Damage control . . .

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Human nature is the same whether you have a Ph.D. from a Southern Baptist seminary or you sell goats’ milk along the Khyber Pass. When you sense you’ve come under attack, you want to defend yourself.  And probably you want to fight back.

If you are the popular president of a Southern Baptist institution, you probably want — very quickly — to appropriate the words that are emblazoned on the official crest of Sao Paulo, Brazil: “Non ducor duco”

I am not led. I lead.

But whatever you do, you’re probably unwise to take a page out of Patterson’s playbook. You can neither dismiss the matter, discredit the messenger, nor defy the means of denominational accountability in the Southern Baptist Convention. Nevertheless, if you are the president of Midwestern Baptist Theological Seminary, your chief academic officer will probably advise a Pattersonian path forward. Acorns don’t typically roll far from the oak tree.

That will get you nowhere.

So here’s what we would do if we were in receipt of a letter like the one sent on Monday.

  1. Overnight a response to the author of the letter that: (a) acknowledges receipt of the original correspondence; (b) thanks the author for the opportunity to respond; (c) assures the author that this matter is being taken seriously; and (d)makes clear that the letter has been shared with trustee leadership, who are aware of the accreditation status of the school have been asked to respond in a manner they deem appropriate.  Shorthand: Be polite, but don’t take the bait. Since this is your first interaction with the author, it is best to assume his sincerity and respond with equal, but cautious sincerity.
  2. Share the letter immediately with the trustee officers, and perhaps the entire trustee executive committee. Ask the chairman to make a response to the letter an item on the agenda for the forthcoming trustee meeting.
  3. Instruct your chief academic officer to prepare a report to the trustees detailing every action that has been taken to address the concerns raised by the Higher Learning Commission to date and lay out the schedule going forward. Demand that the report be fully transparent with the trustees, no stone unturned. Demand this report be completed within 24 hours, a timeline that should not be difficult if due diligence is already the standard.
  4. Ask the trustee chairman to formulate a response to this matter in the event that media inquiries are made concerning the HLC accreditation or faculty plagiarism.  Stick to the script. Say nothing on your own. Get behind your trustees. Take your own advice, and cool it on social media for a bit.
  5. Formulate an email to your faculty, have it reviewed by your trustee officers and perhaps your mentor, explaining that public concerns about academic integrity have been raised regarding Midwestern Seminary. Reaffirm the faculty. Ensure them that you are responding appropriately with trustee guidance. Then tell them to focus on their classroom work and ministering to students and let this matter be handled by the administration and trustees.
  6. Inform the president of the Southern Baptist Convention about this matter and apprise him of your response plan.
  7. Get back to your primary job of overseeing a great, growing seminary and devote only as much time to this as is required. Stop refreshing your browser.

We typically charge clients for this sort of counsel.  But today, we’re offering it for free.

The Downgrade Controversy


We considered entitling this post, “All that glitters.” Whatever the case, our letter to the president of Midwestern Baptist Theological Seminary was received yesterday, Oct. 2, at 1:19 p.m. CT.


October 1, 2018


Dr. Jason Allen, President
Midwestern Baptist Theological Seminary
5001 N. Oak Trafficway
Kansas City, MO 64118

Dear President Allen:

With great interest in the work of Midwestern Baptist Theological Seminary and appreciation for the manner in which you assumed the presidency of that once-troubled institution, I listened attentively to your report during the 2018 annual meeting of the Southern Baptist Convention in Dallas, TX.

