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Aggressive Tack on Accreditation Rules

The U.S. Education Department late Thursday released a set of proposed regulatory changes that would require accrediting agencies to get much more involved than they historically have in judging whether the colleges they oversee are succeeding in educating their students.

The draft language, which will be considered next week by a federal panel weighing possible changes in federal rules governing higher education accreditation, would give accreditors three options for measuring institutions’ success in educating students — two of which force them to set minimal levels of acceptable performance, which accreditors (and many college officials) have traditionally considered it inappropriate for them to do.

The department’s proposals would also require accrediting agencies to bar the colleges they monitor from basing decisions about whether to accept a transfer student’s academic credits on the accreditation status of the “sending” institution, and significantly increase the amount and types of information that accrediting groups would have to make public.

At the urging of the Secretary of Education’s Commission on the Future of Higher Education, and especially its chairman, Charles Miller, department officials have been pushing aggressively to use the accreditation process — higher education’s traditional (and oft-maligned) means of self-regulation — as a lever to force colleges to measure and report significantly more and better information about how well they are educating their students.

The department has pushed this approach both in the process it uses to recognize accrediting agencies, and in the regulatory review that it undertook last fall. How hard the department should push in this direction has been much debated and discussed by college officials and is being closely watched on Capitol Hill, where lawmakers have urged the department not to try to bring about through regulation major changes that would be more appropriately achieved through changes in law that would require Congress’s approval.

The proposals released Thursday, on the same day that many of the members of the federal negotiating panel were otherwise occupied at the education secretary’s higher education summit, are likely to ramp up those concerns, particularly in the area of student learning, where the department proposes two major changes.

One, which aims to measure how well academic programs prepare students for the work force, would require accrediting agencies to establish “minimum quantitative standards for completion rates, job placement rates, and pass rates on licensing and professional certification exams or other measures of occupational or professional competency for prebaccalaureate vocational programs and for baccalaureate and professional degree programs that prepare students for employment in an occupation or profession that requires certification or licensure.”

The other, which is much broader, would apply to all agencies and all programs. It would give accrediting groups three choices. An agency could:

  • Establish “for all agencies it accredits specific quantitative and qualitative measures of student achievement and an expected level of performance.”
  • Develop “a set of evaluative rubrics for groups of institutions with similar missions, which includes a variety of quantitative and qualitative measures. The agency then weights the components of the rubric for each institution and specifies an expected level of performance on each component.”
  • Let each institution it oversees establish “quantitative and qualitative measures for each of the programs it offers, and an expected level of performance, that is satisfactory to the [accrediting] agency.” The accrediting group would then presumably need to ensure that the institution is meeting the agency-approved goals it has set.

The department’s proposed regulatory language also states that “the institution is required to make available to the public, and to each prospective student, information about its mission and each program’s objectives, expected levels of performance on measures of student achievement, and actual performance.”

The draft language on transfer of credit will please officials at for-profit and other institutions that are accredited by so-called national rather than regional accrediting agencies, who complain that many institutions have policies on academic transfer that discriminate against students from nationally accredited institutions.

But the idea of dictating colleges’ transfer is strongly opposed by most other college officials, including those at community colleges, even though their students’ academic credits are also frequently turned away by four-year institutions. Registrars and other say it is inappropriate for the federal government to dictate colleges’ admissions policies.

Doug Lederman

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Comments

pretty scary stuff

Pretty scary. A bunch of proposals to make legislators and business leaders feel good, but in the end accomplish nothing.

Jim, at 6:50 am EDT on March 23, 2007

The composition of the committee is really shocking. (Two people from Goldman Sachs??) So far this sounds like an acceleration of the transformation of the undergraduate experience into vocational education and the death knell for the liberal arts education.

Mommy, at 7:45 am EDT on March 23, 2007

credit portability

The issue of credit portability and transference between institutions with varying accreditation (i.e. national versus regional) must balance the interests of the student, the federal and state funding agencies, and the academic institutions.

