; the hiring of department chairs and a professional librarian who lack requisite skills and experiences; buying several hundred books for the library; imposing a uniform grading scheme and a research requirement not clearly related to course content and learning objectives; a board of trustees lacking knowledge and responsibility; establishing academic governance bodies without any real deliberative responsibilities or authority; and requiring one faculty administrative hour per week as the basic substitute for provision of tutoring, counseling and other needed support services.  There is a consistently formulaic and “magic bullet” approach toward a pro forma compliance.   There is not a management-led and broadly participatory focus on student learning and development.  There is an institutional reliance on surface and cosmetic changes, not a commitment to the serious education of each student.


  • In the bulk of its educational activities, the Institute operates more as a high school equivalency preparation enterprise rather than as a college.  Much of the instruction is not college level.  After completing their program at Taylor Business Institute, students may have attained a high school equivalency diploma and obtained a degree, but consistently did not acquire the knowledge and skills expected of a holder of an associate degree.  In view of the attrition rate of about 80 percent, the public cost of what is essentially a high school diploma attained through study that is marginally of college level and rigor, is estimated to be about $80,000 – $90,000 per student - a questionable public expenditure for this outcome.

In view of these considerations, the Department concludes that Taylor Business Institute is not in substantial compliance with applicable laws, rules and regulations.  The gap between expectations and performance remains wide in areas cited in the Deputy Commissioner’s determination letter of October 4, 2005, and does not provide a basis for holding in additional abeyance the termination of the Institute’s program registration.    



 

Taylor Business Institute Review

 

Regulatory Basis of Compliance Findings

Text of Applicable Commissioner’s Regulations

 

September 2006

 

Pertinent Regulations for each of the six areas of non-compliance are reproduced below.

Area 1

Inadequate equivalency of coursework in rigor, level and content with courses offered by other degree-granting institutions, including four-year institutions, to which Taylor students might seek to transfer [§§50.1(o); 52.1(b)(3); 52.2(c)(1), (3) and (5); 52.2(e)(4)].

§ 50.1 Definitions.

(o) Semester hour means a credit, point, or other unit granted for the satisfactory completion of a course which requires at least 15 hours (of 50 minutes each) of instruction and at least 30 hours of supplementary assignments, except as otherwise provided pursuant to section 52.2(c)(4) of this Subchapter. This basic measure shall be adjusted proportionately to translate the value of other academic calendars and formats of study in relation to the credit granted for study during the two semesters that comprise an academic year.

 § 52.1 (b) To be registered, each curriculum shall:

(3) show evidence of careful planning. Institutional goals and the objectives of each curriculum and of all courses shall be clearly defined in writing, and a reviewing system shall be devised to estimate the success of students and faculty in achieving such goals and objectives. The content and duration of curricula shall be designed to implement their purposes.

§ 52.2 (c) Curricula and awards.

(1) In addition to the requirements of section 53.3 of this Subchapter, the objectives of each curriculum and its courses shall be well defined in writing. Course descriptions shall clearly state the subject matter and requirements of each course.

(3) Credit toward an undergraduate degree shall be earned only for college level work.  Credit toward a graduate degree shall be earned only through work designed expressly for graduate students.  Enrollment of secondary school students in undergraduate courses, of undergraduates in graduate courses, and of graduate students in undergraduate courses shall be strictly controlled by the institution. 

(5) The institution shall assure that credit is granted only to students who have achieved the stated objectives of each credit-bearing learning activity.

(e) Administration.

(4) Academic policies applicable to each course, including learning objectives and methods of assessing student achievement, shall be made explicit by the instructor at the beginning of each term.

Area 2

Unsatisfactory provision for, and assessment of, the effectiveness of, interventions and services to support student persistence and attainment [§§52.1(b)(2); 52.2(a)(2) and (3); 52.2 (b)(2) and (3); 52.2(d)(2); 52.2(e)(1) and (5)].

§ 52.1 Registration of postsecondary curricula.

§ 52.1 (b)(2) To be registered, each curriculum shall:  conform to all applicable provisions of this Part 50, 52, 53 and 54 of CR)

§ 52.2  (a) Resources. The institution shall:

(2) provide classrooms, faculty offices, auditoria, laboratories, libraries, audiovisual and computer facilities, clinical facilities, studios, practice rooms, and other instructional resources sufficient in number, design, condition, and accessibility to support the curricular objectives dependent on their use.

(3) provide equipment sufficient in quantity and quality to support instruction, research, and student performance.

§ 52.2 (b) Faculty.

(2) To foster and maintain continuity and stability in academic programs and policies, there shall be in the institution a sufficient number of faculty members who serve full-time at the institution.

(3) For each curriculum the institution shall designate a body of faculty who, with the academic officers of the institution, shall be responsible for setting curricular objectives, for determining the means by which achievement of objectives is measured, for evaluating the achievement of curricular objectives and for providing academic advice to students. The faculty shall be sufficient in number to assure breadth and depth of instruction and the proper discharge of all other faculty responsibilities. The ratio of faculty to students in each course shall be sufficient to assure effective instruction.

§ 52.2 (d) Admissions.

(2) Admissions shall take into account the capacity of the student to undertake a course of study and the capacity of the institution to provide the instructional and other support the student needs to complete the program.

§ 52.2 (e) Administration.

(1) Responsibility for the administration of institutional policies and programs shall be clearly established.

(5) The institution shall provide academic advice to students through faculty or appropriately qualified person.  The institution shall assure that students are informed at stated intervals of their progress and remaining obligations in the completion of the program.

