T
he higher education community and institutions of higher learning generally approve of a voluntary peer review process for quality assurance. In an article entitled “There’s A Lot That’s Right About Regional Accreditation,” Judith Eaton (2009, ¶ 4) noted thatPerhaps most important, regional accreditation is a successful model of a powerful professional peer review process by which academic quality can be judged. Peer review is acknowledged throughout the world as the most appropriate and desirable approach to the evaluation of such complex areas as higher education.
In thinking about accreditation, it is important to keep in mind that U.S. higher education is not monolithic and that the various institutional sectors do not necessarily agree on what the process of peer review should entail. For example, there is no agreement across sectors and institutions as to whether and how student learning outcomes should be assessed.
The federal government wants to assure that higher education delivered in the United States meets high-quality standards because higher education has become
increasingly essential in developing a citizenry prepared to participate in a knowledge-driven economy. A huge amount of federal funding (now reported to be more than
What’s an Accrediting
Agency Supposed to Do?
Institutional Quality and Improvement vs.
Regulatory Compliance
Do everything possible to let others know that we are open to discussion and that
we do not believe that everything we do is perfect the way it is.
by Elizabeth H. Sibolski
Elizabeth H. Sibolskiis president of the Middle States Commission on Higher Education, one of seven U.S. regional accrediting agencies. She is a past-president of the Society for College and University Planning and co-author of Integrating Higher Education Planning and Assessment: A Practical Guide(SCUP 2006). She holds Ph.D. in public administration and master of public administration degrees from American University.
$175 billion) goes into higher education annually (National Advisory Committee on Institutional Quality and Integrity 2011), and it is clear that the government and the general public have a right to know that these funds are well spent. At the same time, the press and the Congress (especially the Senate Committee on Health, Education, Labor and Pensions) have investigated and made public a number of situations in which it is clear that, at the very least, students have been misled and, in the worst cases, subject to fraud and abuse. The money involved, the high stakes of higher education, and the “bad actor factor” have naturally resulted in moves to protect the public interest through increasingly granular regulation and review processes.
Add to this mix the fact that the Higher Education Act is renewed and revised every few years, and in the months leading up to reauthorization, there is always a debate about how to improve the law and the regulations that flow from it. Current debate springs from passage of the Higher Education Opportunity Act in 2008 and ongoing related regulatory activity. In addition, the act will once again be up for review and reauthorization shortly, and the cycle will start again.
The higher education community supports peer review and institutional improvement as a means of assuring quality, but debates what should be involved. The federal government seeks to protect the public interest and the public purse through accountability, transparency, and compliance with regulation. All of this produces ongoing tensions in and for accreditation. Focus on institutional improvement or on compliance—what should an accrediting agency do?
The Context for U.S. Higher Education
Accreditation
A few words about higher education accreditation in the United States may be useful for readers who are not familiar with the subject. Those who are familiar with the structure of accreditation in the United States may wish to skip this section.
One important set of current definitions of accreditation is provided by the U.S. Department of Education: accreditation is “the status of public recognition that an accrediting
agency grants to an educational institution or program that meets the agency’s standards and requirements,” and an accrediting agency is the entity that “conducts accrediting activities through voluntary, non-Federal peer review” (U.S. Department of Education 2012, p. 4). An agency that meets the department’s requirements and demonstrates that its standards are rigorous and effective is determined to be “a reliable authority regarding the quality of the education or training provided by the institutions or programs it accredits” (National Advisory Committee on Institutional Quality and Integrity 2012, ¶ 1). Once an accrediting agency has met federal requirements and has achieved recognition by the Secretary of Education, it can serve as a gatekeeper for access to federal funding. However, each agency must regularly undergo review in order to maintain its recognized status. These regular reviews usually take place at five-year intervals, but additional follow-up may be required as necessary.
There are three principal types of accrediting bodies that may be recognized by the Secretary of Education and thus become gatekeepers for access to U.S. Title IV funding. First, national accreditors focus on the institution as a whole. Among the national accreditors are some that are faith-based and others that accredit career-based or single-purpose institutions.
