By Ralph A. Wolff
Regional accreditation—long an overlooked corner of higher education—has lately come under fire from multiple directions: From the government, which tends to see accreditors as too lax; from institutions, which often resent the administrative burden and perceived presumptuousness of accreditation agencies’ scrutiny; and from outside players who see regional accreditors either as ineffective in dealing with low-performing institutions or as part of a cabal devoted to keeping innovative competitors from entering the marketplace.
While many of the criticisms are not new, the combination of voices from both outside and within higher education suggest this may be a time when the role and value of accreditation will become a significant part of the conversations surrounding the impending reauthorization of Higher Education Act. The criticisms have been heightened by comments from President Obama, congressional hearings challenging the cost and effectiveness of accreditation, and a spate of reports calling for its reform or even elimination as a gatekeeper for access to federal financial aid.
In a supplemental statement to his 2013 State of the Union address, President Obama directly challenged accreditation, calling for Congress to “consider value, affordability, and student outcomes in making determinations about which colleges and universities receive access to federal student aid, either by incorporating measures of value and affordability into the existing accreditation system; or by establishing a new, alternative system of accreditation that would provide pathways for higher education models and colleges to receive federal student aid based on performance and results.” The president has already moved to establish a ratings system for higher education institutions, and proposals to restructure accreditation may well come next.
In hearings before the House Subcommittee on Higher Education and Workforce Training, chaired by Rep. Virginia Foxx (R-NC), critics of accreditation aired their concerns, including perceptions of excessive cost, an inability to support innovation, and a failure to address a decline in institutional quality and effectiveness. Recent reports and policy convenings have echoed many of these concerns in an orchestrated effort to promote major changes to accreditation.
It is time to address these concerns head on, and determine whether the current structure of regional accreditation, organized into six regions and seven accrediting commissions, is worth preserving or whether it is time to try something new. It is no longer sufficient to say that accreditation’s greatest value is that it is the least offensive alternative to a federal system of higher education regulation.
As one who has led an accrediting agency amid many of these concerns for nearly two decades, I believe that accreditation remains a robust system and that the peer review process at its core is worth fighting to preserve. U.S. accreditation continues to be seen as the gold standard for quality assurance in the rest of the world.
So why is it the Rodney Dangerfield of higher education? Most criticism of accreditation falls under one or more of the four broad misperceptions, each of which relies on an outdated or insufficient understanding of how modern accreditation actually works:
1. “No one knows what accreditors really do.”
Accreditors, along with institutions, long took the view that the best way to ensure candor and integrity in the self-evaluation and peer review process is to keep the key elements of the process—the institutional self-study and the team report—private between the accrediting agency and the institution, reporting publicly only the generic accrediting action.
But this view is changing, and several accreditors are moving rapidly to make the process more transparent. The Western Association of Schools and Colleges (WASC) Senior College and University Commission has for more than a year published on its website team reports and detailed commission action letters. Among WASC’s fellow regional accreditors, the Higher Learning Commission is moving to do something similar within the next year, and the Middle States Commission on Higher Education has expanded the information provided on the reasons for its actions.
Only through greater transparency will institutions and policymakers be able to see the depth and quality of institutional reviews. We need to be proactive in defining ways for the accrediting process to be more transparent so that the policymakers and other institutions of higher education can see for themselves the criteria applied to ensure institutional quality and integrity.
2. “Accreditors can’t make tough decisions.”
Actually, the process of getting accredited is a demanding one, and many institutions don’t make the cut. A study conducted for the ACE National Task Force on Institutional Accreditation found last year that more than 40 percent of institutions are not successful in achieving accreditation from a regional accrediting agency. Institutions that do gain initial accreditation are subject to regular, exhaustive reviews and a full spectrum of sanctions to alert the institution and the public of major problems, ranging from a notice of concern to probation and termination.
