The following serves as an institutional response to your letter dated March 16, 2019. In all honesty, the high administration of the Conservatory of Music cannot inform the FOMB about the referred proposal for consolidation or reorganization (with the SPAD) or the status of any legislation vis-à- vis this process, primarily, because no one in the Conservatory knows about—or favors—this proposal. In this context, one would expect that both academic communities (let alone their executive directors and board members) would have been consulted before envisioning or approving this consolidation proposal—particularly when one of the institutions (PRCM) is in the middle of its accreditation review with the MSCHE (Spring 2020). A consolidation process is regarded, by the U.S. Department of Education and our two accreditation agencies (MSCHE and NASM), as a substantive change. Substantive change procedures not only cost money (and are, as it should be, an exhaustive and demanding process), but also require approval prior to implementation. As noted by the MSCHE, failure to obtain prior approval from the Commission for substantive changes jeopardizes the institution’s accreditations status and may negatively affect the institution’s Title IV funding or eligibility. Furthermore, a consolidation process without performing the proper due diligence of consulting the institutional groups of interest might well collide with the specific criteria of some of the Standards of Accreditation. Needless to say, there are plenty of examples of unsuccessful consolidations and absorptions in the United States and Europe (especially since the 2000s) that failed to produce projected saving targets, but also generated an extremely tense atmosphere between the state and the academic communities (faculty, administrators, students, donors and alumni). The consolidation of these institutions—which, in this case, seems to be based on insufficient research and planning (quite frankly, I resist to believe that we are dealing with a perilous disregard for the principles that guide academic institutions)—would affect everything from restructuring its institutional laws and missions to merging two specialized universities with disparate budgetary patterns, fiscal capacities, and sources of revenue and expenditure. In the context of the PRCM (a specialized university that, as of today, complies with all the Requirements of Affiliation and Standards of Accreditation of MSCHE), the Commission states the following: “The PRCM has provided information that shows sound fiscal strategies during the aftermath of Hurricanes Irma and Maria and the budgetary difficulties endured by the Commonwealth of Puerto Rico. From the information provided, the institution appears to be in good financial position despite a reduction in the appropriations received from the state. The PRCM administration has a positive fund balance and no debt and is looking for new streams of revenue in the future” (MSCHE’s Team Report; September 11, 2018). In the opinion of the high administration of the Conservatory, this consolidation (that, from an economic standpoint “barely counts,” to quote a recent Chronicle of Higher Education article about college mergers, “as a drop in the fiscal ocean”) could potentially put in danger two of the most prestigious and accredited art schools in Latin America and the East Coast of the United States. As someone who has lived half of his life associated with the Conservatory (as a student, instructor, tenured professor, member of various committees, Chair of Department, and Chancellor), I urgently implore the relevant authorities to reconsider this ill-conceived proposal. At this juncture, I have no other option but to defend the autonomy of the Conservatory of Music in every forum (an institution that this year celebrates its 60th anniversary), even if this decision leads to my resignation or dismissal from the post of Chancellor.
Sincerely,
Dr. Pedro I. Segarra Sisamone
Chancellor and Executive Director—Puerto Rico Conservatory of Music