Second, regional accrediting agencies also focus on the whole institution, and many can trace their origins back to the late 1800s. The New England Association of Schools and Colleges was founded in 1885, and the Middle States Association of Colleges and Schools was formed in 1887. The North Central Association of Colleges and Schools and the Southern Association of Colleges and Schools were established in 1895. The Northwest Association of Schools and Colleges followed in 1917, and, finally, the Western Association of Schools and Colleges was founded in 1924. As is clearly evident from the naming conventions of these agencies, regional geographic boundaries were established at the outset and have been maintained to present times even though geography is much less relevant today.
Programmatic or specialized accrediting agencies make up a third group of accreditors that may be recognized by the Secretary of Education. These agencies focus on a specific academic discipline such as business, law, or medicine.
Regardless of the type of agency, accreditation addresses the following roles (Eaton 2011):
• Assuring quality,
• Providing access to federal and state funds,
Focus on institutional improvement
• Engendering private-sector confidence (e.g., among employers), and
• Easing transfer of student credit among institutions. There are a number of resources available to readers interested in learning more about higher education accreditation in the United States. One of the best general discussions about the history of U.S. accreditation can be found in “Accreditation in the United States: How Did We Get to Where We Are?” (Brittingham 2009). A number of publications and other resources, many of which can be found online at www.chea.org, are available from the Council for Higher Education Accreditation. Among these are The Fundamentals of Accreditation: What Do You Need To Know?(Council for Higher Education Accreditation 2002); “The Value of Accreditation: Four Pivotal Roles” (Eaton 2003); and An Overview of U.S. Accreditation(Eaton 2011).
Additional resources about U.S. higher education accreditation are available from each of the accrediting agencies. For example, the Middle States Commission on Higher Education (2009) has published Highlights from the Commission’s First 90 Years. This and other documents concerning Middle States’ accreditation standards and processes are available online at www.msche.org.
The View from a Regional Accrediting
Agency
An emphasis on quality.As noted previously, regional accrediting associations were initially founded by educators to serve the common goals and purposes of member institutions. In the case of Middle States, the original objectives of the association were
to standardize the qualifications required for admission to college; to determine the desired characteristics for college preparatory schools; to recommend courses of study for both colleges and schools; to foster relationships among schools, colleges, and the government; and to study and recommend best practices of organization and governance. (Middle States Commission on Higher Education 2009, p. 2)
It was not until the 1920s that Middle States institutions achieved approved status by verifying compliance with accreditation guidelines through completion of “definitions and standards” questionnaires and application forms.
During these early years, institutions were added to the approved list following inspection visits that usually were made by a single individual. In the 1930s, the designation of “approved” was dropped and institutions were identified as “accredited.” The 1940s brought the use of evaluation teams to replace inspection visits by an individual, and emphasis shifted from “the maintenance of minimal standards to the improvement of institutions” (Middle States Commission on Higher Education 2009, p. 5). In 1957, a cycle of re-visits at approved/accredited institutions was instituted. That practice was found to be so useful that “the Association agreed, without dissent, to have the practice continue on a regular basis at 10-year intervals” (Middle States Commission on Higher Education 2009, p. 6). As the years passed, accreditation standards and processes were refined. By the 1970s, comprehensive self-studies were expected from institutions, and a new standard report was added in the fifth year of the accreditation cycle. In the years since, an optional alternative to the traditional self-study approach has been added to provide for institutional focus on selected topics, collaborative reviews with other agencies have been introduced, and the commission has devoted increasing attention to the provision of training and orientation programs that assist member institutions and volunteer peer evaluators in understanding their roles and responsibilities (Middle States Commission on Higher Education 2009).
The commission has regularly reviewed and revised its accreditation standards and processes over the years. In the 1990s, standards were less specific than they are today. For example, the 1994 Middle States publication on standards for accreditation had this to say about institutional effectiveness and outcomes:
Institutions should develop guidelines and procedures for assessing their overall effectiveness as well as student learning outcomes.… The process of seeking such evidence and its subsequent use helps to cultivate educational excellence.… The plan for the assessment of outcomes should attempt to determine the extent and quality of student learning. (Middle States Commission on Higher Education 1994, pp. 16–17)
In the decade that followed, institutions increasingly noted that the commission’s expectations were not clear Elizabeth H. Sibolski
enough, and the commission learned that these statements about the assessment of outcomes were not as specific as they needed to be. When the standards were fully reviewed and overhauled, effective in 2004, these problems were addressed. Henceforth there would be two standards dealing with outcomes assessment—one focusing on the assessment of student learning and the other focusing on institutional assessment. In addition, an expectation for “closing the loop” would be clarified in statements explicitly connecting assessment to planning and resource allocation.
