Section 5002(4) of the Education Law sets forth two distinct methods in which schools can secure curriculum approval by the Bureau of Proprietary School Supervision (BPSS). The current avenues to curriculum review and approval are as follows:
Curricula or courses submitted require full evaluation by the Bureau. Under this path, schools are billed for the curriculum evaluation cost for any curricula or courses requiring evaluation by an expert evaluator not employed by the department. Before these applications are sent to the expert evaluator, BPSS and school staff must adequately perfect the curriculum submission in anticipation of a substantive form and content review; and
Nationally Recognized Vendor (NRV) Method
Curricula or courses provided to schools by NRV's as defined in Section 126.1(y) of the Regulations of the Commissioner of Education and as identified in Policy Guideline PG1-0300. Curricula must be submitted in the original format provided by the vendor. Additionally, BPSS reviews the school equipment inventory submitted to determine that the school can support the curriculum or course.
The purpose of this policy guideline is to add additional paths to the options for curriculum or course evaluation. Due to the nature of the pre-evaluation described in each alternative, BPSS has determined that these routes substantially meet the intent of the curriculum review requirements set forth in Education Law and the Regulations of the Commissioner.
- Pre-Evaluation Method
Under this alternative, a school would have its course or curriculum pre-evaluated by a Bureau-authorized, independent curriculum evaluator who is an expert in the content area of the program and preferably who has a strong education background as well. The school would bear whatever costs are agreed to with the evaluator directly and would resolve any curricula deficiencies prior to submitting the application to this office. By doing so, this Bureau would not require any additional course or curriculum review, provided that the appropriate curriculum forms are in proper order for submission. This would allow for an expedited curriculum or course approval process similar to that in place for the NRV process, while maintaining the legislative intent of an expert substantive evaluation as required in the Traditional Method.
This new "pre-evaluation" method is in full compliance with current laws and regulations as it includes the necessary accountability and oversight. The process requires BPSS to ensure that the curriculum includes the necessary factors enumerated in Education Law Section 5002(4)(b), but first undergoes an expert evaluation. The additional method is basically as follows:
Schools work with their independent evaluators as approved by BPSS in meeting all requirements necessary for approval. The evaluator's full curriculum/course evaluation, notes, and BPSS affirmation form are submitted to BPSS along with the curriculum upon the completion of the evaluator's review and any adjustments made to the curriculum by the school as a result of the expert review.
Schools would be responsible for nominating prospective independent curriculum evaluators who are expert in the content areas taught at the school. In order for consideration, BPSS requires an Independent Evaluator Nomination form, complete resume from the prospective evaluator, as well as full disclosure of any ownership, employment, or any other relationship or interest in any non-degree granting proprietary school operating or licensed in New York State. At least three original reference letters attesting to the prospective evaluator's expertise must also be included. The prospective evaluator must agree to objectively review the course or curriculum applications submitted on the appropriate Curriculum Application Form (BPSS-30) and use a BPSS-provided evaluation instrument for that review. Although encouraged to provide the school with appropriate feedback on the evaluation, the prospective evaluator must agree to take no part in the actual construction or revision of a course or curriculum submitted for his or her review. Finally, the evaluators must understand that their approval as an authorized curriculum evaluator can be terminated at any time for just cause by BPSS. When an evaluator is approved, both the evaluator and the school who nominated the evaluator will be notified of that approval. At that time, a form will be sent to the evaluator to be used when submitting curriculum or course applications to this office after the pre-evaluation.
By participating in the Pre-Evaluation Method, schools will be better able to provide direct and timely communication with the evaluator in satisfying any deficiencies. For schools not choosing this alternative, the other methods for curriculum review can be utilized. Schools may decide to use any of these review and approval methods depending on the particular curriculum or course to be submitted.
- Request for Proposal (RFP) Evaluation Method
This is to be used by schools who submitted a proposal, to an outside agency to train a specific population which was subsequently approved. It is designed to provide a stream-lined approval process in order for the school to begin the contracted training as quickly as possible. The requirements for submission under this method are as follows:
- Schools must submit 2 Copies of each of the following and receive approval prior to offering any instruction;
- The RFP for which the curriculum/course is intended;
- Verification from the agency issuing the RFP that the school's proposal has been accepted and approved;
- A summary of the requirements of the program described in the RFP including the specific target population for the training, the entrance requirements, the duration approved for the training, any specific equipment required, and any other information that is essential to the approval of the proposal.
- Completed curriculum application (form BPSS-30), completed in full with the exception that performance objectives are not required if the agency issuing the RFP does not require them. To alert Bureau staff to this as an RFP application, the school must write "RFP" in block letters at the top of each application. This is the school's responsibility as the Bureau will not develop a separate application form for this purpose. Failure to do this may result in a delayed review process.
Special RFP Curriculum Application Approval Information
Curriculum or courses approved through this process will be limited only to that student population group specified in the RFP and not the general public.
Additionally, if the agreement with the agency issuing the RFP has an expiration date, no additional enrollment may be conducted after that expiration date, regardless of the expiration date listed on the curriculum or course approval.
Any RFP curriculum or courses approved must adhere strictly to the guidelines approved and submitted to the Bureau with the initial application for curriculum or course approval. Any changes agreed to by the agency issuing the RFP and the school must be sent, in duplicate, to the Bureau.
All approved RFP curriculum or courses will bear the parenthetical (RFP) after the title to fully denote the process through which approval was issued and the limited population for which the curriculum or course will be offered.