News, Views and Careers for All of Higher Education
Nov. 30, 2006
As she formally opened the Education Department’s forum on higher education accreditation Wednesday, Vickie Schray, an aide to Secretary Margaret Spellings, clearly sought to reassure those participants and onlookers who have feared that the department has an aggressive agenda up its sleeve to revamp higher education’s system of quality assurance, in line with the recommendations of the Secretary of Education’s Commission on the Future of Higher Education. “Today’s meeting is not about criticizing,” she said, adding, “We’re not here to reach consensus about any of this.”
Yet two hours later, after leaders of the various small group discussions reported back on what had been said around the eight-person tables, Schray seemed almost giddy that many of the participants had acknowledged the need for colleges to use and report common measures of what, and how successfully, their students learn. “Nobody shied away from comparability,” Schray said. And Spellings herself, when she addressed the group, said she too was “struck by the commonality of thought here.”
Some participants agreed. Margaret A. (Peg) Miller, a higher education researcher at the University of Virginia who spoke forcefully near the start of the meeting about the need for college officials to get with the Spellings commission’s program, said afterwards that she had been pleasantly surprised by “how far higher education seems to have come in seeing the value of publicly reported data” that can be compared among “peer institutions.”
Miller qualified that statement, though, by noting that the nearly 60 college officials, accreditors, business leaders and other invited to participate in Wednesday’s forum came largely from the public sector and excluded all but two representatives of private nonprofit colleges, the sector of higher education that has expressed the most qualms about the possibly of government-mandated requirements that colleges use similar measures. “The outliers are not here,” Miller said.
Even so, the call for comparability was far from unanimous. “At our table ... there was a great deal of concern about comparability,” said Terry W. Hartle, senior vice president for government and public affairs at the American Council on Education. “I think institutions can and should be pushed to do more on this, and to be more transparent about it. But any effort to force or propose some sort of comparability standard will be enormously complex and exceedingly controversial.”
Added Judith S. Eaton, president of the Council for Higher Education Accreditation, a membership group that coordinates accreditation nationally and recognizes more than 60 regional, national and specialized accrediting groups. “They may claim that they have agreement about moving to common templates. But we fought over that tooth and nail in our group.”
Wednesday’s discussion was the most tangible step so far by the Education Department to begin carrying out the recommendations of the commission that Spellings appointed to examine the current state and the future of American higher education. Although the panel offered ideas on a wide range of topics and issues, including increasing need-based financial aid for students, expanding access to underrepresented students and significantly greater accountability, department officials have made accreditation their first order of business for two reasons: (1) they believe accreditation can be an important lever in achieving other changes, and (2, and more pragmatically) they believe it is an area where they can achieve the most without having to seek Congress’s approval.
Department officials have already floated the possibility of using an upcoming process of federal rule making to carry out changes in the regulations governing accreditation. They have also asserted frequently that the standards used by the department’s National Advisory Committee on Institutional Quality and Integrity, which provides to or withholds from accreditors the authority to approve individual institutions or academic programs, could be used to force changes in how accrediting groups operate. That panel next meets next week, and some accrediting officials said they expected the committee to begin to flex its muscle then, perhaps holding some accrediting groups’ feet to the fire on learning outcomes.
At Wednesday’s meeting, department officials struck a collaborative rather than confrontational tone. “I’m here to allay some of your fears,” Spellings said to the group. “I fully understand that this is not a place where one size fits all is either desirable or workable,” she said about the measurement of learning outcomes. “I value the great diversity” of higher education.
But she also made clear that while department officials were hopeful that academics themselves would get behind the movement to use the accreditation process to better measure how well students are learning — “we’re going to do this with you, not to you” — time was of the essence. “There are some things that we can do, and let’s not let the perfect be the enemy of the good,” she said. “This is something we need to get about quickly.”
Many participants in the meeting did indeed seem open to the need for significant changes in accreditation, particularly in how hard the process pushes institutions to show that they are succeeding in educating students. Many accrediting and college officials have objected to the constant characterizations by the Spellings commission and department officials that they have done little to assess how well students learn, noting that accrediting groups have been much more aggressive in recent years about insisting that colleges assess their own performance on that score.
But it is one thing for a college to use its own or external measures to assess how well it is doing, and quite another for individual institutions — and higher education generally — to show the world that students are learning, which is the stated goal of the Spellings panel and department officials. The only way that colleges can be held accountable for their performance, this line of thinking goes, is if they use measurements or tools that can be compared to those used by other institutions, too — and if the results are then made public in a way that allows consumers and policy makers to judge how they’re doing.