This short trip through the history of one accrediting agency provides a means of making some important points. First, the development of accreditation activities has been evolutionary rather than revolutionary. Further, because regional accrediting agencies are nongovernmental membership organizations, their college and university members are ultimately responsible for decisions made about the content of the standards for which each institution will be held accountable.
Another point that can be drawn concerns the ongoing emphasis placed on improvement. For example, some believe that accreditation requirements have been the driving force behind today’s emphasis on assessment. The journey toward assessment has not been smooth to date and will not be smooth in the future, but regional accreditation has provided a venue for discussion and establishment of some common expectations.
Federal regulatory controls from the accreditor’s perspective.The developmental story for each of the regional accrediting agencies is somewhat different, but the goals of these organizations probably would have remained focused on institutional quality and improvement had there not been increasing attention from the federal government. This situation began to develop in the 1950s, when significant federal student financial aid was provided to GIs and that aid was linked to accredited institutions. While certainly good for the GIs and for the institutions they attended, with hindsight we now know that this represented a “foot in the door.” Since that time, more and more federal funding has been poured into higher education, and, as gatekeepers for access to that increasingly important funding, accrediting agencies have been a point of access for the introduction of increasingly granular regulation.
With each reauthorization of the Higher Education Act, the number of issues covered by federal regulation has grown. For example, following passage of the Higher Education Opportunity Act of 2008 and negotiated
rulemaking, the Department of Education issued a number of revised and new regulations. These covered topics such as distance education and the verification of the identity of students undertaking education via this modality; confirmation that institutions have and disclose transfer-of-credit policies; credit hour definitions and regulatory requirements; state authorization, especially as it relates to distance learning undertaken by residents of various states; the elimination of safe harbors for incentive compensation as related to enrollment and financial aid; engagement in substantial misrepresentation; and gainful employment rules related to programs that are focused on providing the education and training necessary to secure employment in a recognized occupation.
How have these regulatory developments affected the work of accreditation? Certainly not all of them have had the same impact, but they all require understanding and communication with member institutions and the general higher education community, and some require much more—up to and including the development and introduction of new policies and procedures to ensure compliance. In at least one case—the credit hour rule—the sweep of regulatory activity has entered the academic realm in a new and unsettling way.
Then there is the process through which accrediting agencies must apply every five years for continuing recognition as gatekeepers for access to federal Title IV aid. The guidelines provided by the Department of Education to assist accreditors in preparing petitions for recognition have grown to 88 pages of detailed information about what must/should be provided.
Following a two-year hiatus, the National Advisory Committee on Institutional Quality and Integrity (NACIQI) was reconstituted in late 2010. Departmental staff review and analyze the petitions for recognition received from accrediting bodies and provide information to NACIQI that is taken into consideration as that body makes a recommendation to the secretary about agency recognition. Since 2010, the scope of departmental and NACIQI review has been characterized as granular. Omissions or deficiencies small and large lead to findings of noncompliance and extension of a 12-month period during which all issues must be addressed. In the December 2011 NACIQI meetings, virtually all of the accreditors up for review were faced with this situation.
Seeking an appropriate balance.Where does this leave an accrediting agency? Initially, our purpose was
focused on quality and institutional improvement, and this has continued to be an essential foundation of accreditation. Indeed, the federal government and the public continue to look to our agencies to be reliable authorities regarding the quality of education and training offered by the institutions that we accredit.
At the same time, accrediting agencies have become responsible for increasingly granular and intrusive regulatory and compliance-based activity. The introduction of these regulatory responsibilities has been determined to be necessary for the public good, and, to date, accreditation has been seen as the best method to address compliance issues.
It is also important to note that the introduction of increasing regulatory requirements is coming at a less than opportune moment for most institutions of higher education. Budgets have been tight for several years—particularly for public institutions—and there is little evidence that the situation will change in the near future. Where new regulations mean changes and additions to campus-based record keeping and other processes, added pressures are felt, and it is often easy to blame the accreditor for the increasing cost of accreditation.