Ironically, accreditors act far more expeditiously than the Department of Education in addressing problems with institutional performance, only to face criticism when tough actions are taken. When institutional conditions compel accreditor actions such as termination, appeals processes can take six months to a year to ensure that there was sufficient evidence and a fair process to reach such decisions. Here again, greater transparency will demonstrate that accrediting agencies are taking the appropriate steps in light of the evidence reflected in a peer review report. Several recent and highly publicized cases where accreditation has been terminated attest to accreditors’ willingness and ability to act decisively when institutions fall below standards and needed changes are not made quickly.
3. “Accreditors don’t pay enough attention to results.”
The most frequently cited basis for sanctions or termination of accreditation is financial unsustainability or serious breaches of institutional integrity. Unlike metrics for finances and indicators of institutional sustainability, which are clearly quantifiable and well-established, indicators and metrics that examine completion rates and learning outcomes are far more murky and challenging. That is because there are significant ranges of results in both areas when comparing open-access and highly selective institutions, and because our ability to analyze retention rates is limited by the lack of comprehensive data that tracks results beyond those captured by the federal government’s traditional Integrated Postsecondary Education Data System (IPEDS) reports.
Secondly, higher education is still a long way from effectively evaluating what an acceptable completion rate is within the context of each institution’s mission and student characteristics. WASC’s Senior College and University Commission took up this issue head-on in its major reforms last year by calling for review and evaluation of all undergraduate and graduate programs. Together with its institutional partners, WASC has developed templates to capture more comprehensive retention and completion data, which each institution can use to assess its own performance and develop plans for improvement, followed by analysis by a trained peer review panel.
Pilot implementation of this effort has shown how critical the need is for comprehensive retention/ completion data beyond the limitations of traditional IPEDS reports, and how important disaggregating results is to understanding the larger issues of retention and completion. It takes some time to gather ever more comprehensive retention and completion data to be included in the new federal ratings scheme.
Even more challenging is reviewing the data and attempting to assess what rate of completion is “good enough” in light of the incredible diversity of students within as well as across institutions.
Still, if we are not prepared to make judgments about what is good enough, who will? We may soon find a single, federal standard imposed upon us if we are unwilling to set our own standards based on institutional mission and student characteristics. President Obama’s new ratings system includes comparative completion data, and already the initiative is being taken from academe.
Much of the same can be said for evaluating learning results. While accreditors can rightfully take much of the credit for requiring the assessment of student learning (validated by many surveys and studies), assessment is not the same as demonstrating effective learning. Accreditors must work with institutions to more publicly describe both the content and level of graduates’ learning, and demonstrate that students can apply their learning to the world outside academe.
In this area, the WASC Senior College and University Commission took a bold step by calling for all undergraduate degrees to achieve a set level of proficiency, determined by the institution, in five core competencies considered foundational to a bachelor’s degree: written and oral communication, critical thinking, quantitative reasoning, and information literacy.
To help institutions define more clearly how proficient their graduates must be in key areas, WASC piloted Lumina Foundation’s Degree Qualifications Profile with 28 institutions, ranging from large public campuses to online universities. At the request of our art-focused institutions, the accreditation agency also added creativity and innovation to our standards of learning. WASC even runs an assessment leadership academy to develop the talent to undertake learning outcomes assessment thoughtfully, and in ways that will lead to higher standards of learning. The Higher Learning Commission and the Southern Association of Colleges and Schools similarly lead major educational workshops and academies to train faculty and staff on how to create cultures of learning within institutions.
4. “Accreditation is too costly for the value added.”
The direct cost of accreditation—paying for the travel of a peer review team—is small, especially given the quality of volunteer peer reviewers who give their time for the improvement of institutional quality. The most significant cost is the amount of institutional time and energy devoted to the self-study process for a period of a year or more. Undertaken every six to 10 years, depending on the region, the process pays lasting dividends in the form of durable institutional improvement, but it might also be useful to set the process in a larger context: Institutions do not balk at the substantial costs of an annual financial audit, but are far more prickly about the costs of the accreditation process, which should be seen as a periodic academic-quality review.