“In the past years, there has been tremendous development in self-improvement, in the use of student learning outcomes to energize campus discussions,” said Peter Ewell, vice president at the National Center for Higher Education Management Systems and one of the country’s leading experts — for nearly 25 years, he noted with some irony — on higher education accountability. But “asking campuses to do assessment is not the same thing as assuring” that all graduates are achieving and of making it public. “Addressing the issue of comparability requires external benchmarks,” and while standardization — in the form of testing — “is the easy answer,” it may not be the only one, Ewell said. He cited externally validated electronic portfolios and “discipline-based capstone” experiences as other possibilities.
Participants through out a slew of ideas for how higher education — perhaps through the accrediting process, perhaps not — might develop a set of student learning measures that might be comparable from one institution to another (most likely within sectors or groups of institutions with common missions: public research institutions, say, or for-profit institutions that serve adults). Several cited the voluntary system that the National Association of State Universities and Land-Grant Colleges and the American Association of State Colleges and Universities are jointly developing, while Jane Wellman, a higher education consultant, said American college officials might consider defining a common understanding across institutions of expectations for degree level work, like the National Qualifications Framework that European countries are crafting.
Others suggested that accrediting groups might develop menus of acceptable measurement tools, to which institutions could seek to add their own measures upon approval by the accrediting groups or perhaps a new third-party entity. Still others suggested that the department should focus instead on building up its own data collection system, constructing a “huge database” of information on student outcomes and other issues.
For all the brainstorming, though, it was difficult to walk away from Wednesday’s meeting with a clear sense of where this conversation was heading, and whether there was anywhere near a consensus on even which direction the next baby steps should go in.
In an interview with reporters, Spellings, for her part, acknowledged that that was to be expected, given that this was an “opening discussion.” She said that she would “take [college and accrediting officials] on good faith that they’re willing to get to work right away, as I am,” and that she had “no predetermined timelines” for when she needed to see progress. But she implied, clearly, that she would not wait forever.
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One of my many concerns with the Spellings report and with actions stemming from it have to do with who is determining the standards for “comparability.” What happens if those standards diverge from what educators think/know/understand (based on experience) are appropriate? This is an issue that we in composition face frequently (i.e., when one ‘arm’ of an institution determines that one kind of writing assessment is ‘appropriate’ for one purpose or another, but it doesn’t reflect what compositionists shaping/teaching in the writing program believe about writing). The conceptualization issue seems to be absolutely essential here. I haven’t seen/heard much about this — others?
Linda Adler-Kassner, Writing Program Administrator, at 8:31 am EST on November 30, 2006
The contrasts in this country right now are dizzying. We are putting up with “child-led” homeschooling AKA “unschooling” while demanding a common measurement system from IHE’s. I see this as a sign of lack of common ideals in regard to education.
At our college we have been assessing student outcomes since the late 80s. But this effort mostly yields long reports rather than simple numbers that can be put into a comparative table.
Grocheio, Asst VP Planning and Institutional Effectiveness at Shorter College, at 9:25 am EST on November 30, 2006
The previous comment is right on target. Writing lies at the crux of the problem, because it is at once a basic skill we measure among elementary students, a higher-order skill we measure among college students, the primary means of assessing other higher-level skills such as critical thinking, and even the primary means of teaching those other higher-order skills, in all subjects.
Linda, what a ripe time this is for writing professionals themselves to step up and control the process of developing standards! Who could do that better? What could be of more use to higher education in the quality/accountability debate? Writing professionals could provide the leadership on this issue: they need only a little less slant toward individual perspective and a little more slant toward common goals.
Merilee Griffin, at 10:15 am EST on November 30, 2006
From those of us not attending, thanks go to Doug for keeping us informed.
The point quickly needs to be made that the procedural model which NACIQI follows is “process” based, whereas the legislative intent of HEA 1992, Part H, is for “minimum standards” that the accreditation agencies must have in order to be recognized by the Sec. for access to Title IV funds. At present, the rubber-stamp renewal process conducted by NACIQI is fundamentally at odds with what Congress intended. This is an example of what could be called the accountability gap in American higher education.
But there is even a bigger obstacle to using NACIQI to “hold some accrediting groups’ feet to the fire,” and that is the Atomic Bomb problem that has stymied efforts in this direction for decades. The “Atomic Bomb problem” refers to the devastating effect accrediting agency derecognition would have on the finances of colleges and their students. Over the years, this politically unacceptable consequence has acted as an effective deterrent, preventing the delisting of any major accreditor and most others as well. This problem continues to cripple the quality control function of OPE, and it also completely undermines the gatekeeping credibility of NACIQI. Not until the Atomic Bomb problem is solved can high hopes for NACIQI be realized.
