The Department shall ensure that mandatory annual financial
assessments of Institutions are conducted in accordance with the following
procedures.
(1)
Screening.
(a)
Annual Screening. All Institutions shall be screened
annually for the purpose of assessing each Institution's past, present, and
future financial stability to identify any Institution potentially at Risk of
Imminent Closure.
(b)
Screening Tools. The Board shall establish the
procedures, to be used in the screening process, after consultation with
representatives of Institutions and other stakeholders, and shall periodically
review and refine such procedures as needed. Said procedures may include, but
are not limited to:
1. The use of financial
and non-financial indicators from publicly available data sources to conduct a
preliminary assessment of whether the Institution may be at Risk of Imminent
Closure.
2. Credit ratings assigned
to Institutions by credit rating agencies or services.
3. Any information obtained from other
regulatory, oversight, or law enforcement entities, including Accrediting
Agencies, the U.S. Department of Education, and the Massachusetts Office of the
Attorney General, that could allow the Department to evaluate the sufficiency
of the Institution's financial resources.
(c)
Notification and
Consideration of Other Information Relevant to the Screening. The
Commissioner shall notify each Institution identified through the screening
process as potentially at Risk of Imminent Closure under 610 CMR 13.03(1)(c).
The notification shall include Department staff outreach to the administration
of the Institution to provide an opportunity to review the results of the
screening process, including the analytical methodology, and to submit
additional information that they or the Commissioner deem relevant to the
screening results, including updated data not taken into account as part of the
methodology used.
(2)
Determination of Financial Status. If the screening
results, including any information provided to the Department in 610 CMR
13.03(1)(c), indicate an Institution may be at Risk of Imminent Closure, the
Commissioner shall provide the Institution with a summary of the basis for his
or her determination and require the Institution to submit information, in the
form of a risk mitigation plan, to accurately and fairly determine the
institution's financial status and likelihood of imminent closure and to
monitor its condition, and prepare a contingency closure plan.
(a)
Submission of Risk Mitigation
Plans. The Institution's risk mitigation plans shall, at a
minimum, inform the Board of any known liabilities, risks, or financial issues
and outline the Institution's plans, initiatives, and goals to sustain
operations and to substantiate its current and prospective resources and
financial capacity to address the Risk of Imminent Closure. The Commissioner's
request for risk mitigation plans shall be addressed to the chief executive
officer of the Institution and shall direct the Institution to work with
Department staff. Copies of the Commissioner's request shall be sent to the
chair and vice chair(s) of the Institution's governing board. As part of the
Institution's risk mitigation plans, the Institution's chief executive officer
and the chair of the Institution's governing board shall provide written
assurances and certifications which, at a minimum, shall certify the accuracy
and completeness of the Institution's risk mitigation submission, and certify
the Institution's intention and ability to continue operations and
substantially fulfill its obligations to enrolled and admitted students.
Additional content and the format of the required assurances and certifications
shall be determined by the Commissioner.
(b)
Review and Evaluation of Risk
Mitigation Plans. Department staff shall review the Institution's
risk mitigation plans and evaluate the Institution's Risk of Imminent Closure.
The Commissioner shall, after Department staff review, make one the following
determinations:
1. if the risk mitigation
plans are deemed satisfactory, such that the Institution is deemed no longer at
Risk of Imminent Closure, the Department shall monitor the implementation of
the plans as set forth in 610 CMR 13.03(3); or
2. if the Institution does not submit the
requested risk mitigation plans, or if the submitted plans do not demonstrate a
likelihood that Risk of Imminent Closure will be mitigated during the current
and subsequent academic year, the Commissioner shall require continued
contingency planning for closure and, after notice to the Institution and an
opportunity to cure, notification to the public, as set forth in 610 CMR 13.04
and/or may impose sanctions as outlined in 610 CMR 13.07.
(3)
Monitoring. Department staff shall monitor the
Institution's progress in implementing its risk mitigation plans and
initiatives and meeting its goals. Monitoring shall continue until the
Department determines that:
(a) the concerns
identified have been satisfactorily resolved, such that the Institution has
sufficiently mitigated the Risk of Imminent Closure; or
(b) the Institution's plans to address the
Department's concerns, as originally presented or subsequently amended, have
not resulted and are unlikely to result in a satisfactory resolution.
Department staff may require periodic and other reports as part of the
monitoring process.