Atlantis University, a Miami-based for-profit school, appears to be in violation of a rule of the private accrediting agency that oversees its operations, a standard governing the use of “branch campuses” tied to a school’s central campus.

Remarkably, in 2017 Atlantis won an award from that accreditor, Accrediting Commission of Career Schools and Colleges (ACCSC), as a “School of Excellence,” recognized “for their commitment to the expectations and rigors of ACCSC accreditation, as well as demonstrating exceptional student achievement.” That year, Atlantis’s executive director,  Carol Palacios, whose family owns the school, was elected an ACCSC School Commissioner.  And in May 2022, Palacios, who is also an “ACCSC Certified Accreditation Professional,” was elected as ACCSC’s Chair of the Commission.

Certification by an established accreditor like ACCSC that a school is complying with applicable rules is necessary to make and keep a school eligible for the federal student grants and loans that are the lifeblood of many colleges and universities.

ACCSC is the largest accreditor focused on U.S. for-profit colleges; it achieved that status after the U.S. Department of Education, after a long saga, denied the application of another big for-profit accreditor, ACICS, to be renewed as a recognized accreditor, and ACICS decided to shut down.

Atlantis University is owned by the Palacios family and is associated with the school UNIR, which Omar Palacios founded in Venezuela in 1975 and, according to the Atlantis University catalogue, “has expanded into an urban, multi-campus college serving the Latin American community.”

According to ACCSC records, Atlantis University has a main campus and one branch campus, which uses the name Florida Palms University. According to its website, Florida Palms University was “born in 2020.”

ACCSC standards define a branch as a campus whose management and supervision oversight is “carried out by the same ownership and management that controls the main school“ but that is “a separate facility established by a main school that is geographically apart from the main school.” The standard continues, “The branch campus must be permanent in nature, offer courses in educational programs leading to a degree, a certificate, or other recognized educational credential, have its own faculty and administrative or supervisory organization, and must provide for all required educational resources and student services (e.g., advising, testing, library resources, financial aid, employment assistance, etc.).”

The ACCSC standard essentially follows the requirements for branch campuses in Department of Education regulations.

According to the ACCSC website, Atlantis is located at “1011 Sunnybrook Rd., Miami, FL 33136,” and Florida Palms is located at “1011 Sunnybrook Rd., 11th Fl. Miami, FL 33136.” Each school’s phone number is listed as (305) 377-8817.

The Florida Palms University 2022 catalogue, the most recent catalog posted online, also lists the two schools at the same address – 1011 Sunnybrook Road; it lists Atlantis University on the 8^th floor and Florida Palms on the 11^th floor, and lists different phone numbers for the two schools. The catalog also states that Florida Palms University is “using a dedicated space of 10,000 square feet on the 11th floor of the AU Main Campus location.”

Three floors away in the same building would not seem to meet the definition of “geographically apart.”

Atlantis University and Florida Palms University are presented online as two distinct institutions.  Each has its own website, catalog, institutional email, and, apparently, intercollegiate sports teams with different names and logos.

But available evidence raises questions as to whether the branch campus is functionally a distinct educational institution.

For example, LinkedIn lists 177 employees at Atlantis University; it appears to list zero employees at Florida Palms University. Also, Department of Education records indicate that there are just a handful of federal student aid recipients at Florida Palms.

I contacted Carol Palacios by email to ask whether her school was in compliance with the rules of the accreditation agency that she chairs. I also asked what she is trying to accomplish with the present relationship between the two schools. If you have a university with a recognized brand in the community, why would you open a branch with a different name and in some respects be starting all over again? I asked if she instead was effectively trying to launch a new school or brand without having to wait years for approval to get federal financial aid from the Department of Education and approval to enroll international students under the Homeland Security department’s Student and Exchange Visitor Program (SEVP).

Palacios did not respond.

I also contacted Michale McComis, ACCSC’s Chief Executive Officer, with similar questions. He emailed me back: “ACCSC is aware that Florida Palms University is currently sharing space in the same building occupied by its main campus, Atlantis University, for the time being. Florida Palms University received initial approval to operate as a Branch campus at a different location in February 2021.”

I followed up, asking McComis to clarify whether he believed there is no violation of ACCSC standards, whether there is a violation but ACCSC accepts it “for the time being,” or whether he thinks the geographical separation requirement has lost relevance and can be ignored. I asked whether he has asked the school for, or received, a plan to remedy the situation, with a timeline. I also asked if ACCSC would be concerned if a branch were essentially an alter ego of a school, with a different branding and marketing but largely the same administration, faculty, and programs, as well as operating out of the same space, and whether ACCSC has taken any steps to monitor whether that is the situation with Florida Palms.

McComis has not responded.