For students, there is an expectation that if they attend an accredited institution, credits earned will transfer to another accredited institution. The absence of this portability costs the student time and money and is generally anti-consumer.

For federal and state government that provides grants, loans and direct institutional funding, there is great inefficiency in having to duplicate covering the costs of the same or similar instruction for the same student.

For institutions who wish to preserve the integrity of their degrees and the value of their respective curriculums, there is the need to control transfer credits (although for most institutions the failure to allow transfer credits is based upon financial, and not academic, objectives.)

To balance the equities for each of these stakeholders in the issue, there will need to be some compromise.

One possible approach would be to require all institutions to have a minimum transfer threshold. For example, any accredited institution (participating in Title 4) could be required to accept at least 50% of an admitted student’s credits toward associate and bachelor degrees, and a higher rates if the institution chooses.

Institutions could be required to publish transfer threshold rates as part of their public disclosure, allowing students to better understand such policies before going forward with application. Thus, the marketplace would also push institutions toward higher level of credit acceptance from other institutions, as those with higher rates will be favored by transfer applicants.

Students need and want flexibility in their pursuit of higher education. Transferring between institutions, adding summer terms, and attending online, have become a common pattern. With national six-year graduation rates at four-year colleges hovering at 50%, this is an issue whose time has come and should move toward resolution.

howard e horton, esq., president at new england college of finance, at 7:50 am EDT on March 23, 2007

Transfer

The effect of negating accreditation requirements will be to prompt more testing. As it stands it is often difficult to determine what a student has learned at another college prior to seeking transfer; gpa often means too little. If you remove accreditation as one layer of protection against students who are unprepared, we will have to substitute some kind of transfer testing. Another big win for the makers of tests, and testing is never too far from the Bush Administration’s hearts. It will not help students very much, however.

Jon Burdick, Dean of Admissions and Financial Aid at University of Rochester, at 10:50 am EDT on March 23, 2007

Not Scary at All

Why is it scary to simply provide evidence that your students are making progress toward your stated outcomes? Assessment tools have been available for many years to make it relatively easy to do just that. Accountability is nothing to fear.

Higher learning organizations should move beyond their bravado of lofty verbiage regarding their grand heritage of everlasting quality and finally get down to demonstrating the quality we so enthusiastically claim.

Have a happy day!

oklahomakid, at 10:50 am EDT on March 23, 2007

Compare Apples

Because entrance exams are high for all students does not equate to all programs are good. Accredit departments not schools.

This group has the ability to get the job done — only time will tell if they go the way of the Warren and 9/11 Commissions or do quality work.

William Sumner Scott, J.D.

Judicial Equality Foundation, Inc.

wss@jefound.org

William Sumner Scott, J.D., at 10:50 am EDT on March 23, 2007

NACIQI make-over ?

This draft involves a number of ambitious proposals, including a beefing-up of NACIQI’s role in the review of accrediting agencies which, until now, has been to give a rubber-stamp of approval to accreditors.

The insertion of an additional layer of accountability into the regulatory structure (i.e., the addition of the senior Department official) also gives the federal agency a great deal more flexibility, and is perhaps an attempt to overcome the symptoms of regulatory agency capture by the accrediting guilds that have undermined the overall credibility of the Secretary’s recognition process.

Yet, there are at least two major obstacles remaining before moving away from the process model of regulation of the accrediting guilds.

First, these proposed CFR changes must be understood as attempts by the Federal government to transform a mutual benefit association organizational model(the accrediting guilds) into quasi-governmental instrumentalities, that is, into regulatory arms, of the Department of Education.

Viewed in terms of organizational theory, there are many reasons for the accrediting guilds to strenuously resist these kinds of changes.

Historically, the voluntary system of peer review and institutional self-improvement that emerged over 100 years ago has almost nothing in common with the much more recent Federal interests in American higher education, which have now been imposed upon the older organizational foundation. Regional accrediting guilds were originally formed for the benefit of their members, and in this regard they have performed admirably well by resisting interference and change.

