The American Board of Funeral Service Education (ABFSE), Committee on Accreditation (COA), is a national specialized accrediting agency. Its current scope of recognition is the accreditation of institutions and programs awarding diplomas, associate degrees and bachelor's degrees in funeral service or mortuary science. ABFSE is, therefore, both an institutional and programmatic accreditor. ABFSE currently accredits approximately 46 programs in 31 states and the District of Columbia. ABFSE also accredits 11 single purpose institutions in two of which also have regional accreditation. However, it serves as the Title IV gatekeeper, of nine institutions enabling them to establish eligibility to participate in the Title IV student financial aid programs. As such, it must meet the separate and independent requirements as set forth in the Secretary's Criteria for Recognition or seek a waiver. As of this review the agency has been found not to meet the definition of "separate and independent" as provided in the regulations. This paper presents the recommendations of the staff of the National Advisory Committee on Institutional Quality and Integrity (NACIQI) concerning ABFSE's petition for continued recognition.