Thank you for the opportunity to submit my comments on accreditation.
I hope they will be useful to the National Advisory Committee on
Institutional Quality and Integrity as it reviews and deliberates this
issue of national importance.
The historic role of accreditation
The American system of accreditation was created as a
non-governmental, collaborative, peer system of accountability. It was
designed to assure a minimum level of quality and to encourage
institutional self-improvement. Its focus rightfully should be on
accountability, transparency, and consumer protection.
American accreditation also resembles the nation’s historic
dispersion of political power, reflecting core ideals of federalism and
individual autonomy. Accreditation serves as one part of a three-legged
stool – accreditation, state government, and federal government.
Accreditation determines that the institution meets minimum standards of
quality, the state government sanctions its ability to operate, and the
federal government determines whether the institution is eligible to
receive federal funds.
While accreditation serves to ensure a level of quality education at
an institution of higher education, it is not attempting to distinguish
or define the quality. Accreditation serves to determine that the
elements for delivering a quality education are in place at an
institution. It does not distinguish whether the education at one
institution, such as Southeast Missouri State University, is of better
or lesser quality than the education offered at another university such
as Northern Kentucky University or CSU Northridge.
I am very proud of the role that AASCU and its sister organization
APLU have played in facilitating accountability, transparency, and
consumer protection among our own institutions with the development of
the Voluntary System of Accountability, which now involves 326 public
institutions. Accreditors can and should rely on
institutionally-determined and implemented outcomes measures to evaluate
quality assurance and improvement at the institution.
I believe that the system of accreditation that we have created over
the years has in the main done an excellent job of assuring quality
while preserving diversity and creativity. However, this series of
hearings reflects the need for all of us to consider accreditation in
the rapidly changing context of the 21st century.
1. The voluntary system of accreditation is substantially
better than a process designed and carried out by a governmental agency.
Our belief in the need to preserve a non-governmental system doesn’t
grow out of a defensive, self-protective reaction but instead emerges
from a careful study of accountability systems around the world. Most
countries employ a government-organized system of accreditation. Most of
those systems promote uniformity and adherence to a single set of
standards, while repressing innovation and new models.
2. Having said that, however, the American system needs to develop some new approaches to address areas of current concern.
The historic process of accreditation has focused largely on inputs. I
believe that we must focus substantially greater attention on outcomes.
In particular, I believe that we must pay greater attention to learning
outcomes for our students. Those outcomes must be broad, not narrow.
How well are institutions preparing students for work in a global
economy? How well are institutions preparing students for living in a
diverse, multicultural world? How well are institutions preparing
students to become informed and engaged citizens in our great democracy?
How well are institutions preparing graduates to think critically and
analyze thoughtfully? The accrediting community, to its credit, began to
address learning outcomes, beginning in the mid-1980s. But that focus
on learning outcomes, for far too long, was toothless. The focus on
learning outcomes must be accelerated and substantially improved.
A second concern is cost. The cost in both financial and human
resources is enormous. Are there ways that cost could be reduced without
jeopardy to the accreditation process?
A third concern involves the practice of purchasing an institution
and simultaneously accreditation, even though the faculty, curriculum,
and mission of the institution is substantially changed or eliminated.
A fourth concern involves developing better mechanisms to account for
rapid changes in delivery systems, program design, and instructional
practices. Technology continues to alter the ways that institutions
carry out their basic educational purposes. We need to ensure that
accreditation processes are as nimble as the rapidly-changing
educational landscape it monitors. Some regional accreditors, to their
credit, have created processes (Academic Quality Improvement Project
[AQIP] and Quality Enhancement Plan [QEP]) to allow institutions to
focus on new approaches but more such development is needed.
A fifth concern is that the current process allows groups of
institutions to gather together for self-accreditation. There is always a
tension in the self-regulatory process between high community standards
and self-interest. Usually, self-interest is addressed by having the
community diverse enough that any single institution’s self-interest is
subsumed by the community’s collective interest. But if a select group
of institutions, all similar in their self-interest, are allowed to
become their own accreditors, the self-interest of individual
institutions becomes paramount. That should not be allowed to happen.
3. The accreditation process should not be confused with the
Department of Education’s responsibility to determine institutional
Title IV eligibility.
The federal government now invests more than $150 billion in
financial aid programs. It is appropriate that the federal government
wants to have some accountability for that vast annual expenditure. And
it is also appropriate that accreditation be used as one measure of
eligibility for receiving federal funds. At times, the federal
government has placed requirements on accreditors to ensure that
taxpayer’s interests are best served. Some of these requirements make
sense and they are usually reviewed through a traditional accreditation
However, many of these requirements are legislative mandates on the
Department that have been inappropriately transferred to the
responsibility of the accreditors. The Department needs to move away
from its reliance on accreditors as enforcers. Perhaps a model can be
put in place in which accreditors merely inform the Department of their
decisions, whereafter the Department engages the institution before
making a decision regarding Title IV aid. The Department of Education’s
reliance on accreditors for enforcement has led to a diffusion of the
appropriate role for institutional accreditors and has fostered an
environment where the Department does not do an adequate job of
enforcing its own rules.
The diversity of accreditors has diffused, rather than focused,
appropriate federal concern about accreditation. There are regional,
national, program and career-specific accreditors. NACIQI should focus
its attention on recognition of institutional accreditors as part of the
Title IV eligibility considerations and should question whether
regional and national institutional accreditors should be treated
differently. AASCU recommends exploration of the concept of a "tiered or
developmental" approach to accreditor recognition as well as
disseminating the best practices of those agencies known to be
historically stable and clearly in compliance with all government
recognition criteria. We think NACIQI should choose to leave program and
career-specific accreditation issues to the states.
Accreditors need to shift the focus of their accreditation reviews
from process and input specific criteria to a greater concern about
student and learning outcomes. They need to consider institutional
reports of learning outcomes such as those to be reported as part of the
Voluntary System of Accountability. Institutional accreditors, not the
federal government nor the individual institutions, should establish
minimum standards for student and learning outcomes and should recognize
institutional achievements beyond meeting those minimum standards.
If the focus does shift from over-reliance on input standards, then
Department of Education regulations also need to shift, because they too
are overly process and input specific. The Department will need to
relax its expectations of accreditor enforcement of its requirements and
rely on its own resources for enforcement. It is appropriate for
accreditors to assist the Department with the protection of the taxpayer
in the vein of serving the public interest, but only on those levels
that are appropriate to the quality of education and an institution’s
ability to offer that education.
One of the initial purposes of accreditation was to help ensure
confidence in the quality of an institution’s offerings; the
accreditor’s role for providing consumer information should be expanded
to meet new and changing demands from consumers for reliable and
relevant information about the quality and outcomes of the academic
offerings of institutions. The quickly evolving state databases that
share common elements for accountability should be considered as a
source of such information that might readily be incorporated into an
institution’s pre-accreditation visit self-study. We also believe this
means an increasing reliance upon and distribution of consumer useful
data following an accreditation review.
Finally, AASCU challenges NACIQI to set a goal of having the public,
states, congress, parents and students better understand the
accreditation process and its necessity. The goal should be aimed at
helping them know what it is and what it does for students, institutions
and the public.
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