In your remarks, you noted the seminary’s record enrollment growth and reinforced the commitment to stewardship that guides the work of the school at every level. As you noted, there are some 45,000 Southern Baptist churches that support Midwestern Seminary through the Cooperative Program; that support totaled more than $19 million in the years since you were elected president. This year, Midwestern stands to receive more than $6.2 million in Cooperative Program disbursements, more than any previous year since the school’s founding in 1957.[1]

This news is encouraging, particularly given the fact that grave questions arose prior to your tenure about the improper use of funds, misappropriation of government grants, and the possibility of severe fines that could arise from the school’s noncompliance with federal funding statutes. Public reports at the time indicated that seminary trustees had been misled by the previous administration, that auditors had been deceived, and that the morale of the seminary community was at an all-time low.[2]

Indeed, the tone struck at your inauguration was exactly what the seminary and the convention needed to hear. In your speech on May 1, 2013, you stated clearly: “To our watching denomination I say, this day a man has been installed that loves the churches of this convention. He resolves to serve, in both letter and spirit, in good faith with the churches of this convention and welcomes the oversight and accountability the churches of the Southern Baptist Convention exercise over this seminary; this seminary they own.” You further entreated Southern Baptists to “hope the best” for Midwestern, to “believe the best” and “expect the best” from the school. You implored the churches of the convention to “hold [the seminary] accountable.”[3]

It is in that same spirit that I now send you this present letter.

I have received and carefully reviewed a copy of a certified letter to you dated July 17, 2017, from the Chicago-based Higher Learning Commission, one of two accreditors associated with Midwestern Baptist Theological Seminary.[4]  In that letter, which was copied to the Midwestern seminary trustee chairman, the president of the Higher Learning Commission, Barbara Gellman-Danley, wrote:

This letter is formal notification of action taken by the Higher Learning Commission (“HLC” or “the Commission”) Board of Trustees (“the Board”) concerning Midwestern Baptist Theological Seminary (“the Seminary” or “the institution”). During its meeting on June 29, 2017, the Board continued the accreditationof Midwestern Baptist Theological Seminary and placed it on Notice because the Seminary is at risk of being out of compliance with the Criteria for Accreditation and the Core Components identified in the Board’s findings as outlined below. This action is effective as of the date the action was taken. In taking this action, the Board considered materials from the most recent comprehensive evaluation, including but not limited to: the Assurance Filing the Seminary submitted, the report from the comprehensive evaluation team, the report of the Institutional Actions Council (IAC) Hearing Committee, and institutional responses to these reports. (emphasis added)

The concerns of the HLC were significant.  They included, but are not limited to, the seminary’s Title IX reporting and training, faculty oversight of academic matters, the authority of the seminary president, the absence of clearly-defined faculty bylaws, the conduct of faculty meetings, the seminary’s Doctorate of Counseling program, the implementation of the seminary’s zero-tolerance policy, the lack of an institutional review board to supervise the seminary’s research programs that involve human subjects, and the absence of clear channels of internal communication between faculty, staff, administrators, and seminary trustees.

In all, the notice lists six major issues of concern, each with additional sub-points. Evidence of having addressed the issues (a “Notice Report”) must be submitted by the seminary no later than December 1, 2018, or Midwestern risks “non-compliance with the Criteria for Accreditation and Core Components” required by HLC, and possible revocation of the school’s accreditation.

Prior to Dr. Gellman-Danley’s letter to you, the HLC issued a public disclosure dated June 29, 2017, changing the Seminary’s status from “Accredited” to “Accredited–On Notice.” The same issues were listed.[5]  As of October 1, 2018, Midwestern’s accreditation with the Higher Learning Commission remains “On Notice.”[6]

With increasing interest in the strength of Midwestern’s academic programs and administrative efficiencies in light of this now 15-month accreditation downgrade, I contacted HLC representatives via telephone on the week of Sept. 24, 2018.  In fact, the Midwestern website directs persons with questions regarding HLC issues, notation, and/or other matters needing outside mediation to the HLC.[7]

The accreditor’s staff walked me through all the concerns in the notation, described to me the responsibilities of the seminary in the coming months, and explained the procedures and timeline HLC will follow to ensure Midwestern’s full and fair hearing at the June 2019 meeting of the HLC trustees. As of Friday, Sept. 28, 2018, the commission has not received the mandatory “Notice Report” from Midwestern that is due no later than December 1, 2018.  HLC Staff also informs me that any in-person meeting between seminary officials and HLC staff would not obviate the seminary’s need to produce the mandated report before the stated deadline. Finally, I am informed that the seminary is still expected to have an on-site review by the HLC review team in the Spring of 2019, after which time the commission staff will prepare a final report for the commission’s trustees’ consideration at their June 2019 meeting. It is at that point – and not before—that Midwestern’s accreditation jeopardy will either worsen or be resolved.