It may happen that the accreditors will protest these proposed changes, and unleash their dogs on the Secretary and Congress, as happened during the defeat of the SPREs in the 1990s. It may be that the accreditors will acquiesce for political reasons, and seek minimal compliance internally.

This leads to the second major problem, the so-called Atomic Bomb problem with the current regulatory structure.

The Atomic Bomb problem refers to the regulatory dilemma that has been avoided by the US DOE’s “minimalist” or process approach to HE accreditation, but which tends to undermine the credibility of the recognition process.

“The Education Department’s accrediting agency evaluation branch has in the past often approached its function regarding accrediting agencies not as a regulator, but as a collegial peer reviewer. While this approach has been helpful in avoiding undue federal influence over higher education, it has also meant that the recognition process has not been effectively used to promote better ‘gatekeeping.’ ... Part of the staff’s reluctance to consider deregulation of an agency resulted from the devastating effect on schools’ eligibility if their accrediting agency were delisted. Students and quality institutions could be seriously harmed by such action. Thus, the consequences of derecognition were so severe that the threat of derecognition was not credible. (Jeffrey C. Martin, “Recent Developments Concerning Accrediting Agencies in Postsecondary Education,” Law and Contemporary Problems 57:4, Autumn 1994, pages 121-150.)

This is what Martin calls the “atomic bomb problem,” and although the 1992 HEA provides for a Title IV waiver of up to 18 months for accredited institutions upon the loss of their accreditor, the problem illustrates the kinds of disincentives that the US DOE/AAEU is forced to operate under. The proposed changes do not address this problem in any way.

The NCA, for example, accredits about 1,000 postsecondary institutions and SACS accredits about 800. The negative repercussions of closing down either of these associations would be difficult to describe, let alone face in actuality. Thus, acting resolutely against non-compliance is simply ruled out. One recalls the sage advice of the Puffer Report, which urged breaking up these massive agencies into smaller ones. Perhaps the time has come to reconsider this proposal once again.

Lastly, these are just proposed CFR 602 changes. It remains to be seen what, if any, changes will be actually made.

Glen S. McGhee, Dir., at Florida Higher Education Accountability Project, at 10:51 am EDT on March 23, 2007

L’État, c’est moi

Last year, the House of Representatives attempted, but failed, to enact legislation that would have created a new federal mandate on transfer of credit. Clearly, even those members of Congress who are in agreement with the Secretary believed that she would need new legislation to authorize her to impose their shared (and profoundly mistaken) views on colleges and universities.

Neither the Commission, nor the “negotiating” committee, nor the Administration’s generous supporters in the for-profit sector can be substituted in our system of government for Congress, which must first grant the Secretary with legal authority to micromanage the academic affairs of colleges and universities.

For reasons that are not that difficult to fathom, the Secretary has opted to disregard things she should be doing (like protecting the taxpayers and students from being ripped off by student loan companies) and has instead decided to actively pursue ill-considered policies that she has no legal authority to implement.

Barmak Nassirian, AACRAO, at 10:51 am EDT on March 23, 2007

Uneducated students with diplomas is even scarier

Although there are many valid educational pitfalls to minimum standards, I feel that sending off students into the work world without the basic skills they should be receiving along with a piece of paper on the wall is scarier than the pitfalls.

Since I handle both graduate and undergraduate admission, I see a cross-section of finished high school products and finished college products. Sometimes the results (even from my own college) are frightening.

College graduates need to be able to write, think and analyze on a higher level than the CLEP exams offer (which is the basis at so many colleges for “mastery” of basic courses). The high school sophomore who took the US History CLEP and ‘passed’ or the high school senior who graduated adn then earned her BA one month later is enough evidence for me that minimum standards must be met on a higher level than a high school education.

Currently, There are too many ways (regional, national, state) to be accredited. Although I am not a fan of the federal government stepping in needlessly, sadly I feel there is a pressing need!

