07/14
Supplemental Materials
AGENDA ITEM VII-D
Consideration of adopting the Commissioner’s recommendations relating to authorization of baccalaureate degree programs at public community colleges (S.B. 414, 83rd Texas Legislature, Regular Session)
RECOMMENDATION: Approval Background Information:
Staff recommendations were presented for discussion to the Committee on Affordability, Accountability and Planning (CAAP) at the meeting on June 25, 2014. At that time, the recommendations had not been distributed for comment from interested stakeholders. After the meeting the staff recommendations, modified to include Committee comments, were distributed to all the public and private institutions within Texas for comment. The comment period ended on July 16, 2014.
Included in the supplemental material is a summary of the comments grouped by subject with a staff response. A copy of each comment received is also attached along with a presentation on the Commissioner’s recommendations relating to authorization of baccalaureate degree
AGENDA ITEM VII-D Page 1
Summary of responses received from stakeholders on staff recommendations related to authorization of Community College Baccalaureates
Responses received from: Sam Houston State University (SHSU); Sul Ross University – Rio Grande (SRURG); The University of Texas at Dallas (UTD); Texas Tech University Health Sciences Center (TTUHSC); Texas Lutheran University (TLU); Austin Community College (ACC); Brazosport College (BC), The University of Texas System (UTS); Texas A & M System (TAMUS); Alvin College (AC); University of North Texas System (UNTS); South Texas College (STC); Texas Women’s University (TWU); and Tarrant County College District (TCCD). Copies of comments received are attached to this summary.
Nursing Comments
The availability of online RN to BSN programs offered by universities should be considered. Quality of program and faculty are already established at a university level. (SHSU & TWU) In terms of the nursing program, local hospitals need to be surveyed to see if they would support community colleges offering BA degrees. (SHSU)
This will not address the nursing faculty shortage. In fact, it will further complicate it as now additional faculty will be needed for the new programs. The criteria of pass rate on the NCLEX is not relevant to the RN to BSN degree. The Community Colleges need to forge partnerships with universities such as Southwest Texas Junior College has done with Sul Ross Rio Grande College to offer a connected, smooth BSN degree for students. (SRURG)
The manner for guaranteeing academic rigor should be prescribed through accreditation by the Commission on Collegiate Nursing Education (CCNE) as it is the industry standard for
guaranteeing said academic rigor in BSN programs. (TTUHSC)
If the recommendation from the Texas Higher Coordinating Board is to authorize only RN to BSN programs at specific community colleges, the Texas Board of Nursing only approves pre‐ licensure programs so there is some concern related to the oversight of the adherence to these standards of quality at the state level. Authorizing community colleges to offer the BSN will only make it more difficult for existing baccalaureate programs to find qualified faculty, and seriously risk damaging the quality of existing programs. (TLU)
The use of applied baccalaureate degrees for nursing runs counter to national trends and research on high‐standards education for the registered nurse practicing in our complex, dynamic healthcare environment. (TLU)
Diploma nurses with the RN certification should be included in the RN‐to‐BSN proposal. They will have the same requirements to demonstrate the prerequisite course work and therefore should be allowed to apply to the programs. (ACC)
RN to BSN programs are an efficient way to manage clinical sites and make best use of existing nursing faculty resources. (BC)
AGENDA ITEM VII-D Page 2
07/14 Recommend that the THECB require the community college AND program to have an 85% graduation rate and an 85% pass rate on the NCLEX. (UTS)
Staff Response to Nursing Comments
In response to the concerns for quality, staff is recommending one additional requirements for the approval of proposals for new RN to BSN degree programs. An existing associate degree nursing program must be accredited nationally or be seeking accreditation. The proposals will be evaluated on the same requirements that exist for general academic institutions; including faculty credentials, available resources, duplication of programs, and capacity of existing programs. One of the guiding principles of the recommendation is “Provide multiple pathways for a diverse population to earn an academic credential by expanding baccalaureate degree programs offered by public community colleges in a measured way to address workforce needs in a manner that is cost efficient, prevents unnecessary duplication of programs, and prevents undue competition between community colleges and universities”. The recommendation for the use of a graduation rate of 85% is a very high standard. Base on the 2012 graduation rates calculated by the THECB only 11 of the 74 programs at public institutions have a graduation rate at or above 85%. The nursing shortage reduction program uses a graduation rate of 70% as a threshold. Forty-two of the 74 programs met that standard.