Also underlying this critique is the premise that many well-established and high-performing institutions do not require the same kind of time-consuming scrutiny as others. Most accrediting agencies have attempted to be sensitive to these concerns and cost issues, and have allowed for the self-study process to focus on issues found to be of greatest consequence—especially improving completion and student learning. Still, much more can and should be done to focus the accrediting process, including data analysis, more focused reports, and attention to areas that will have particularly great impact. The ACE task force report on accreditation last year posed a sensible solution, calling for a risk-based model that will allow for a more limited review process for institutions that have previously demonstrated excellence. Already, several accrediting agencies have moved—within the extent allowed by federal oversight—to permit adaptations for institutions with a strong track record.
Evaluating the alternatives
As detailed above, accreditors have been changing in response to both institutional changes and the external environment, but many would assert that these changes do not go far enough, and the process of peer review is itself no longer effective. So would the alternatives being proposed make the situation any better? Consider:
A free-market approach. This would have the federal government undertake a limited review of finances, default rates, and completion results. Once an institution had cleared this minimal threshold, students would have to depend on advertisements, marketing, and other unverified information when choosing which institution to attend. Quality improvement would be optional. Even critics who have weighed this approach consider it dangerous for the public and the institutions themselves.
The federal option. There are those who even suggest that direct federal intervention might be more effective than regional accreditation in guaranteeing accountability. Given the rigidity of the federal regulatory process and the narrow interpretation of regulations already on the books, including the imposition of the federal credit-hour definition, this alternative seems highly undesirable and unlikely to succeed.
Segment accreditation, allowing for separate standards for different categories of institutions. Several highly selective institutions have suggested that there is little need for a rigorous review of their performance, and that they should define their own standards. In the same vein, community colleges, faith-based institutions, liberal-arts colleges, for-profit institutions, and other higher education segments might create their own accrediting agencies and processes. But one of the greatest virtues of regional accreditation is its ability to pull together all the segments and collectively engage this diverse community into setting and applying standards across the entire higher education spectrum. Given that today’s graduates all need to compete in the marketplace, segmenting accreditation would only silo institutions from each other.
There are still greater ironies laced into criticisms that accreditation is on the one hand too laissez faire, yet somehow simultaneously too rigorous: With the recent advent of massive open online courses (MOOCs), more widespread competency-based direct assessment programs, and other forms of innovation and disruptive practices, critiques of accreditation have shifted quite dramatically from accreditation’s need for greater attention to accountability to its need to embrace and promote innovation. In fact, when accreditors years ago moved to approve online and competency-based institutions and programs, they faced just as much criticism for embracing innovation as they do now for blocking it.
Not all innovation is automatically good. To protect students and taxpayers, new enterprises need to establish both their quality and sustainability. At the same time, we need to make sure that it doesn’t take too long for an institution with new ideas or approaches to get accredited on its own, without acquiring another institution.
Accrediting agencies have already demonstrated that they can effectively strike that balance between experimentation and ensuring quality and integrity: The New England Association of Schools and Colleges moved efficiently, for example, to review and approve the Southern New Hampshire University competency-based direct assessment program, and both the Higher Learning Commission and the WASC Senior College and University Commission have done likewise in approving other such programs.
Finally, as we move into the beginning stages of reauthorizing the Higher Education Act, it will be vitally important for the higher education community to internally resolve its accreditation concerns. Given that all of the regional accrediting agencies are membership organizations—a fact seen as a liability by outsiders—it is the responsibility of the higher education community at all levels to become more knowledgeable and more engaged with academe’s core quality assurance system.
Without more engagement from institutions, more transparency from the regional agencies, and a greater willingness on the part of policymakers and others to look more closely at the pivotal function that accreditation plays, it will never realize its full capacity to help institutions help themselves stay accountable, and higher education may well lose the privilege and responsibility of self-regulation that accreditation provides.
Reprinted from the Winter 2014 edition of ACE’s flagship magazine, The Presidency.