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March 29, 2013 Dr. Peter J.

Negroni Senior Vice President, Relationship Development The College Board 45 Columbus Ave New York, NY 10023-6992 Mr. Trevor Packer Senior Vice President, AP and College Readiness The College Board 45 Columbus Ave New York, NY 10023-6992 College Board School Code Request Appeal Committee C/O ETS Code Control P.O. Box 6022, Mail Stop 27-Q Princeton, NJ 08543 USA Code Number: 060919 Dear College Board Officials, We are writing to appeal the denial of the High Mountain Institute's Level II Code request (denial of request dated 7/06/2011, see attached copy of denial email). We believe that the reasoning for the denial is inaccurate and that by denying us the Level II Code, the College Board and ETS are restricting fair, equitable access to exams to the detriment of our students. We have been in contact with numerous representatives at various levels from both the College Board and ETS. It was suggested that we submit this appeal to be reviewed by a College Board committee after speaking with Ken Woods, Executive Director, Higher Education for the Western Region, Angela Polestra, Senior Director for AP Business Planning for the Western Region, and Chad Rause, Manager of Code Control at ETS. Specifically we are requesting a review of the decision related to our Level II Code application and access to administer PSAT and AP exams to our students. In the initial correspondence denying us a Level II Code, we were told that we do not qualify for two reasons. (X) School is not accredited by one of the agencies/organizations listed on the attached College Board Approved Accreditation List The High Mountain Institute is accredited by the Association of Colorado Independent Schools (ACIS) as noted on the School Code Request Form attached. While we concede that ACIS is not one of the six regional accrediting bodies listed on the current College Board Approved Accreditation List, we are aware that other ACIS accredited high schools (which are not dual accredited) are approved for Level II Codes and have the ability to administer both PSAT and AP exams. Examples include Kent Denver School, Colorado Academy, Colorado Springs School, Alexander Dawson School, and Fountain Valley School of Colorado. In phone conversations with representatives from both ETS and the College Board, we were told that each of these institutions must have been granted their Level II Code prior to the current standards. Chad Rause estimated that the current list of approved accrediting agencies was generated in 2008. While we do not, in any way, want to impact the ability of other schools to offer these exams to their students, it seems that our students are the unfortunate victims of a change in policy that disallows them

HIGH MOUNTAIN INSTITUTE

Post Office Box 970, Leadville, CO 80461 TEL 719-486-8200 FAX 719-486-8201 EMAIL hmi@hminet.org

