Winebrenner Theological Seminary Action Letter 7-8-15

 July 8, 2015
BY CERTIFIED MAIL
Dr. David E. Draper, President
Winebrenner Theological Seminary
950 N. Main St.
Findlay, OH 45840
Dear President Draper:
This letter is formal notification of action concerning Winebrenner Theological Seminary (“the
Seminary”) by the Higher Learning Commission (“the Commission”) Board of Trustees (“the Board”).
At its meeting on June 25, 2015, the Board placed the Seminary on Probation because the Seminary is
out of compliance with the Criteria for Accreditation and the Core Components identified in the Board’s
findings as outlined below. This action is effective as of the date action was taken. In taking this action,
the Board considered materials from the most recent comprehensive evaluation, including but not
limited to the self-study report the Seminary submitted, the report from the comprehensive visit team,
the report of the Institutional Actions Council Hearing Committee, institutional responses to these
reports, and other materials relevant to this evaluation.
The Board required that the Seminary file an Assurance Filing no later than September 2016, or eight
weeks prior to the comprehensive evaluation, providing evidence that the Seminary has ameliorated the
findings of non-compliance identified in this action that resulted in the imposition of Probation and
providing evidence that the Seminary meets the Criteria for Accreditation, the Core Components,
Federal Compliance Requirements, and the Assumed Practices. The Assurance Filing should include the
following specific documentation:
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A financial plan, inclusive of all operations and locations that indicates the institution is no
longer relying on debt to finance operations;
Debt management data and policy (Core Component 5.A);
All financial data and legal arrangements relating to the ownership of the Scotland,
Pennsylvania property (Core Component 5.A);
Enrollment records from the time of the 2014 site visit and revenue projections based on
tuition versus actual revenue from tuition (Core Component 5.A);
Documentation of strategic planning timeline (Core Component 5.C);
Evidence of engagement of internal and external constituents, including faculty, in planning
process (Core Component 5.C);
Evidence of assessment and evaluation results that provided inputs into planning decisions
(Core Component 5.C);
Adopted strategic plan with implemented initiatives and their results identified (Core
Component 5.C);
Dr. David E. Draper, July 8, 2015
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Budget related to the strategic (Core Component 5.C);
Evidence that the strategic planning process has become systematic and integrated;
Evidence of measurable institutional-, program-, and course-level student learning outcomes
and their correlation (Core Component 4.B);
Evidence that results of assessment of student learning are incorporated into continuous
improvement processes (Core Component 4.B);
The Seminary is required to host a comprehensive evaluation no later than November 2016; while this
visit will consider the institution’s compliance with all the Criteria for Accreditation, its primary focus
will be on those findings of non-compliance and the other concerns identified in this action to determine
whether the findings of non-compliance and other concerns have been fully ameliorated. If the findings
of non-compliance and other concerns identified in this action have not been fully ameliorated or if the
institution is unable to demonstrate that it fully meets the Criteria for Accreditation and Assumed
Practices such that Probation may be removed, the Commission shall withdraw accreditation.
The Board will review the team report and related documents at its June 2017 meeting to determine
whether the institution has demonstrated that it is now in compliance with all Criteria for Accreditation
and whether Probation can be removed, or if the Seminary has not demonstrated compliance, whether
accreditation should be withdrawn.
The Board based its action based on the following findings made with regard to the Seminary:
The Seminary is out of compliance with Criterion Four, Core Component 5.A, “the institution’s
resource base supports its current educational programs and its plans for maintaining and
strengthening their quality in the future,” for the following reasons:
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The Seminary has leveraged borrowed monies to fund its operational expenses and
recent purchase of the Scotland, Pennsylvania location; it anticipates ongoing operating
deficits to cover its operations in the near future through FY15;
The Seminary has accrued approximately $5 million in debt as a result of this practice
and is likely to take on additional debt to cover its operating costs for the current fiscal
year;
The Seminary initially greatly over-estimated its revenues from, and under-estimated its
operating expenses for, the Scotland location, thus resulting in significant liability for the
Seminary from the Scotland transaction and, while a three-year lease of the facility
recently executed by the Seminary may alleviate some of the financial strain for the
Seminary, the purchase of the location remains a significant debt and responsibility for
the Seminary; and
Efforts to boost low enrollment have yielded some modest anticipated enrollment
increases, but it remains unclear whether those enrollment increases will be sufficient
and ongoing such that it is reasonable to base improved financial projections on such
anticipated increases.