PS-Until minimal standards are met and have been in place for at least three years, imposing loose rules on credit transfers will not solve any problems.

Steve, Director of Admissions at Touro College, at 10:51 am EDT on March 23, 2007

Student Learning Outcomes

The need for clear student learning outcome data is past overdue. The colleges and university systems that take this seriously will be the leaders in the future. The ones that fight it will soon look foolish. The reason — its in the demongraphics.

Lisbeth, New York, at 10:51 am EDT on March 23, 2007

Expecations of Transfer

I see no reason why a student should have an expectation that their credits should transfer to other schools especially if the school is up front with the student as to whether or not the credits transfer in the first place. Many of the national accreditors accredit a wide range of schools and have less of stringent accrediting standards. More academically stringent programs should have to write to control the credits they accept.

Alphonso Quashie, Legal, at 10:51 am EDT on March 23, 2007

Accountability not scary, evidence is

What I meant by scary is not the goal of being accountable. What is scary is what many people accept as valid measures of student learning/success and who try to apply a cookie-cutter, one-size-fits all approach to everything ("Lets make all student take a test. Thats the answer!"). There is already a lot of good assessment being done on campuses all over the country. Lets improve on the good assessment practices that are already in place at many institutions.

Jim, at 12:25 pm EDT on March 23, 2007

Are we satisfied with the quality of our graduates?

If the answer to the subject line is yes, then this debate is a tempest in a teapot. However, I sense from comments here that we are not generally satisfied despite differing in how to bring back that quality.

In colleges I think the deck for decades has been getting stacked against professors, students who want to learn, and accreditors and administrators. State legislators have a lot to account for here. College funding in many states is enrollment driven, and the theme of “get the student numbers up” overwhelms the purpose of “educate the students.” In too many places, this has converted educating into processing. Just as there was no shortage of firing squads when Castro took over Cuba, there are no shortage of third-rate administrators willing to participate in this processing, and keeping student numbers up frequently involves corrupting educational standards. In some schools, professors are too intimidated by student evals, “Pick-a-Prof” etc. to demand the hard work, writing and critical thinking that is needed to acquire an education. The equivalent of firing squad members are administrators who disempower faculty by replacing “educate students” with “please customers.” Students will indeed rise to meet the challenges and standards. “Please customers” offers litle to rise to and actually disenfranchises students from responsibility to make a college a fit place in which to learn.

There are a few rays of hope. One is the work of Astin, Kuh and others with the National Survey of Student Engagment that is a good indicator of whether a school has an emphasis in educating or processing of students. Kuh described the processing model in Change Magazine, 2003, v. 35, n. 2 as “the disengagement compact: ‘I’ll leave you alone if you leave me alone.’ That is, I won’t make you work too hard (read a lot, write a lot) so that I won’t have to grade as many papers or explain why you are not performing well.” Classrooms in schools characterized by this compact are characterized by a lot of absences and poor attendance. The students sitting in those classes would be well advised to go to another institution characterized by engagement—where those who don’t want to attend regularly won’t slow down the educations of those who do.

Prof Ed, at 1:06 pm EDT on March 23, 2007

Accreditation Rules

The only part of these guidelines for accrediting agencies that makes any sense is in the area of transferring credits from insitution to insitution and even this shouldn’t be subjected to a one size fits all approach.

The rest of these guidelines are a waste of time and effort. The marketplace and the governing boards of the institutions both public and private have this responsiblity, to overlay their role with another useless federal process will lead only to higher costs and no measurable benefit to anyone, except consultants that will be required by institutions to navigate this mess.

In my opinion the federal government is not carrying anywhere near the cost of attending higher education and has no business adding this rather poorly thought out burden to anyone.

Ralph Caruso Hampden, Maine

Ralph Caruso, at 1:41 pm EDT on March 23, 2007

Where do I find the reference to Goldman-Sachs having 2 members on the committee?? Tks, Jim.