Shortage of Faculty Comments
As the Community Colleges increase offerings, there will also be increased competitions for faculty resources. In addition to pass rate criteria, there should be stated criteria for having faculty with terminal degrees. In the past community colleges have reduced costs by heavily relying on adjunct faculty. Adding such programs to community colleges will make it even more difficult for all schools to recruit and maintain qualified faculty. (SHSU)
Staff Response to Shortage of Faculty Comments
In response to the concerns for faculty shortage, the timeline presented in the recommendation proposes a study of faculty resources to be completed prior the implementation of new program reviews. In addition new program proposals will be evaluated on the same requirements that exist for general academic institutions; including faculty credentials, and available resources. Competition Comments
As part of needs assessment, evaluate online options already in place at universities. Overall, numerous universities have invested in quality online programs. This investment is “wasted” if there is a proliferation of regional programs at Community Colleges. It may be difficult to establish a mechanism to decide on issues related to need and duplications. (SHSU)
We do not have any concerns about offering community college baccalaureate degrees that are targeted to fill applied, job-related needs in fields that are not adequately served at present. The concept strikes me as a good thing for Texas, provided the approved degree programs are carefully thought out, well supported, and of high quality. Like all educational issues in Texas, spreading limited resources too thinly can be counterproductive, but so long as the proposed programs are carefully crafted, there may be real value. My only suggestion is to use the word
AGENDA ITEM VII-D Page 3
07/14 "applied" to describe the degree programs everywhere. I think this is consistent with the spirit and helps to differentiate these degrees. (UTD)
Universities now have bachelor degrees that track students completing an associate of applied science degree. Many of them are on line making them accessible to any Texas residents. Formula funding is not complete, so this will further erode the higher education funding situation. (SRURG)
We recommend the Legislature consider incentives such as those created in the 83rd
Legislature to promote new and expanded GME programs within the State. These incentives would encourage all public institutions with nursing programs to enter into more articulation agreements with community colleges. (TTUHSC)
Staff Response to Competition Comments
In response to the concerns for counterproductive competition, we defer to the guiding principle, “Before expanding baccalaureate degree programs at public community colleges, ensure that current programs are fully utilizing existing resources.” The recommendation also encourages partnership proposals for new applied science degrees.
Student and Tax Payer Concerns Comments
Funding mechanisms are very different with community colleges who are provided a local property tax base not available to universities. In the long run local tax payers will pay twice to support baccalaureate programs in the State, a disadvantage to those taxpayers. (SHSU) Offering baccalaureate degrees at Community College will increase cost to students and shift state funds away from existing programs. (UNTS)
The increased need for qualified faculty may be a hidden cost for community colleges. Nursing and engineering faculty tend to be high-priced professionals. The financial costs to add such faculty may strain the reserves of the community college and necessitate higher tuition rates. (SHSU)
Staff Response to Student and Tax Payer Comments
In response to the concerns of financial costs for student and taxpayers; the recommendations call for the THECB to develop a basis for determining duplication of programs – including factors such as commute time, capacity, delivery method, and hours of operation. In addition, the recommendations states that current rules for new program approval must be met
including: unnecessarily program duplication, adequate faculty resources, good curriculum design, demonstrated workforce need, a critical mass of qualified students available, and adequate financing. There is a concern for students having an affordable path to obtain a bachelor degree. Based on the experience of the three colleges currently offering applied bachelor degrees the lower and upper division costs have risen at a comparable rate to other community colleges. The cost to the student for the BAT degrees is significantly less than available at public universities in the state.
AGENDA ITEM VII-D Page 4
07/14 Duplication & Inefficiency Comments
If community colleges are granted permission for baccalaureate degrees, will the need for associate’s degree continue or will there be a more streamlined 4-year route to degree. This may force colleges to create extra courses to satisfy the needs of both associate and
baccalaureate degree tracks. (SHSU)
THECB’s recommendations do not mention the costs of ongoing operational expenses nor does it address costs related to curriculum issues. To address this cost and to avoid exacerbating shortages of faculty with graduate and terminal degrees, we request your recommendations encourage the systematic and concentrated use of articulation agreements to address expansion needs. (TTUHSC)
Applied baccalaureate degrees offered at Community Colleges (CC) be required to meet the same accreditation, licensure, certification and financial adequacy requirement as General Academic (GA) institutions must meet. (TAMUS)
The expansion of applied baccalaureate programs at community colleges has implications in terms of quality and cost. (UTS)
Suggest adding an investigation of equitability when considering duplication of programs. (ACC) The hallmark of community colleges is responsiveness and the ability to do so in response to local and regional workforce demands. If the process is dependent on a biennium study in order for colleges to meet needs, then that changes their ability to respond in a timely manner. If the ability to move forward is built on “looking backward” to prove need, then that nimbleness will be lost. (BC & STC)
Currently it is not necessary to complete an applied associate’s degree to pursue the bachelor of applied technology degree. (STC)
Staff Response to Duplication & Inefficiency Comments
In response to the concerns of duplication and inefficiency, the recommendation states that current rules for new program approval must be met including: unnecessarily program
duplication, adequate faculty resources, good curriculum design, demonstrated workforce need, a critical mass of qualified students available, and adequate financing. The RAND study
identified the process that THECB is recommending to identify workforce needs and specifically the need for applied baccalaureate degree programs. The process as described in the study will take into consideration statewide, regional and local workforce needs. Staff proposal
recommends that the review and approval of applied bachelor degrees be the same for both universities and community colleges. The recommendation in the proposal submitted to CAAP has been modified to not require the student to have completed the applied associate’s degree. Other Comments
In general agreement with the Staff Recommendations regarding participation and utilization of existing affiliation agreements and partnerships, we currently utilize these extensively, and will
AGENDA ITEM VII-D Page 5
07/14 continue to do so as part of a multipronged solution to the need for Bachelors prepared nurses in our region. (ACC)
I have just relocated from the state of Florida where all the community colleges were granted the opportunity to offer baccalaureate degrees. There was some concern at first that the role of the community college would be marginalized, the college would lose sight of its mission, and that the college’s focus would move to the baccalaureate degree. That did not happen. Another concern was that we would draw students from the area universities. The data did not indicate this. The average age of our baccalaureate students was 37. Additionally, we did not offer programs that competed with the universities. The programs offered were workforce oriented and required the completion of an associate’s degree. There were some issues with regard to which associate’s degree could be used for admission into any given program so that needs to be spelled out. (AC)
Now that the Coordinating Board is preparing to adopt recommendations related to the RAND Study, it may be time to revisit the legislative statute that limits offering no more than five degree programs at any time. I encourage the Coordinating Board to consider a
recommendation that permits the Coordinating Board to determine the number of programs offered based on individual program approval. (STC)
Nursing has a significant current demand. Expectations for continuing demand and increasing shortages are great. With TCC’s current program in nursing and the partnerships with Tarleton State University, Texas Tech and the University of Texas at Arlington, we provide a strong, much needed pipeline to already existing BSN programs. (TCCD)
Staff Response to Other Comments
There will be additional study and discussion of the finding of the RAND study that will follow the submission of the study to the legislature. The issues of program limitations, university partnerships, duplication and quality criteria are address in the timeline presented with staff recommendations.