Area 3

Absence of sustained and effective academic leadership by appropriately trained college-experienced professionals in the areas of academic programs and related educational services, including tutoring [§§52.2(a)(2) and (3); 52.2(b)(1), (2), (6) and (7); 52.2(e)(1), (2) and (3)].

§ 52.2 (a) Resources. The institution shall:

(2) provide classrooms, faculty offices, auditoria, laboratories, libraries, audiovisual and computer facilities, clinical facilities, studios, practice rooms, and other instructional resources sufficient in number, design, condition, and accessibility to support the curricular objectives dependent on their use.

(3) provide equipment sufficient in quantity and quality to support instruction, research, and student performance.

§ 52.2 (b) Faculty.

(1) All members of the faculty shall have demonstrated by training, earned degrees, scholarship, experience, and by classroom performance or other evidence of teaching potential, their competence to offer the courses and discharge the other academic responsibilities which are assigned to them.

(2) To foster and maintain continuity and stability in academic programs and policies, there shall be in the institution a sufficient number of faculty members who serve full-time at the institution.

(6) The teaching and research of each faculty member, in accordance with faculty member’s responsibilities, shall be evaluated periodically by the institution. The teaching of each inexperienced faculty member shall receive special supervision during the initial period of appointment.

(7) Each member of the faculty shall be allowed adequate time, in accordance with the faculty member's responsibilities, to broaden professional knowledge, prepare course materials, advise students, direct independent study and research, supervise teaching, participate in institutional governance and carry out other academic responsibilities, appropriate to his or her position, in addition to performing assigned teaching and administrative duties.

§ 52.2 (e) Administration.

(1) Responsibility for the administration of institutional policies and programs shall be clearly established.

(2) Within the authority of its governing board, the institution shall provide that overall educational policy and its implementation are the responsibility of the institution’s faculty and academic officers. Other appropriate segments of the institutional community may share in this responsibility in accordance with the norms developed by each institution.

(3) The institution shall establish, publish and enforce explicit policies with respect to:

(i) academic freedom;

(ii) the rights and privileges of full-time and part-time faculty and other staff members, working conditions, opportunity for professional development, workload, appointment and reappointment, affirmative action, evaluation of teaching and research, termination of appointment, redress of grievances and faculty responsibility to the institution; and

(iii) requirements for admission of students to the institution and to specific curricula, requirements for residence, graduation, awarding of credit, degrees or other credentials, grading, standards of progress, payment of fees of any nature, refunds, withdrawals, standards of conduct, disciplinary measures and redress of grievances.

Area 4

Insufficient conduct by the faculty of academic governance responsibilities for curriculum and student achievement and development [§§52.1(b)(3); 52.2(b)(1), (2), (3), (6) and (7)].

§ 52.1 (b) To be registered, each curriculum shall:

(3) show evidence of careful planning. Institutional goals and the objectives of each curriculum and of all courses shall be clearly defined in writing, and a reviewing system shall be devised to estimate the success of students and faculty in achieving such goals and objectives. The content and duration of curricula shall be designed to implement their purposes.

§ 52.2 (b) Faculty.

 (1) All members of the faculty shall have demonstrated by training, earned degrees, scholarship, experience, and by classroom performance or other evidence of teaching potential, their competence to offer the courses and discharge the other academic responsibilities which are assigned to them.

(2) To foster and maintain continuity and stability in academic programs and policies, there shall be in the institution a sufficient number of faculty members who serve full-time at the institution.

(3) For each curriculum the institution shall designate a body of faculty who, with the academic officers of the institution, shall be responsible for setting curricular objectives, for determining the means by which achievement of objectives is measured, for evaluating the achievement of curricular objectives and for providing academic advice to students. The faculty shall be sufficient in number to assure breadth and depth of instruction and the proper discharge of all other faculty responsibilities. The ratio of faculty to students in each course shall be sufficient to assure effective instruction.

(6) The teaching and research of each faculty member, in accordance with faculty member’s responsibilities, shall be evaluated periodically by the institution. The teaching of each inexperienced faculty member shall receive special supervision during the initial period of appointment.

(7) Each member of the faculty shall be allowed adequate time, in accordance with the faculty member's responsibilities, to broaden professional knowledge, prepare course materials, advise students, direct independent study and research, supervise teaching, participate in institutional governance and carry out other academic responsibilities, appropriate to his or her position, in addition to performing assigned teaching and administrative duties.

Area 5

Inadequate library resources to support all curricula, and their use in the instructional program [§§52.2(a)(4)].

§ 52.2 (a) Resources. The institution shall:

(4) provide libraries that possess and maintain collections sufficient in depth and breadth to support the mission of the institution and each registered curriculum. Libraries shall be administered by professionally trained staff supported by sufficient personnel. Library services and resources shall be available for student and faculty use with sufficient regularity and at appropriate hours to support the mission of the institution and the curricula it offers.

Area 6

Absence of conceptualization of, planning for, and establishment of an arm’s-length governing board with broad responsibilities for oversight of institutional functioning including compliance with New York State standards and those of the institution’s voluntary accrediting agency [§§52.2 (a)(1); 52.2(e)(1) and (2)].

§52.2 (a) Resources. The institution shall:

(1) possess the financial resources necessary to accomplish its mission and the purposes of each registered curriculum.

§ 52.2 (e) Administration.

(1) Responsibility for the administration of institutional policies and programs shall be clearly established.

(2) Within the authority of its governing board, the institution shall provide that overall educational policy and its implementation are the responsibility of the institution’s faculty and academic officers. Other appropriate segments of the institutional community may share in this responsibility in accordance with the norms developed by each institution.