The Seminary is out of compliance with Criterion Five, Core Component 5.C, “the institution
engages in systematic and integrated planning,” for the following reasons:
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While the Seminary has initiated a strategic planning process, it still has no strategic plan,
and leaders have not yet laid out a comprehensive plan and timeline for steps for
Dr. David E. Draper, July 8, 2015
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producing such a plan relative to other milestones, such as an upcoming Board meeting
at the Seminary;
Based on enrollment and financial trends, documents, and interviews with campus
personnel, the team concluded that the Seminary in the past failed to adequately plan,
implement, and assess institutional operations, including its operational budget plan,
relying instead on short-term emergency planning; and
The Seminary has thus far failed to engage primary constituents such as the faculty in the
strategic planning process.
The Seminary meets with concerns Criterion Four, Core Component 4.B, “the institution
demonstrates a commitment to educational achievement and improvement through ongoing
assessment of student learning,” because the current assessment program does not articulate
inputs that are clear and measurable to allow for the collection of meaningful data, and the
Seminary needs to articulate the connections between its program and course goals and
outcomes.
The Board action resulted in changes to the affiliation of the Seminary. These changes are reflected on
the Institutional Status and Requirements Report. Some of the information on that document, such as
the dates of the last and next comprehensive evaluation visits, will be posted to the Commission’s
website.
Information about the sanction is provided to members of the public and to other constituents in several
ways. Commission policy INST.G.10.010, Management of Commission Information, anticipates that the
Commission will release action letters related to the imposition of a sanction to members of the public.
The Commission will do so by posting this action letter to its website. Also, the enclosed Public
Disclosure Notice will be posted to the Commission’s website not more than 24 hours after this letter is
sent to you.
In addition, Commission policy COMM.A.10.010, Commission Public Notices and Statements, requires
that the Commission prepare a summary of actions to be sent to appropriate state and federal agencies
and accrediting associations and published on its website. The summary will include the Commission
Board action regarding the Seminary. The Commission will simultaneously inform the U.S. Department
of Education of the sanction by copy of this letter.
At this time, the Commission will reassign the Seminary from its liaison Dr. Mary Vanis, to Dr. Anthea
Sweeney. If you have any questions or concerns about the information in this letter, please contact Dr.
Vanis. Please be assured that Dr. Sweeney will work with Dr. Vanis to create a smooth transition.
As you know, the Commission is separately reviewing the Scotland, Pennsylvania acquisition and
ongoing arrangements under its policy related to Change of Control, Structure or Organization. This
review will take place in the next several months and is not related to the review being conducted relative
to the probationary status of the Seminary.
Commission policy INST.E.10.020, Probation, subsection Disclosure of Probation Actions, requires that
an institution inform its constituencies, including Board members, administrators, faculty, staff, students,
prospective students, and any other constituencies about the sanction and how to contact the
Commission for further information. The policy also requires that an institution on Probation disclose
this status whenever it refers to its Commission accreditation. The Commission will monitor these
disclosures to ensure they are accurate and in keeping with Commission policy. I ask that you copy Dr.
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Sweeney on emails or other communications regarding the sanction and provide her with a link to
information on your website and samples of related disclosures.
If you have questions about any of the information in this letter, please contact Dr. Sweeney. On behalf
of the Board of Trustees, I thank you and your associates for your cooperation.
Sincerely,
Barbara Gellman-Danley
President
Enclosure:
cc:
Public Disclosure Notice
Chair of the Board of Trustees, Winebrenner Theological Seminary
Ms. Marilynn C. Dunn, Executive Assistant to the President, Winebrenner Theological Seminary
Dr. Mary I. Vanis, Vice President for Accreditation Relations, Higher Learning Commission
Dr. Anthea M. Sweeney, Vice President for Accreditation Relations, Higher Learning
Commission
Ms. Karen L. Solinski, Vice President for Legal and Governmental Affairs, Higher Learning
Commission
Mr. Herman Bounds, Accreditation and State Liaison, Office of Postsecondary Education, U.S.
Department of Education