July 7, 2014 Gary Johnstone
Texas Higher Education Coordinating Board [email protected]
Dear Mr. Johnstone:
Texas Tech University Health Sciences Center is pleased to have the opportunity to review the Texas Higher Education Coordinating Board (THECB) Committee on Affordability, Accountability and Planning’s draft legislative recommendations regarding the potential expansion of community college baccalaureate programs in Texas.
Herein below you will find our comments and recommendations:
We agree meeting unmet workforce needs should be a priority. In meeting this need, we believe the quality of baccalaureate programs, in this case BSNs, should not be overlooked.
It is noted in the THECB’s recommended principles that baccalaureate degrees should be expanded in a manner that maintains or increases academic rigor. The manner for guaranteeing academic rigor should be prescribed through accreditation by the Commission on Collegiate Nursing Education (CCNE) as it is the industry standard for guaranteeing said academic rigor in BSN programs.
Quality should not be sacrificed in an effort to provide greater access to BSN programs such as
RN-to-BSN. To ensure quality, any new nursing baccalaureate program at a community college must be CCNE accredited. This accreditation insures that a BSN program includes all the essential elements of nursing education that distinguish nursing education leading to the BSN degree.
Should community colleges be allowed to offer RN-to-BSN programs without accreditation, we believe the BSN degree will be watered-down to the equivalency of an Associate’s Degree in Nursing (ADN).
The Institute of Medicine (IOM) Future of Nursing report which calls for 80% of nurses to be BSN
prepared by 2020 presupposes that the rigor and standards of the BSN remains high. Research which
has shown that care outcomes are far better when care is delivered by BSN nurses is also based on those
standards which can only be confirmed through CCNE accreditation.
Of additional concern is the fact that community college RN-to-BSN programs would not allow for
Inter-professional Education (IPE). IPE opportunities are expected in the education of the future healthcare workforce and are required by national accrediting bodies such as Southern Association of Colleges and Schools (SACS). Providing IPE is a key component towards preparing BSNs for the growing role of nursing in the healthcare workforce.
3601 4th Street STOP 6258 | Lubbock, Texas 79430-6258 | T 806.743.2900 | F 806.743.2910 Office of the President
Mr. Gary Johnstone July 7, 2014 Page 2 of 2
THECB’s recommendations do not mention the costs of ongoing operational expenses nor does it address costs related to curriculum issues. To address this cost and to avoid exacerbating shortages of faculty with graduate and terminal degrees, we request your recommendations encourage the systematic and concentrated use of articulation agreements to address expansion needs. TTUHSC has 20 articulation agreements within the state.
We particularly recommend the use of concurrent enrollment articulation agreements. TTUHSC was one
of the first universities in the state to offer such an agreement whereby TTUHSC guarantees students’ admission as long as they complete their first two years at the collaborating community college and meet
certain requirements. TTUHSC has concurrent articulation agreements with Austin Community College, Collin Community College and McLennan Community College.
We recommend your report suggest the use of incentives by the state to encourage the expansion of articulation agreements between universities and community colleges. Incentives would be far less expensive than BSN CCNE accreditation and much higher operational costs for community colleges.
Currently TTUHSC has restricted some aspects of its growth due to the limited supply of qualified faculty
with graduate and terminal degrees. Consequently, TTUHSC currently undertakes controlled strategic
growth within the RN to BSN program. Our strategic growth calls for a 20% increase each year. With this
growth pattern TTUHSC can accommodate students more quickly with existing infrastructure and faculty and at a cost that we anticipate would be less than the efforts of community colleges.
TTUHSC also does not receive reimbursement for any expansion until after the legislature meets and passes the budget for the next biennium. Universities need upfront funding to hire additional faculty and provide greater capacity to enter into more articulation agreements with community colleges. We recommend the Legislature consider incentives such as those created in the 83rd Legislature to promote new and expanded GME programs within the State. These incentives would encourage all public institutions with nursing programs to enter into more articulation agreements with community colleges.
These partnerships are a win-win and will do the following:
1) Increase capacity at nationally accredited baccalaureate programs within the state 2) Save on cost of starting new baccalaureate nursing programs
3) Ensure quality
4) Increase accessibility to BSN programs for first generation, minority and under-served
students
5) Promote greater partnerships among universities and community colleges On behalf of TTUHSC, thank you for the opportunity to provide comments.