from participating in the AP and SAT programs like their peers, thus denying them fair and equitable access. ACIS accreditation is recognized by the Colorado Department of Education and is certified by the National Association of Independent Schools Commission on Accreditation (see attached documentation). The Executive Director of ACIS, Lee Quinby, is pursuing the issue of ACIS being recognized by the College Board as an approved accrediting body. Please see his attached letter of support. Also, attached is a letter from the College Board acknowledging NAIS's Recognition Program now the Commission on Accreditationas equal to other accreditation organizations. We are also aware that The New York State Association of Independent Schools (NYSAIS) and other regional accrediting bodies who are members of the NAIS Commission on Accreditation are currently authorized accrediting agencies by the College Board. (X) School does not have a course of study that leads to a diploma or GED The High Mountain Institute does "have a course of study that leads to a diploma or GED." In fact, 100% of our students graduate from high school with our academic credits as a part of those requirements. While we do not issue our students final high school diplomas, HMI does grant certificates of completion and transcripts that are an integral component of our students' graduations from high school. Although we have been told that this statement is interpreted as "School does not grant diplomas or GED's", that is not, in fact, what it says. Along with being a fully accredited institution, as a semester school, we have formal arrangements with member and sending schools regarding the transfer of credit to be used toward graduation. Our students attend our academic program for one semester during their junior year. They come from public and private schools all over the country and upon completion of their semester with us, their academic credits transfer back to their sending schools as an integral part of a complete transcript toward graduation. Please see the attached letters of support from some of our Member Schools articulating the role that HMI courses and credits play in issuing diplomas at their respective institutions. The academic classes that students undertake at HMI do lead directly to a diploma and the credits that we issue are accepted and integrated into each student's final transcript resulting in a diploma. We are approved by the College Board to teach AP courses (AP United States History, AP Calculus AB, and AP Calculus BC) but are currently unable to administer these exams. We have 42 students each semester (84 over the course of the year) who all take the PSAT in the fall and who combined take over 100 AP exams annually in several different subject areas. As a rural school located five miles outside of Leadville, Colorado (population 2,740), our current strategy for making these critical testing opportunities available to our students is to partner with our nearest public school. Our local public school only administers between five and ten AP exams for their students each year and fewer than five of their students take the PSAT annually. We are therefore an incredible burden to them as our testing needs outnumber theirs 15 to 1. It is untenable to expect that they will facilitate our students testing needs when we far exceed their own students testing needs. The next closest high school is 35 miles away over an 11,000 ft mountain pass, making it often functionally inaccessible during the winter months, which in the mountains can last from October through May. We are one of a small handful of semester high schools that have been operating for more than fourteen years and have a long track record of success and partnership with some of the best schools in the country (visit http://www.semesterschools.net for more information on some of the oldest, most successful, and reputable semester schools). Several of these semester schools do in fact have a Level II Code and are able to administer College Board Exams to their students. In particular, Chewonki Semester School in Maine and Conserve School in Wisconsin, each have a Level II Code. The Mountain School in Vermont as well as CITYterm in New York City have access to a Level II Code, presumably through their associations with Milton Academy and The Masters School respectively, although each are separate campuses with unique missions and students not otherwise enrolled in the parent institutions. The semester schools who do not have a Level II Code, other than the High Mountain Institute, are those

HIGH MOUNTAIN INSTITUTE

Post Office Box 970, Leadville, CO 80461 TEL 719-486-8200 FAX 719-486-8201 EMAIL hmi@hminet.org

that do not wish to offer College Board exams or are not accredited by any organization. Our students are unfairly impacted when compared to similar schools that, under the stipulations of our Level II denial, would also be ineligible. As a semester school, we recognize that we are not always well understood, but we know that we are as credible an academic institution as any other and our students deserve the same access as others. Please fully consider our appeal and feel free to contact me with questions. We would welcome the opportunity to speak with someone involved in the decision making process directly regarding our concerns and the outcome of this appeal. Thank you for your careful consideration of our request. Sincerely,

Ben Dougherty High Mountain Institute Assistant Head of School 719 486-8200 x127 bdougherty@hminet.org School Code: 060919 cc: Pat Bassett, President, National Association of Independent Schools Jefferson Burnett, Vice President for Government and Community Relations, NAIS Mike Maughlin, Chair, High Mountain Institute Board of Trustees Jean Orvis, Chair, NAIS Commission on Accreditation Lee Quinby, Executive Director, Association of Colorado Independent Schools

Attachments: High School Code Request Form Copy of Level II Code denial email received on 7/6/2011 Documents Supporting Accreditation Recognition Letter from Lee Quinby, Executive Director of Association of Colorado Independent Schools in support of HMI's appeal NAIS CoA Certification of Association of Colorado Independent Schools (ACIS) and Letter of Recognition Copy of Letter from Dr. Peter J. Negroni to Ms. Selby McPhee recognizing NAISs Recognition Program now the Commission on Accreditationas equal to other accreditation organizations Letters of Support from HMI Member Schools Concord Academy The Hotchkiss School Dana Hall School HMI Diploma, Transcript, and School Profile

HIGH MOUNTAIN INSTITUTE

Post Office Box 970, Leadville, CO 80461 TEL 719-486-8200 FAX 719-486-8201 EMAIL hmi@hminet.org