The result of this situation is some institutional unhappiness with accreditors as well as growing tension between the original quality and improvement purposes of accreditation that were established by member institutions and the compliance-based requirements and needs of the federal government on behalf of the public interest.
A View from the Federal Perspective
Regulatory controls.The discussion to this point has focused primarily on the perspective of the accrediting agencies and somewhat on that of the institutions that are members of these associations, but what about the federal perspective?
Beginning in the 1950s, the federal government has invested increasing amounts in higher education. In just the last few years, the annual federal investment in higher education has nearly doubled from $90 billion (Brittingham
2009) to a current total that is reported to be more than $175 billion (National Advisory Committee on Institutional Quality and Integrity 2011). For that investment, and without reference to any other factors, taxpayers deserve accountability. The public has a right to know something about how its tax dollars are spent.
Beyond the sheer amount of money involved, there are other reasons why the government and the public should be concerned with accountability. Periodically, questions are raised by representatives of the media, public watchdog organizations, governmental investigatory agencies, Congressional committees, or others about abusive practices in higher education. Some of these abusive or potentially abusive practices have been quite serious, and some of the institutions involved have been accredited by agencies that are recognized by the Secretary of Education, including regional accreditors.
Investigations have led to Congressional hearings, extended television and press coverage, and other forms of reporting about abuses and outright fraud. The presence of high-pressure “sales” tactics, the enrollment of students who will find it difficult or impossible to complete a degree or other credential, and the generation of debt that students and their families are unlikely to ever be able to repay are just a few of the revelations that have surfaced.
Perhaps in a kinder, gentler era there was a public trust that higher education represented the path to a better life. However, what the public experiences and learns about through the media concerning higher learning paints a very different picture today—one that suggests that more consumer and public protections are needed.
Given the actions of some accredited institutions and the growing recognition that students and their families, as well as taxpayers, may be taken advantage of, it should be no surprise that the federal regulations governing higher education and accreditation would be expanded and tightened. One answer to the concern over fraud and abuse has been the creation of new regulations, some of which are to be enforced by accrediting agencies. A few of the newest regulations have already been mentioned. Elizabeth H. Sibolski
The government and public look
to our agencies to be reliable
authorities regarding quality.
The public has a right to know
something about how its tax
dollars are spent.
The problem of oversight to prevent fraud and abuse becomes somewhat more complicated when one considers recent revelations. For example, institutions are cautioned to be watchful regarding fraud by students applying for financial aid, a serious concern even if it did not involve systemic thefts by groups moving from one campus to another, intent only on collecting aid dollars.
How are issues of regulation and oversight to be addressed? The federal government and accrediting agencies do not stand alone. Of late, there has been increasing interest in what is known as “the Triad.” In addition to the accreditors and the federal government, states also play a significant role in the oversight of higher education. Although oversight structures and responsibilities vary greatly from state to state, the responsibility for licensure/ charter and for various types of regulation rests here.
Seeking an appropriate balance. What is the picture that is painted from the federal perspective? Higher education is important to the future of this nation and therefore is worthy of significant federal investment; however, there are bad actors out there perpetuating fraud and abuse at multiple levels, and the oversight and enforcement Triad does not seem to be working as effectively or efficiently as is needed. This describes an additional set of tensions that exists today that should and will be addressed in some way.
Can’t (and Shouldn’t) Have One Without
the Other
It appears that we have reached a point where we should not expect there to be only one prevailing view of higher education. Realistically, we cannot expect to return to that kinder and gentler age (that may or may not have ever existed) when higher education was placed on a pedestal and honored for the pure “good” it was thought to represent. However, higher education still represents an important public priority for individuals and a nation that must operate in a sophisticated information age. The positive aspects of higher education should be encouraged and supported, while fraud and abuse at any level should be found and eliminated. This position recognizes the necessity of reviews focused on both institutional quality and improvement and regulatory compliance.