Sincerely,
Tedd L. Mitchell, M.D. President
Texas Tech University Health Sciences Center
cc: Michael L. Evans, Ph.D., RN, FAAN
Texas Tech University: Comments on Staff Recommendations Related to Authorization of Community College Baccalaureates
Key Consideration
Texas Tech University has serious reservations about community college delivery of baccalaureate degrees. The primary mission of community colleges is to provide general education for transfer to four year colleges and universities, and to provide workforce training programs that particularly meet local workforce needs. Baccalaureate degrees, whether
workforce directed or more general, require faculty prepared above that level for delivery of the full program. It is the mission of four year colleges and universities to prepare these individuals among many other baccalaureate recipients. Four year colleges and universities further help to extend the impact of community colleges through 2+2 articulation agreements and the offering of their degree programs on community college campuses, both approaches providing
community college students who need them more ready access to baccalaureate completion opportunities.
More universities are beginning to offer more workforce directed baccalaureate degrees such as the Bachelor of Applied Arts and Sciences (BAAS) degree. These programs can expand the partnerships between community colleges and four year institutions that aim to address both local and wider employment opportunities. If community colleges in Texas are to offer baccalaureate degrees, these should be limited to vocational degrees such as the
Bachelor of Technology (BAT). The BAT degree can be planned to conform to specific industrial and workforce needs in an area.
It is necessary to make sure that there are (remain) clear distinctions between what community colleges do and what universities do. Our stakeholders may want to consider that in order for a community college to offer a baccalaureate degree, the institution must first submit a proposal that includes a documented “community or surrounding area workforce need.”
Because community colleges are expected to reflect and address the workforce needs of their districts, as well as provide lower-division academic transfer-oriented programs, it seems as if any expansion of baccalaureate credentials offered through community college districts should be tied directly to the needs of the taxing district -- combining concern for cost/resourcing with concern for mission disambiguation.
Comments Regarding “Recommendations are based on the following principles:”
1) Regarding the first bulleted principle:
Comment: There is little actual data available supporting the cost effectiveness of baccalaureate degrees currently offered at community colleges in comparison with similar programs at public universities. A thorough study should be done to determine how community college baccalaureate degrees compare to university degrees in actual cost, including lost earnings for length of time to degree.
TTU 7-11-2014 Page 2 of 3
2) Regarding the second and third bulleted principle:
Comment: Because community colleges are funded in part by local taxing districts, the implementation of any baccalaureate degree at a community college should directly address workforce need in that taxing district, so that taxpayers are not paying for curricular offerings that do not directly benefit their communities.
3) Regarding the fourth bulleted principle:
Comment: The shortages of qualified faculty in certain fields are problems that should be solved in advance of the approval of degree program authority, especially considering the earlier principle that seeks to avoid “undue competition” between community
colleges and universities. Ample qualified faculty may be available for current community college baccalaureate degrees, but as the numbers of these degree opportunities
increase, so will the need for more qualified faculty. Universities will be providers of these additional faculty, a factor to include in assessment of costs for community college baccalaureates.
Comments Regarding Staff Recommendations Related to Authorization of Community College Baccalaureates:
Regarding Overall Board Requirements
Overall Board Requirement 1:
Comment: The phrase “appropriate sections of the required SACSCOC level change” is unclear. What is meant by “appropriate sections” and what would be considered sufficient documentation of the approval of a level change?
Overall Board Requirement 2:
Comment: Community college catalogs routinely display curricular information regarding academic (transfer) degree programs as if they offer discipline-specific majors. A program inventory for academic associate degree programs (AA and AS) similar to those currently used to inventory the AAS offerings at colleges and the programs at all levels for universities should be a requirement prior to any further approval of baccalaureate level degrees at colleges, and colleges should be held accountable for the quality and productivity of those programs, should they be approved in the future, in a manner that is identical to what is currently in place for universities.
Comments Regarding Recommendations Specific to Applied Science:
Regarding the recommendation “Each biennium, conduct a process …”
Comment: Universities have funding streams and missions that are shared statewide, but community college taxing districts impose specific financial obligations upon the taxpayers in the specific district. If need for a baccalaureate program is determined to be statewide rather than local/regional, encourage universities to deliver the baccalaureate program, including transfer partner agreements with regional community colleges, via face-to-face and/or online options, before authorizing delivery of the baccalaureate program at community colleges, in order to
TTU 7-11-2014 Page 3 of 3
spare regional/district taxing districts/taxpayers from bearing the expense of fulfilling statewide needs.
Comments Regarding Timeline for Implementation:
Comment: Generally agree with the four goals for study during FY 15, but recommend using conclusions from that year of study to supplement and possibly modify recommendations from the RAND study.
Comment: Generally agree that study should be restricted to types of applied baccalaureate degrees, and agree that criteria and definitions for BAAS, BAT, and BAS would be useful for further consideration of the issues.
1
Johnstone, Gary
From: Liedtke, Amy <[email protected]> Sent: Wednesday, July 16, 2014 5:28 PM
To: Johnstone, Gary
Cc: Neely, Robert
Subject: Community College Baccalaureate Study Recommendations
Mr. Johnstone:
From Texas Woman’s University regarding Community College Baccalaureate Study Recommendations:
•The first comment TWU would like to offer is regarding approval ofonly the RN to BS degree at community colleges. This degree option is widely available at universities across the state in fully online format. We believe there is adequate capacity at existing 4-year institutions, and certainly TWU. Approval of this recommendation would only exacerbate competition among institutions for faculty and clinical placement sites,
which is unnecessary given available options already in place.