As Peter Ewell points out, implementing student learning measures on campus, then comparing the results across institutions and publicizing the results, are completely different animals. It is a false optimism that ignores the political obstacles to accomplishing the latter. Perhaps this difference can be made clearer if we talked about “ranking” institutions instead of using the innocuous term, comparability. History already provides us with an object lesson in failure, the kind of failure that is surely guaranteed when institutional ranking by the US DOE is proposed: the Bureau of Education’s suppressed rating of colleges (1911).
Spellings is trying to steer the course of our institutions of higher education toward greater market transparency, using only her little row boat. The currents of institutional history, government bureaucratic constraints, and the sheer size of the institutions she wishes to influence, dwarf her puny efforts.
Glen S. McGhee, Dir. at Florida Higher Education Accountability Project, at 10:15 am EST on November 30, 2006
“Michigan audit finds that eight Community Colleges fumbled data reporting and record keeping” (11/20/06) from Community College Week. It appears that much needs to be done before any of us can even talk about comparability. It seems that we need to create a dictionary of common terms first.
LAR, at 11:55 am EST on November 30, 2006
The comments above are on point, but I disagree with the comments regarding the intent of Congress in the language of Section 496 of the HEA. There is only one very brief mention of student achievement in the entire section of law, and it is buried in a list of other things the institution has to do to maintain its accreditation, such as define standards for faculty and curriculum, etc. From what I can tell, if accreditation is process-centered, it’s because the law makes it that way.
Although Sec. Spellings may have a point in suggesting that there ought to be more focus on student outcomes in the accreditation process, I have yet to hear her recommend legislative changes to section 496. Whatever the accreditors want to do with respect to student outcomes, they’ll be compelled to continue doing what’s required by law as well. That could make an already complex and drawn-out process that much longer, and it won’t make it any less process heavy.
The Secretary should skip the neg-reg on accreditation and encourage Congress to make changes when they start the new session in January.
Scott, at 1:00 pm EST on November 30, 2006
The legislative history of Sec. 496 of PL 102-325 (106 Stat. 448) clearly shows what was intended by both the US House of Representative and the US Senate:
During the Committee’s hearings ... witnesses generally faulted the existing triad system ... for being ineffective in assuring integrity in the Title IV programs and preventing abuse and mismanagement of Title IV funds. The Committee intends that institutional eligibility criteria be strengthened under H.R. 3553. ... H.R. 3553 sets forth a list of criteria by which an institution’s performance can be measured. (House Report No. 102-447, page 85)
The House Conference Report that describes the final resolution of differences between US Senate and House versions of PL 102-325 is even more direct:
Both the Senate and House bills require the Secretary to establish minimum standards for accreditation associations and lists requirements for these standards with minor differences in language. The Senate bill includes these provisions in Subpart 2 of Part G of Title IV, while the House bill includes them in Title XII. The conference substitute incorporates these standards in Subpart 2 of Part H. (House Conference Report No. 102-630, page 523)
With such explicit language pertaining to legislative intent, requiring “the Secretary to establish minimum standards for accreditation associations” and requiring the listing of “requirements for these standards” preceding the promulgation of the final regulations at 34 CFR 602, it becomes nearly impossible to reconcile the statute and the regulations.
The reason is that a way was found to nullify the intent of Congress by former Secretary Richard Riley. Using what he called a “minimalist” approach to managing these statutory requirements for the regional and national accrediting associations (59 Fed Reg No. 82, April 29, 1994), Sec. Riley’s actions obscured many of the problems which we have been discussing, but which now must be faced.
Regarding what has been in place now for decades, Riley’s stratagem is — for all intents and purposes — a hands-off policy that the department has been using to dodge its fiduciary responsibilities to the American people and Congress. By hiding behind the Secretary’s hands-off policy, departmental committees and AAEU staff sign off on flagrant accrediting association violators.
Glen S. McGhee, Dir., at FHEAP, at 5:45 pm EST on November 30, 2006
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December 4 to 6 Hearings
The advisory committee on accreditation hearings on specific accreditation petitions to be held at the Madison in DC from December 4 to 6 will begin to sift out the issues.
William Sumner Scott, J.D.
wss@jefound.org
William Sumner Scott, J.D., at 8:31 am EST on November 30, 2006