DHE Did Not Meet With the Commonwealth Commitment Advisory Board To Review the MassTransfer Commonwealth Commitment Program.

If DHE does not ensure that it meets with CCAB to review all aspects of the MassTransfer Commonwealth Commitment Program, the program may not operate effectively because necessary or recommended changes are not identified and made.

Overview

DHE did not meet with the Commonwealth Commitment Advisory Board (CCAB) at least annually to review all aspects of the MassTransfer Commonwealth Commitment Program. These aspects include cost structures, program operations, implementation, accreditation, and licensure-related issues.

Changes in critical components of the program or higher education environment, such as state funding availability, college or university accreditation, and degree pathway¹ availability, happen frequently. If DHE does not ensure that it meets with CCAB to review all aspects of the MassTransfer Commonwealth Commitment Program, the program may not operate effectively because necessary or recommended changes are not identified and made.

Authoritative Guidance

The “Commonwealth Commitment to College Access, Affordability, and Completion” memorandum of understanding states,

Annually, a working group of campus and DHE representatives will meet to review all aspects of the program, including cost structures, program operations, implementation, accreditation and licensure related issues, and will recommend operational changes or adjustments as deemed necessary.

This requirement is reiterated in DHE’s MassTransfer Procedures Manual:

1. At least once annually, the Department will convene a working group of campus and Department representatives to review all aspects of the program, including cost structures, program operations, implementation, accreditation and licensure-related issues.
2. This working group will recommend to the Department operational changes or adjustments as deemed necessary.
3. The campus representatives to this working group will be known as the Commonwealth Commitment Advisory Board.

Reasons for Issue

DHE officials told us in an email on November 29, 2021 that CCAB had been “absorbed by the MassTransfer statewide group”² and that they “did not identify a need to update the Board [of Higher Education, or BHE] on matters related to MassTransfer during the audit period.” DHE could not provide evidence that CCAB had been formally disbanded or its responsibilities transferred to a different group.

Recommendations

1. DHE should meet with CCAB at least annually to review the MassTransfer Commonwealth Commitment Program and make recommendations about its improvement.
2. Alternatively, if DHE’s commissioner has approved the disbanding of CCAB and changes to the nature and frequency of reviews, DHE should update the MassTransfer Procedures Manual to accurately identify the group responsible for the review of the MassTransfer Commonwealth Commitment Program and the frequency and nature of the review.

Auditee’s Response

The Department welcomes comments and ideas on ways it can continuously improve program administration and evaluation. The Department is also in agreement in principle of the need to regularly evaluate programs and their effectiveness.

To this point, the Department has recently evaluated MassTransfer, including the Commonwealth Commitment program, through an Equity Agenda related review, including conducting interviews with campus administrators and institutional transfer counselors and evaluating quantitative institutional outcomes. The MassTransfer Policy and Implementation Guidelines are reviewed and revised regularly, in partnership and with input from institutional stakeholders. The comprehensive and collaborative nature of the program has gained it state and national recognition. For example, a typology framework developed by [consulting firms] for the purposes of assessing state transfer policies in four areas: pathways and credit applicability, student supports, institutional collaboration and implementation, and accountability, found that Massachusetts has one of the most robust transfer systems in the country. Further, in the spirit of continuous improvement, the Department has partnered with external researchers and has several initiatives underway to evaluate policy outcomes for the MassTransfer policy.

The Commonwealth Commitment Advisory Board (CCAB) was absorbed by the MassTransfer Statewide Committee, and the program has been an item on the meeting agendas and a continued topic of conversation at systemwide meetings since the CCAB was dissolved. All members of the CCAB are invited [to] MassTransfer Statewide Committee meetings. The Department will update the MassTransfer Procedures Manual accordingly.

Auditor’s Reply

In its response, DHE states that “the Department has recently evaluated MassTransfer, including the Commonwealth Commitment program, through an Equity Agenda related review.” No documentation was provided to us detailing the evaluation that took place. Further, DHE’s statement does not address our audit’s finding that CCAB did not review the MassTransfer Commonwealth Commitment Program at least annually.

Though DHE also states that the CCAB “was absorbed by the MassTransfer Statewide Committee,” no evidence was provided to us to support this claim. DHE continues, “The program has been an item on the meeting agendas and a continued topic of conversation at systemwide meetings since the CCAB was dissolved.” Although DHE did provide two agendas for meetings that the MassTransfer Statewide Joint Transfer Group (referred to in DHE’s response above as the MassTransfer Statewide Committee) held during the audit period, and each one did contain a line item for “MassTransfer Commonwealth Commitment,” the accompanying meeting minutes did not contain any mention of this item being discussed at the meetings. Further, we believe that a brief discussion of the program during meetings scheduled for no more than two hours, with 12 items on the agenda, would not have constituted evidence of the review of the MassTransfer Commonwealth Commitment Program by the CCAB that the MassTransfer Procedures Manual requires.

DHE is taking measures to address our recommendation of updating the manual with regard to the nature and frequency of its review of the MassTransfer Commonwealth Commitment Program.

1.    Degree pathways are the associate’s-to-bachelor’s-degree agreements between community colleges and public IHEs offering bachelor’s degrees under the MassTransfer Commonwealth Commitment Program. The pathways ensure that all credits earned through a community college’s associate’s degree program will be transferred and applied to another IHE’s bachelor’s degree program.

2.    According to its meeting agendas and minutes, the MassTransfer Statewide Joint Transfer Group consists of approximately 100 individuals (transfer professionals, registrars, DHE staff members, and others) who receive updates on, and discuss, DHE’s equity agenda and aspects of MassTransfer, such as its website, its “Policy and Implementation Guidelines,” and the MassTransfer Commonwealth Commitment Program.

Date published:	June 27, 2022