• Second, further clarification of the THECB’s intentions regarding BAS, BAT, and BAAS degrees seems necessary, and would be helpful to both universities and community colleges.
• In general, TWU believes that the principles THECB staff enumerate are appropriate for assessing whether a baccalaureate program should be approved at a community college.
Thank you.
Amy Liedtke
Executive Assistant to the Chancellor and President
Texas Woman’s University
Ph: (940) 898-3207
Fx: (940) 898-3216
Email: [email protected]
Gary W. Johnstone
Deputy Assistant Commissioner
Planning and Accountability
Texas Higher Education Coordinating Board 1200 East Anderson Lane
Austin, Texas 78752 July 8, 2014 Dear Mr. Johnstone:
This letter is in response to the Memorandum dated July 1, 2014, related to the Community College Baccalaureate Study Recommendations. Texas Lutheran University supports the concept of creating opportunities to establish appropriate workforces in critical need areas for our diverse populations. The principles that the staff from the Texas Higher Education Coordinating Board based their recommendations to authorize community college baccalaureates are vital to the success of such opportunities. Since Texas Lutheran University is at the forefront of creating innovative strategies to expand the workforce, especially for disadvantaged groups in specified rural areas of our state, we have some concerns related to the authorization of community college baccalaureates specifically for nursing
programs.
The first concerns the will‐understood shortages of qualified faculty for BSN programs and the need for adequate clinical experiences for students. There are clear guidelines that must be adhered to by the Texas Board of Nursing and national accrediting agencies related to qualified faculty and type of clinical experiences for baccalaureate nursing education programs. The Texas Board of Nursing through the
Differentiated Essential Competencies of Graduates of Texas Nursing Programs (2010) clearly documents
the appropriate differentiation for the various types of nurses in Texas with clear guidelines for educational programs for each of these groups. In addition, the Commission on Collegiate Nursing Education has standards for baccalaureate and master education for nursing programs with specific outcome expectations for graduates and faculty of these programs. If the recommendation from the Texas Higher Coordinating Board is to authorize only RN to BSN programs at specific community colleges, the Texas Board of Nursing only approves pre‐licensure programs so there is some concern related to the oversight of the adherence to these standards of quality at the state level. Authorizing community colleges to offer the BSN will only make it more difficult for existing baccalaureate programs to find qualified faculty, and seriously risk damaging the quality of existing programs.
It is vital to ensure that there are appropriate resources to establish RN to BSN programs in the state that meet quality standards. These programs still require qualified faculty and clinical experiences so difficulties may develop related to existing programs that are expanding to meet student demands. . We endorse the “stackable credentials” model promoted by the American Association of Community Colleges (2014) in their document, Empowering Community Colleges to Build the Nation’s Future, works well with specific institutions in our state concentrating on the sequence of multilevel, industry‐
recognized credentials and/or certification as well as seamless education and career systems. Partnerships between community colleges and universities allow students to stay in one location but obtain the education that is appropriate for students and their identified professional career. These collaborative support structures allow institutional efficiency and strengthen services to students in community colleges and universities while not impinging on available resources. The concept of
ensuring the establishment of partnerships with articulation/transfer agreements and distance learning options are vital to the success of the identified recommendations and would allow existing programs that meet appropriate standards to serve geographic areas of highest need.
Finally, the use of applied baccalaureate degrees for nursing runs counter to national trends and research on high‐standards education for the registered nurse practicing in our complex, dynamic healthcare environment. The American Association of Colleges of Nursing Fact Sheets, The Impact of
Education on Nursing Practice (2014) and Creating a More Highly Qualified Nursing Workforce (2013),
indicate nurse executives, federal agencies, the military, leading nursing organizations, health care foundations, magnet hospitals, and minority nurse advocacy groups all recognize the unique value that baccalaureate‐prepared nurses bring to the practice setting. The evidence presented in these
documents strongly supports the importance of higher‐level education that promotes effective critical thinking, clinical judgment, and safety and cultural competencies for today’s registered nurse. A degree program consisting of liberal arts, academic, and professional coursework provides both the breadth and specialization for students to compete in today’s high acuity, complex, and dynamic healthcare environment. Institutions of higher learning that focus on this type of baccalaureate education are built on the foundation of developing well‐rounded students who are problem‐solvers, adaptable and able to think outside the box by applying concepts, skills and knowledge in and outside the classroom.
For these reasons, we have concerns that the proposed, well‐intentioned program may have unintended consequences of lowering the quality of nursing education in Texas, and actually
Thank you for the opportunity to speak to this proposal.
Sincerely,
Stuart Dorsey Dr. Kathie Aududell
President Director of Nursing
Texas Lutheran University Texas Lutheran University
1
Johnstone, Gary
From: Paul Sorrels <[email protected]> Sent: Wednesday, July 02, 2014 11:20 AM
To: Johnstone, Gary
Subject: community College baccalaureate
Dear Gary,
About the proposal, I can see many additional problems with limited benefit for only a handful of community colleges.