The issue seems to be, how do we best organize to address quality/improvement and regulatory compliance? The following points may suggest a foundation for further discussion and exploration:
• Let’s recognize that we are in a period of disruption and transition that is unlikely to abate any time soon. Changes in the landscape of higher education coupled with the current economic context suggest that we may wish to reexamine elements of accreditation and other oversight and regulatory compliance activities that are necessary now and likely to be needed in the future. • Instead of focusing on only one area at a time (e.g.,
on fixing accreditation), perhaps it would make more sense and be more efficient to look at the overall picture. The Triad is a part of this, but we should also consider the roles and responsibilities of institutions and other constituencies.
• While it is very easy to get caught up in the minutia of regulation, this may be a good time to focus on what is really important rather than on the granular detail. Above all, let’s not get so caught up in process points that we stop thinking about broad policy content. Discussion and exploration is a place to start, and there are some current initiatives that may prove helpful. NACIQI has been asked to provide the Secretary of Education with recommendations for consideration during the next renewal cycle of the Higher Education Act. NACIQI has been working on that project and is expected to release its final report later this spring. Discussion at the NACIQI hearing held at the end of 2011 suggests that the final report may offer a significant list of topics for further study, but that de-linking accreditation from Title IV probably will not be recommended.
A second important initiative is the formation of the National Task Force on Institutional Accreditation by the American Council on Education. To date, that group has held a number of meetings, and its report is also expected later this spring.
So What
Should
an Accrediting Agency
Do?
Some have suggested that accreditors, especially in public pronouncements, appear to be complacent, that we appear to be set in our ways and unwilling to acknowledge changes that need to be made. From inside an accrediting agency, that unflattering characterization does not seem at all accurate. No matter how we accreditors may have achieved our current reputation or how accurate it may be, we do need to do everything possible to let others
know that we are open to discussion and that we do not believe that everything we do is perfect the way it is.
Critiques of the current accreditation system and hearings/discussions that are taking place within the NACIQI and the American Council on Education task force represent necessary steps toward figuring out what should happen next with regard to oversight of institutional quality and improvement as well as regulatory compliance. In the interest of developing the best systems possible, current discussions and debates should be extended to include all of the members of the Triad as well as other interested parties.
Another way that accreditors can provide guidance is by focusing on what is truly important in reviewing institutional quality and promoting institutional improve-ment. As nongovernmental membership organizations, we have the means and ability to do this. Working cooperatively in a collegial process, we can define what is important and put in place the systems that are necessary for today and the years ahead.
The author wishes to note that the views expressed in this article are hers and do not necessarily represent positions that have been or will be taken by the Middle States Commission on Higher Education.
References
Brittingham, B. 2009. Accreditation in the United States: How Did We Get to Where We Are? New Directions for Higher Education, no. 145, 7–27.
Council for Higher Education Accreditation. 2002. The
Fundamentals of Accreditation: What Do You Need To Know?
Washington, DC: Council for Higher Education Accreditation. Eaton, J. S. 2003. The Value of Accreditation: Four Pivotal Roles. Washington, DC: Council for Higher Education Accreditation. ———. 2009. There’s A Lot That’s Right About Regional
Accreditation. Inside Accreditation 5(1): 1.
———. 2011. An Overview of U.S. Accreditation. Washington, DC: Council for Higher Education Accreditation.
Middle States Commission on Higher Education. 1994.
Characteristics of Excellence in Higher Education: Standards for Accreditation. Philadelphia: Middle States Commission on Higher Education.
———. 2009. Highlights from the Commission’s First 90 Years. Philadelphia: Middle States Commission on Higher Education. National Advisory Committee on Institutional Quality and Integrity.
2011. NACIQI Discussion Draft: Higher Education Accreditation Reauthorization Policy Considerations. Retrieved February 13, 2012, from the World Wide Web: www2.ed.gov/about /bdscomm/list/naciqi-dir/hea-recommendations.pdf.
———. 2012. Purpose and Importance of the NACIQI. Retrieved February 1, 2012, from the World Wide Web:
http://ed.gov/about/bdscomm/list/naciqi.html.
U.S. Department of Education. 2012. Guidelines for Preparing/ Reviewing Petitions and Compliance Reports in Accordance with 34 CFR Part 602 The Secretary’s Recognition of Accrediting Agencies. Unpublished document.