Dr. Allen, Southern Baptists have a six decade investment in Midwestern Baptist Theological Seminary and its ability to train ministers for various fields of church service. As any investor would expect, Southern Baptists deserve to know the accreditation status of their seminary asset, the health and strength of its academic programs, the academic integrity of its faculty hires, the seminary’s compliance with federal laws, and the seminary’s policies and practices when handling cases of reported Title IX violations that may include gender and race discrimination.  All of these substantive issues have become a matter of concern to Midwestern’s secular accreditor, and they are surely a concern of Midwestern’s sole owner and primary underwriter, the Southern Baptist Convention.

Yet Midwestern has made no public statements about the HLC Notice nor any reference to progress the seminary has made to resolve the matter. In fact, since you first received the HLC letter, Midwestern has had two regular meetings of the trustee governance board; you have given one report to the Southern Baptist Convention in annual session, and one report was provided to Southern Baptists in the 2018 Book of Reports. Yet, the trustee meeting reports and convention reports are bereft of any mention of the serious accreditation cloud under which Midwestern presently seeks to train men and women sent by Southern Baptist churches.

For instance, during the October 2017 meeting:

The Board of Trustees’ Executive Committee brought forth a recommendation, which the full board unanimously approved, to move forward with plans to renovate the Trustee Classroom building and old student center. Plans include consolidating faculty offices to one central location, as well as to consolidate all of the student services components into one convenient location for student access. Such areas include the financial services office, admissions, information technology, registrar’s office, housing office, and church partnership office.

In other business, via recommendations from the Academic Committee, the trustees re-elected David McAlpin as associate professor of biblical interpretation, Radu Gheorghita as associate professor of biblical studies, and Matthew Swain as assistant professor of worship ministries.[8]

Included in the April 2018 trustee meeting report posted to the MBTS website is a lengthy report on the hiring of New Testament scholar Andreas Köstenberger[9]as a research professor of New Testament and Biblical Theology and director of a forthcoming Center for Biblical Studies.[10]

Under the subheading “Trustee Meeting Business” are updates on construction, enrollment (a new record), and the budget. Actions by the Academic and Governance committees are reported, but nothing—not a single line—about the accreditation notice.

As the president of Midwestern Baptist Theological Seminary, you had the opportunity to present to the messengers of the 2018 Southern Baptist Convention an update on any progress your administration has made toward resolving these residual issues. Yet there was no mention of accreditation, the Notice, or the Higher Learning Commission in your either your spoken or written report to the messengers.[11]

Finally, you have now had four opportunities to report on these matters to the Executive Committee of the Southern Baptist Convention (Sept. 2017 meeting; Feb. 2018 meeting; June 2018 meeting; and Sept 2018 meeting). Yet at none of these public meetings of the Executive Committee have you apprised Southern Baptists of the accreditation concerns that have been raised by outside accreditors or your plan to address them. One may search with futility for any reference to Midwestern’s serious accreditation issue on Baptist Press. Not one single mention. In fact, I cannot find where you have referenced the seminary’s accreditation issue on any of your 13,500 Twitter posts, neither in thousands of posts on your Facebook page or any of your blog posts at jasonkallen.com.

To be perfectly blunt: I am curious that an accreditation action of the severity presented in the HLC’s public letter and notice seemingly warrants your extended public silence. Moreover, students considering Midwestern Seminary for their ministry training deserve to know the school’s response to the serious allegations outlined in the HLC’s notice, and the seminary’s improvement plan point-by-point.