Frist, many universities now have bachelor degrees that track students completing an associate of applied science degree. Many of them are on line making them accessible to any Texas residents.
Second, current formula funding is not complete, so this will further erode the higher education funding situation.
Third, regardless of what is said, this process will not address the nursing faculty shortage. In fact, it will further complicate it as now additional faculty will be needed for the new programs.
The criteria of pass rate on the NCLEX is not relevant to the RN to BSN degree anyway. As stated in the proposal it is not a factor since every BSN completion program requires RN licensure before admission. Thus, the NCLEX will not be even related to quality of the BSN completion programs. If what is meant that before a CC can have a BSN degree they need to meet this NCLEX pass rate, then it is also irrelevant as the numbers listed are the minimums now required to maintain an ADN program by the Board of Nursing, so again it is irrelevant.
Finally, there are many BSN completion programs, the problem is that community college nursing faculty see the hand writing on the wall that the nursing profession is quickly moving to the BSN and the minimum degree and that many ADN programs may become obsolete. What these CC need to do is forge partnerships with universities such as Southwest Texas Junior College has done with Sul Ross Rio Grande College to offer a connected, smooth BSN degree for students.
Finally, if approved, it is inevitable certain community colleges will return requesting even more expanded bachelor degree authority. The legislature during the last session seemed to indicate that they felt the State of Texas already has too many universities, so this would simply press the matter further.
Paul
J. Paul Sorrels, Ph.D. Associate Provost/Dean Sul Ross - Rio Grande College
ASTC
South Texas CollegeOff1ce of the Pres1dent
3201 W Pecan Blvd. • McAIIe'l, TX 78501 July 16, 2014
Susan Brown
Assistant Commissioner, Planning and Accountability Texas Higher Education Coordinating Board
P. 0. Box 12788 Austin, Texas 78711 Dear Susan: P.O. Box 9701 McAllen, TX 78502-9701 (956) 872-8366 rox (956) 872-8368
Thank you for the opportunity to respond to the Coordinating Board's recommendations m
response to the RAND Community College Baccalaureate Study.
While I concur with the recommendations that have been developed, I do have a couple of specific concerns and they are as follows:
LEGISLATIVE RECCOMENDA TION (Slide 2)
"All new applied baccalaureates must be based on initial completion of an Applied Associate 's
degree. "
Currently, it is not necessary to complete an Applied Associate's degree in order to pursue the
Bachelor of Applied Technology or Bachelor of Applied Science. It is common, for students with an Associate of Arts or Associate of Science to enter the baccalaureate programs offered by South Texas College.
RECOMMENDATIONS SPECIFIC TO APPLIED SCIENCE (Slide 4)
"Each biennium, conduct a process to select 3-5 disciplines to study which includes participation from institutions and the TWC and local worliforce development boards"
My concern is that statewide agreement on 3-5 disciplines will be restrictive to local needs. Deep South Texas may have unique needs that do not fit within the 3-5 disciplines established at a
statewide level. I recommend that the disciplines be locally or regionally determined.
"Duplication of programs within a one hour commute is not allowable unless institution can
show program design differences related to capacity, delivery method, and/or hours of operation that are not available through existing programs. "
A one hour commute can mean very different distances for different parts of the state. The need
for a duplicative program may exist even if the commute is 45 minutes long.
TIMELINE FOR IMPLEMENTATION (Slide 5)
"The RAND study that was performed for the Coordinating Board established varying levels of need in fire science, computer and information technology, nursing, and science technology
Susan Brown July 16, 2014 Page 2
Restricting the disciplines for the baccalaureate to the four identified disciplines is too restrictive and prohibits a timely response to local workforce needs.
Additionally, the statement " . . . can be used for the first biennium" is confusing. What are the dates ofthe first biennium? Does this limit the development of new degrees to these areas for the next two years? This timeline seems unnecessarily restrictive and prohibits development of programs in different disciplines for at least another 2 years.
While South Texas College began the pilot program to offer a baccalaureate degree in 2003 and now has four degree programs with 586 graduates as of May 2014, the legislative imposed limit for offering community college bachelors of applied science degrees remains at five. Because of these legislative restrictions, South Texas College is now faced with limited opportunities for expansion and not being able to respond to the needs of the region and the requests for additional applied baccalaureate programs.
I continue to be approached by businesses and industry leaders urging the College to develop more baccalaureate programs to help increase the talent pool for an expanded professional workforce and the professional development needs of current employees; however, legislative restrictions curtail the College's ability to respond to these requests.
Now that the Coordinating Board is preparing to adopt recommendations related to the RAND Study, it may be time to revisit the legislative statute that limits offering no more than five degree programs at any time. I encourage the Coordinating Board to consider a recommendation that permits the Coordinating Board to determine the number of programs offered based on individual program approval.
Based on South Texas College's experience with developing, and now offering four applied baccalaureate degrees, the rigor of the Southern Association for Colleges and Schools accreditation process would serve as a determinate factor in deciding which community colleges may have the ability to pursue and achieve Level II accreditation. The rigor of the accreditation process would provide the limitations and controls necessary for expanding the opportunity for additional community colleges to offer these premier applied baccalaureate degrees.
Thank you for the opportunity to provide input on the recommendations you are bringing forward for consideration by the Coordinating Board. Please know I am available if you have questions or if you wish my testimony.
