TO:                 NCAA WORKING GROUP TO REVIEW INITIAL ELIGIBILITY TRENDS
FROM:           THE COALITION ON INTERCOLLEGIATE ATHLETICS 
DATE:            27 MARCH 2006
RE:                 COIA RESPONSE TO THE WORKING GROUP DRAFT REPORT

            This letter is in response to the February 2006 draft report by the NCAA Working Group to Review Initial Eligibility Trends. The report correctly identifies and begins to address the problem of a small subset of private high schools whose primary function is to remediate otherwise inadmissible academic records  such that previously ineligible students can secure an athletic scholarship at an NCAA member institution.  The Working Group draft report was sent out to all COIA members for review and comments. The following comments emerged from our discussion and have been approved by the COIA Steering Committee. Our comments begin with those that respond to specific issues raised in the working group paper and are followed by a few additional comments. We respectfully submit these for consideration by your committee.

WORKING GROUP ISSUE #1:  SOURCE OF GRADUATION AND CORE COURSE.   

     Recommendations 1a and 1b of the Working Group’s report propose to establish a more comprehensive process for reviewing high schools used to meet graduation and core-course requirements for purposes of meeting NCAA initial-eligibility requirements. The enhanced review process might include in-person site visits of certain schools.

     The draft report states on page 1 under assumptions that all public high schools and many nonpublic high school are subject to state review and thus there are means to determine the validity of high school work. However, relying on principals in non-public high schools that are not subject to state regulations creates problems in guaranteeing the integrity of academic credentials. Further, the Working Group recommends the establishment of a more comprehensive process for reviewing high schools to ensure that basic academic requirements are met.  While the COIA strongly supports the intent of these recommendations, we raise some concerns as follows:

     1) The recommendations should clearly state which high schools will be subject to the enhanced NCAA-led review. If only the non-public high schools that are not currently under state regulations, this should be stated.

     2) The NCAA will have to clearly define what is meant by “basic academic requirements”. Perhaps the first step in the process is to examine the current state requirements to determine if there is a wide discrepancy across states. Assuming that these requirements are similar, then the NCAA should use these requirements to define the basic requirements that non-public, non-state regulated schools must follow.

     Most of the issues raised above would disappear if scholarship athletes were required to graduate from accredited high schools. Obviously there would need to be exceptions for home schooled students, many of whom are already required to meet state curriculum requirements. Additional exceptions may be needed for those few, well-established quality private schools that are not currently accredited. Such a regulation may have the unfortunate consequence of encouraging the establishment of bogus accreditation agencies to provide ‘cover’ for these unscrupulous high academies. It seems to us however that these consequences would exist only in the short term because such cover-ups would not remain unnoticed by the NCAA, college admissions officials, and/or the public.

WORKING GROUP ISSUE #2: CORE COURSE PATTERNS

            COIA supports the recommendations for Issue 2. It has been reported that some of the non-traditional high schools allow students to take and pass up to 10 courses per term, oftentimes in the summer. There is no sound educational rationale for such an overload. Limiting the number of core courses and sequential courses taken during any year and especially the senior year would address this concern.

WORKING GROUP ISSUE #3: TAKING TEST PATTERNS

            The Working Group proposed three recommendations:

  1. Explore the option of obtaining official test scores for all prospective student-athletes directly from the testing agencies;
  2. Explore the option of requiring test scores used for initial-eligibility be taken prior to July 1 following a student’s eighth semester of high school;
  3. Explore the option of requiring official test scores for some prospective student-athletes.

            COIA supports recommendation 3a (obtaining official test scores for all prospective student-athletes). These should be obtained for all student-athletes, not just some (3c).  However, this raises a bigger issue. Given that admitting institutions presumably already require official scores, and submitting false information is already grounds for ineligibility, we wonder if some institutions are looking the other way when presented with obviously inconsistent test scores?  Is the NCAA trying to make sure that institutions see all the relevant scores, or is the NCAA going to make its own assessment of the possibility of fraud?  And how will that fraud be proved?  COIA believes these questions should be addressed by the Working Group in its final report.