A long-time industry executive asked whether ACCSC might be tolerating Atlantis’s co-location of its main campus and its branch, and the apparent staff and program overlap, because Atlantis’s leader was chair of the commission. “I don’t see them letting anybody else do such a thing,” he said. “How long will they be allowed to do this?” He pointed out there is no indication in any of the schools’ catalogues or other materials that Florida Palms is in its current location only temporarily.

ACCSC already is on thin ice with the U.S. Department of Education, whose recognition is required to maintain ACCSC’s status as a gatekeeper for federal student aid eligibility.

In July 2021, NACIQI, the U.S. Department of Education’s outside advisory committee that reviews accreditors, voted to reject the Department staff’s recommendation that ACCSC be renewed as a recognized accreditor for five years, the maximum renewal period available. Instead, after some NACIQI members presented evidence that ACCSC had long tolerated abuses and violations at some predatory colleges, the panel supported only a three year renewal. In October 2021, the Department announced it would defer renewal of ACCSC “pending the submission of further information about the agency’s monitoring, evaluation, and actions related to high-risk institutions,” including the shut-down schools operated by the Center for Excellence in Higher Education.

[UPDATE 7-25-23 12:30 pm: We found out today that on June 8, ACCSC informed its accredited schools by memo that the Department of Education’s designated Senior Department Official “[a]fter an exhaustive review,” had found ACCSC in compliance with federal regulations and renewed ACCSC’s recognition through 2026 — meaning five years from the July 2021 NACIQI meeting. According to the memo from McComis, the Department “did have some suggestions for ACCSC’s ongoing consideration in regard to the assessment of student achievement which the Commission intends to consider over the course of its recognition period.” So essentially the Department seems to have reverted to the staff recommendation of five years renewal, rather than the three years recommended by NACIQI. I guess ACCSC had to hold its breath for two years, but in the end there was no penalty for its lax oversight of predatory schools, including the CEHE schools.]

[UPDATE 7-25-23 7:15 pm: We located the decision letter from Senior Department Official Jordan Matsudaira to ACCSC, dated May 25, 2023. It extensively faults ACCSC for its reviews, especially of the CEHE schools, and concludes:

In July 2021, Department staff recommended that I continue ACCSC’s recognition as a nationally recognized accrediting agency for five years; NACIQI recommended that I continue ACCSC’s recognition for three years. After careful review of the record, I renew ACCSC’s recognition for a period of three years.

I don’t know quite how to square that statement with McComis’s statement that the Department “has extended ACCSC’s term of recognition to 2026.” That is three years from now, but five years from the NACIQI meeting.  I will find out more about the recognition cycle — forgive my ignorance — and see if I can figure this out.]

[UPDATE 7-25-23: Having discussed this matter with a number of former Department officials, it does seem that the recognition renewal period tends to begin at time that the Senior Department Official issues a decision.  But a delay in the SDO deciding, as occurred here with a two-year gap between the NACIQI meeting and the SDO decision, seems to give a questionably-performing accreditor a free extension of recognition.

It’s also concerning that the Department seems not to have made any public or press announcement of its May decision on ACCSC, even though the issue, through the NACIQI proceedings, became one of significant public concern. Instead it appears the Department quietly posted the decision in a list of links to proceedings related to the July 2021 NACIQI meeting. The Biden Department of Education faces numerous challenges undoing the harms done by the Trump-DeVos team and advancing progress on educational quality and integrity, but greater transparency, as we have long urged, would advance, not hinder, that progress.]

Atlantis / Florida Palms disclosures regarding the costs of attendance raise additional questions about compliance with ACCSC rules.

An ACCSC standard requires that all tuition costs and charges “must be as set forth in the catalog, enrollment agreement, and accompanying addendum,” and “Tuition costs and charges, tuition discounts, and all costs incidental to training” must be “Fully, clearly, and accurately disclosed to the prospective student before enrollment.”

The Florida Palms’ catalog, though, offers a confusing discussion of costs and fees, including, on top of tuition — $450 per credit for undergraduates and $897 per credit for graduate students — a $50 “registration fee” and additional “semester fees” that cover “a variety of services offered by the University to all students enrolled at the University, including but not limited to technology, lab access, and online platform access and support.” Florida Palms says it charges undergraduates $80 per credit hour for these “semester fees,” while graduate students are charged $223.33 per credit hour. Atlantis University’s catalog has a similar discussion of fees, except that the undergraduate tuition is slightly less, $410 per credit, and the undergraduate “semester fee” per credit hour is half as much — $40. Atlantis’s website also states, “A $1,000 administrative non-refundable fee will apply to all international students who wish to transfer or withdraw prior to their program completion.” This fee does not seem to appear in the Atlantis catalogue.