Respectfully yours,
~
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~
. .B.A., Ed.D.
Cc: Dr. Anahid Petrosian, Interim Vice President for Academic Affairs Dr. Ali Esmaeili, Dean for Math, Science and Bachelor Programs Ms. Laura Boyer Talbot, Director of Curriculum and Student Learning
---Original Message---
From: Daniel, David E. [mailto:[email protected]]
Sent: Thursday, July 03, 2014 9:08 AM To: Hartman, Marilyn
Cc: Gardner, David Dr.; Wildenthal, Bryan; Snellings, Judy
Subject: RE: Comments on Community College Baccalaureate Study Dear Ms. Hartman,
Dr. Hobson Wildenthal (Provost) and I have reviewed the materials that you sent.
We do not have any concerns about offering community college baccalaureate degrees that are targeted to fill applied, job-related needs in fields that are not adequately served at present. The concept strikes me as a good thing for Texas, provided the approved degree programs are carefully thought out, well supported, and of high quality. Like all educational issues in Texas, spreading limited resources too thinly can be counterproductive, but so long as the proposed programs are carefully crafted, there may be real value.
My only suggestion is to use the word "applied" to describe the degree programs everywhere. I think this is consistent with the spirit and helps to differentiate these degrees.
Thank you for giving us the opportunity to comment. Best regards,
David
___________________________ David E. Daniel
President
University of Texas at Dallas 800 West Campbell Road Richardson, TX 75080 Phone: (972) 883-2201 [email protected]
Staff Recommendations Related to Authorization of
Community College Baccalaureates
Recommendations are based on the following principles:
•
Provide multiple pathways for a diverse population to earn an academic credential
by expanding baccalaureate degree programs offered by public community colleges
in a measured way to address workforce needs in a manner that is cost efficient,
maintains or increases academic rigor, prevents unnecessary duplication of
programs, and prevents undue competition between community colleges and
universities;
•
Before expanding baccalaureate degree programs at public community colleges,
ensure that current programs are fully utilizing existing resources, and
partnerships, articulation agreements and distance learning options have been fully
explored and are not viable alternatives to expansion.
•
Expand the Board’s evaluation of workforce need for community colleges offering
baccalaureate degrees by consulting with the Texas Workforce Commission on
current and projected local and state workforce needs; and
•
Address the shortage of faculty in certain fields like nursing and the shortage of
Legislative Recommendation
1.
Establish the same legislative requirements for all new applied baccalaureates, at a university
or a community college.
2.
All new applied baccalaureates must be based on initial completion of an Applied Associate’s
degree.
3.
New applied baccalaureates should be approved after a workforce need has been
demonstrated, partnership possibilities have been explored, and consideration has been
given to student costs.
4.
Only community colleges that meet the current statutory criteria of $2.5 billion in property
valuation should be eligible to offer baccalaureates. Currently 9 community college districts
do not meet this $2.5 billion threshold as they were grandfathered in when the statute was
developed.
Related
Comments and
Excerpts and
Comments from the RAND Study
•
Many institutions commented that
the process should be the same for
all institutions.
•
The currently authorized applied
baccalaureates offered at community
colleges and universities should be
required to meet all the same
standards.
•
Nationally, one of the more
commonly adopted policies states
use to restrict program development
is to require that all community
college programs be built on top of
existing associate programs.
•
This will allow the Coordinating Board
to provide guidance to colleges going
through this process.
•
Overall, authorize community college
baccalaureate expansion with
restrictions.
Comments on Recommendation:
• Past experience with program approval for applied baccalaureate degrees has not been consistently applied across Texas university and community college sectors. For example, community colleges were required to meet program approval rules that applied to new engineering programs rather than those that applied to similar degrees at General Academic Institutions. The perception resulting from this disparate treatment may be difficult to overcome so attention should be paid to working “in partnership” with colleges as they move through the approval process.
Staff Recommendations Related to Authorization of Community College Baccalaureates
2
Overall Board Requirements
1. For initial baccalaureates, institutions must submit appropriate sections of the required
SACSCOC level change to the Coordinating Board along with any other information required by
the Board.
2. The current rules for new program approval must be met including: unnecessarily program
duplication, adequate faculty resources, good curriculum design, demonstrated workforce
need, a critical mass of qualified students available, and adequate financing
Recommendations Specific to Nursing
•
Determine under what conditions existing programs would be able to expand capacity before
authorizing new programs, make sure that resources are utilized most efficiently.
•
Given current clinical space and faculty shortages, evaluate if and how additional program will
affect current programs.
•
Consistent with the overall recommendation of having baccalaureates based on initial
completion of an Associate’s degree, authorize only RN to BSN programs.
•
Start with a limited number of programs in geographic areas of highest need.
•
To ensure quality adopt the following criteria: a) meet a minimum 70 percent nursing
graduation rate; b) maintain an 80 percent pass rate on NCLEX (National Council Licensure
Examination) over three years.
Related Excerpts and Comments from the
RAND Study
•
Addresses the concern about quality
raised by universities.
•
Study the lack of nursing faculty and
determine how community colleges
would address the issue.
•
Start in metropolitan areas with the
largest need as long as the faculty and
clinical issues have been addressed.
Staff Recommendations Related to Authorization of Community College Baccalaureates
•
Comments on Recommendation:
•
RN to BSN programs are an efficient way to manage clinical sites and make best use of existing
nursing faculty resources.