Dr. Allen, Southern Baptists have a vested interest in the academic integrity of their institutions just as they do the financial stability, construction planning, and enrollment projections you regularly cite in your public reports. Additionally, the board has a fiduciary responsibility to the Convention. That duty includes timely updates on challenges the seminary faces as well as successes the school experiences. Southern Baptists, most of whom have been entirely unaware of Midwestern’s accreditation issues, deserve to know how the administration of their fastest-growing seminary is addressing these matters with urgency and transparency. Your continued silence while months pass of published concerns about Midwestern’s operations is unacceptable. The time to address these matters publicly has long-since passed.

I leave you with these questions:  Will Midwestern respond publicly to the concerns enumerated in the July 2017 HLC letter? Does Midwestern plan to continue receiving federal funds? Will Midwestern become compliant with Title IX requirements, and if so, by what date? Does the seminary plan to continue the Doctorate of Counseling program in a way that fits both the seminary’s mission and meets national professional standards? Will you make any cost-benefit analysis and job-market analysis of this program you provide to accreditors available to Southern Baptists? Will the seminary be hosting a focused visit of HLC auditors by February 2019? Is this meeting already scheduled, and will you report on this meeting to the Midwestern Board of Trustees and the Southern Baptist Convention? Do you anticipate the accreditation matter will be clear before the SBC’s 2019 annual meeting in Birmingham? Do you anticipate reporting on this matter at that time? Has the seminary’s commitment to academic integrity been altered in any way to account for new faculty with a public record of plagiarism? What protocols are being strengthened to prevent known faculty plagiarists from appropriating the unattributed work of others in their current research at Midwestern?

Charles Spurgeon once said, “Ministers should be stars to give light, not clouds to obscure.” As you consider the responsibilities of administering Southern Baptist’s annual contribution of $6 million in addition to other resources and support, I ask you to give a little more light to these already-public matters and not seek to obscure in any way the seminary’s accreditation status and its strict enforcement of academic integrity in the face of faculty plagiarism concerns.

I anticipate your response.


Benjamin S. Cole

[1]http://sbcec.org/bor/2018/2018SBCAnnual.pdf, Page 58.



[4]https://www.hlcommission.org/download/_BoardActionLetters/Midwestern Baptist Theological Seminary Action Letter 7-17-17.pdf





[9]Andreas Köstenberger is truly a well-known and highly regarded New Testament scholar. I am curious, however, what impact the hiring of Köstenberger may have on Midwestern’s policy concerning plagiarism and academic integrity? On page 55 of the seminary catalogue, the plagiarism policy states clearly: “It cannot be exaggerated how strongly Midwestern deplores plagiarism in all its forms. Dishonesty is incompatible with the very purpose for which a student avails himself of its ministries. It is to be desired that one remain without a degree rather than to obtain it by dishonest means, for Christianity cannot countenance conduct that contradicts its basic tenets.” (See http://www.mbts.edu/downloads/_current_students/seminary_catalog_17-18.pdf).

Yet a mere 5 months earlier, Zondervan Academic’s Senior Vice President and Publisher, Stanley Gundry, released the following statement about Köstenberger: “In October 2017, Dr. Andreas Köstenberger informed Zondervan Academic that his commentary on the Gospel of John in volume 2 of the Zondervan Illustrated Bible Commentary: New Testament (ZIBBC: NT) contained ‘a series of inadvertently unattributed references” to D.A. Carson’s The Gospel According to John in The Pillar New Testament Commentary published by Wm. B. Eerdmans. After careful consideration of the evidence, we concluded that the problem was so extensive that there was no acceptable way to fix the problem. Since the commentary on John of ZIBBC: NT does not consistently follow commonly accepted standards for the use and documentation of secondary sources, our commitment to high publishing standards leaves us no choice but to put volume 2 of the ZIBBC: NT out of print in its print form and to destroy the remaining inventory. The digital formats of the John part of volume 2 are also out of print and withdrawn from the market.” (emphasis added) See: https://zondervanacademic.com/blog/statement-from-zondervan-academic-on-dr-andreas-kostenbergers-john-commentary/


[11]http://www.sbc.net/cp/ministryreports/2018/pdf/seminaries/mbts/mbts-presidents-letter.pdfand http://www.sbc.net/cp/ministryreports/2018/mbts.asp