            There are additional issues on the subject of national tests. Faculty members across the country have recounted rumors that some high school students, including student-athletes, employ other students to take the SAT or ACT exam for them.  There is a clear need for the ACT and SAT testing agencies to continue to improve their verification of test takers. The other problem associated with national college entrance exams is that of fraudulent score reporting. This problem would be greatly reduced if the NCAA required that higher education institutions and the NCAA clearinghouse obtain official test scores for all prospective student-athletes directly from the testing agencies. At some point it may be valuable for the NCAA to consider revisiting the minimum SAT/ACT requirement.

WORKING GROUP ISSUE #4: SHARED RESPONSIBILITY IN THE INITIAL ELIGIBILITY PROCESS

            COIA supports the recommendations proposed by the Working Group on this issue.

WORKING GROUP ISSUE #5: ABILITY TO IDENTIFY AND RESPOND APPROPRIATELY TO SUSPECTED ACADEMIC FRAUD

            The Working Group recommends that the NCAA clearinghouse and/or NCAA staff “conduct a special review of a prospective athlete’s academic records and/or a high school's information where there is the appearance of malfeasance in the academic record”. This is a huge task that will require a whole new set of rules and a large, well-trained staff. We believe that this review should be the responsibility of the academic institution’s admissions office rather than at the NCAA level. It is certainly possible that some institutions may avert their gaze when presented with suspicious or questionable credentials, but they do so at the risk of their credibility and reputation. The additional level of bureaucracy suggested in the recommendations under Issue #5 may be avoided if prospective athletes were required to attend and graduate from accredited high schools, as proposed above.

            With the exception of a mention about reporting to local law enforcement and accrediting agencies, the Working Group report avoids the issue of penalties.  COIA believes that enforcement and penalties should not be left to other organizations and agencies. As has been discovered with the sliding admission scale, the GSR and NCAA rule violations, the NCAA needs to take a strong stance on enforcement and penalties otherwise violators will continue to flourish.  Such a system might include penalties at the individual and institutional levels. Some possible penalties include:

            a) Students involved in submitting fraudulent credentials would be banned from athletics at any NCAA member institution for at least one year;

            b) High schools submitting fraudulent credentials would face increasing penalties, including a blanket refusal to accept their student-athletes for an athletic scholarship to any NCAA institution; and;

            c) NCAA institutions with repetitive patterns of accepting student-athletes with fraudulent credentials would face increasing penalties, including losing scholarships.

            Penalties such as these would raise the stakes for those seeking to violate sound educational practice. Instituting a penalty system that affects individual and institutions would put the onus for compliance on the student-athletes, their high schools and the admitting NCAA institution, and not just on the NCAA.

WORKING GROUP ISSUE #6: DEVELOPMENT OF PARTNERSHIPS TO ADDRESS ISSUES OF ACADEMIC INTEGRITY

            COIA supports the recommendations proposed by the Working Group on this issue.

ADDITIONAL CONCERNS AND SUGGESTIONS

            1. Require Review of Distance Learning Courses.  Distance learning is a rapidly growing field at all educational levels. However the rigor of courses taught in this fashion may not meet the same standards as traditional classroom courses. Higher education institutions should take care in reviewing applications from incoming freshman and transfer students that contain distance learning courses, particularly when these courses are used to satisfy entrance requirements and bolster the application.

            2. Determine the Influence of University Supporters/Boosters on Questionable High Schools.  In addition to raising athletes' GPAs, these "diploma mills" also provide training grounds for athletes. It may be that they provide better training grounds than many high schools, for presumably the athletes play and practice with and against some of the best. Although we have no evidence, we wonder whether any college or university supporters/boosters are providing funding for these schools in the form of direct or indirect charitable contributions.

            COIA thanks the NCAA and the Working Group members for their thoughtful efforts to deal with this difficult problem. We are grateful that COIA has been included in these discussions and has been asked to comment on the Working Group’s draft report. We look forward to further opportunities to interact with the Working Group on this issue.