•
Determination of need should start at the local level and be based on multiple considerations as
presented by the College , including capacity, workforce demographics, and capacity in existing
programs. It will be difficult to define metropolitan versus suburban and a host of problems will
accompany that kind of “artificial “ attempt to come up with a definition.
Recommendations Specific to Applied Science
Each biennium, conduct a process to select 3-5 disciplines to study which includes participation
from institutions and the TWC and local workforce development boards:
•
Survey all community colleges for suggestions on which fields to study.
•
Engage the Community and Technical College Leadership Council to narrow the fields.
•
Include other stakeholders in the process, as appropriate.
•
Use the needs assessment process developed by RAND, in conjunction with TWC, workforce
boards, and industry representatives to narrow selection to three to five applied science
disciplines.
•
Need can be determined to be: a) none; b) local/regional; or c) statewide.
Related Excerpts and Comments from the
RAND Study
•
Allow a staged opening of
baccalaureate applied science
degrees once a workforce need has
been established.
•
Take into account the amount of
need in programs such as fire science
to request proposals for a minimal
number of on-line programs that
could fulfill a statewide need.
•
Many universities and community
colleges are currently partnering to
improve students’ access to
bachelor’s degrees through
articulation agreements or teaching
university upper-division courses at
community college campuses.
•
Duplication of program standards will
be the same for both community
colleges and universities.
•
Partnerships will be encouraged for
cost and efficiency reasons.
Staff Recommendations Related to Authorization of Community College Baccalaureates
Comments on Recommendation:
•
Duplication is not always something you want to avoid. For example, there are many degrees
that are appropriately duplicated across colleges and universities. A good example is
workforce programs in areas such as Process Technology or Nursing. To avoid the problem
that is being created by casting all duplication as not allowable, focus on the proof of local and
regional need.
4
Once the level of need has been established, the Coordinating Board will accept proposals that
would fulfill the need within discipline specific criteria. Proposals will be accepted from community
colleges, partnerships, and universities and must meet the following conditions:
•
To ensure quality, fields with a licensure component must have an acceptable pass rate
dependent upon licensure board input.
•
Institution must demonstrate availability of qualified faculty.
•
Duplication of programs within a one hour commute is not allowable unless institution can show
program design differences related to capacity, delivery method, and/or hours of operations that
are not available through existing programs.
Timeline for Implementation
September 2014 – August 2015
•
CB Staff work with all institutions to develop clear definitions of the BAAS, BAT, BAS (RAND
Recommendation).
•
Study the constraints created by faculty shortages on nursing programs at all levels and work on
developing seamless transitions.
•
Work with all institutions to develop criteria for defining “workforce need” at the local or
regional level; include RAND workforce need study recommendations in the process.
•
Develop a basis for determining duplication of programs – including factors such as commute
time, capacity, delivery method, and hours of operation.
Related Excerpts and Comments from the
RAND Study:
•
Texas currently has three different
types of applied baccalaureate
degrees, and there is confusion about
the distinctions between different
degree types.
•
As the applied baccalaureate expands
in the state of Texas, students and
employers would benefit from a well
defined set of degree types and a
clear understanding of the student
and workforce needs that are met by
a degree to ensure some consistency
and transparency across programs.
•
Working with TWC and local
workforce development boards to
make sure that workforce needs are
prioritized.
•
Make clear to all involved what will
be required to determine need.
Staff Recommendations Related to Authorization of Community College Baccalaureates
Comments on Recommendation:
The hallmark of community colleges is responsiveness and the ability to do so in response to local
and regional workforce demands. If the process is dependent on a biennium study in order for
colleges to meet needs, then that changes their ability to respond in a timely manner. If the ability
to move forward is built on “looking backward” to prove need, then that nimbleness will be lost.
That would not be a good thing for the state of Texas and the important role that community
colleges play in economic development.
5
September 2015
•
The RAND study that was performed for the Coordinating Board established varying levels of
need in fire science, computer and information technology, nursing, and science technology
management can be used for the first biennium.
•
Work with the Community and Technical College Leadership Council and survey all community
colleges to determine three to five disciplines to study.
•
Collaborate with TWC and local workforce boards to begin the review cycle that will determine if
Comments on Recommendation: • Austin Community College is in general agreement with the Staff Recommendations shown above. Regarding participation and utilization of existing affiliation agreements and partnerships, we currently utilize these extensively, and will continue to do so as part of a multi‐ pronged solution to the need for Bachelors prepared nurses in our region. We also believe that we can implement an RN‐to‐BSN program without negatively impacting faculty recruitment or clinical placements for other programs in our region. ACC has a long history or partnership with regional health systems to supply appropriate faculty and clinicals. The proposed clinical simulation center at Highland will also be a significant resource in meeting clinical requirements. • Diploma nurses with the RN certification should be included in the RN‐to‐BSN proposal. They
will have the same requirements to demonstrate the prerequisite course work and therefore
should be allowed to apply to the programs.
• On maintaining an 80% NCLEX pass rate, this is a bit unclear. Since all candidates for the
program are already RNs, they will already have their certification, and there will be no NCLEX
pass rate for the RN‐to‐BSN program. If this means that the ADN program affiliated with the
community college granting the RN‐BSN should maintain this pass rate, then we concur.