Jim, at 3:05 pm EDT on March 23, 2007

In engineering assessmen, we’ve learned to quantify even such things as “desire for life-long learning.” But I’m sensitive to “mommy’s” comment that this “will be the death of the liberal education.” How can we quantify critical thinking, or the ability to identify and question one’s own assumptions? I’m not saying it can’t be done, but I’d like to see how.

Dave Vaccari`, Civil Env Eng Dept Head at Stevens Institute, at 3:05 pm EDT on March 23, 2007

Government Does Pay Enough to Participate

It is unrealistic to think the government department of education will back off — energy should be spent to make this process productive. Any ideas?

Quizzical, at 3:06 pm EDT on March 23, 2007

Credit Transfer Red Herring?

What’s all this nonsense about making it impossible for colleges and universities to judge for themselves which transfer credits that they will or will not accept?

The only thing that has been proposed is that receiving institutions not be allowed to judge a student’s transcript wholly on whether the sending institution is a regional or national accreditor, both of which must pass the same requirements in order to be recognized by the Secretary.

Most of the policys requiring that incoming credits be from a regionally accredited institution were established at a time when undergraduate accreditation and regional accreditation meant pretty much the same thing. When this was true, using regional accreditation as an easy way of sifting the wheat from the chaff might have made sense. But it doesn’t now, when there are other agencies recognized by the Secretary that possess standards at least as rigorous, and in some instances more rigorous, than some of the regionals.

We would not be subject to all these misguided scare tactics if Congress had kept a provision in the Higer Ed Act that would have required institutions merely to provide reasons for relying on whatever screening mechanism they choose to use. So they could even continue to filter by requiring regional accredition, so long as they give reasons for doing so. This would prevent them from implying without having to argue the superiority of all regional to all national accreditation.

Unfortunately, this provision was taken out, primarily because of hysterical objections from admissions officers whose arguments were clear evidence that they had not read, or if they did, were not able to understand the clear text of this very simple bill, which would, again, have left all discretion regarding incoming credits to the receiving institutions and faculty.

JDW, President at American Academy for Liberal Education, at 3:06 pm EDT on March 23, 2007

Makes One think of what happened to AALE

Apparently, the Department of Education’s newly proposed regulations will require accrediting agencies to establish “quantitative and qualitative” measurements for student achievement, including benchmarks for institutional success and failure.

This implies, rightly, that the agencies do not presently possess such measurements.

Those who have been following accreditation in recent months may wonder just what is going on here. At its last meeting on the recognition of accrediting agencies, the Department clobbered the American Academy for Liberal Education (AALE) for not possessing measurements ("benchmarks” or “bright lines") for assessing student learning, the very things that are now to be created. Put another way, AALE was charged with lacking something – student learning benchmarks — that have yet to be established. If they already existed, the Secretary would not now be demanding their creation.

This makes a nice hash out of the Department’s claim that AALE has stubbornly refused to adopt requirements that have been on the books for years. In truth, benchmarks have never been required of either AALE or the regionals, and neither possesses them. In regard to the standard regarding student success, at least, the regionals and AALE are exactly alike.

Nevertheless, they are being treated quite differently. The regionals continue to be recognized by the Secretary. Only the AALE has been singled out for punishment on this ground. Why?

Is it to “send a message to the regionals,” as some have suggested? Has the Department decided to make a scapegoat of AALE, even at the price of maintaining that it has violated non-existent requirements? As also noted by many, AALE is small enough to destroy without having to face repercussions of the sort that would certainly greet any attempt to railroad one of the regionals like this.

Yesterday’s “summit,” along with the new draft regulations on accreditation, make it difficult to believe otherwise.

dbr

dpg, at 3:06 pm EDT on March 23, 2007

Quality Control of Education

The only way that our profession can really validate the effectiveness of teaching is by assessing student learning outcomes. Put simply, if students are not learning, we are not teaching anything. Thus, enough with the “my students are learning because I say so” rethoric and let us open our minds to a quality control of higher education through purposeful assessments of student learning outcomes.

Jose Ricardo, Assistant Professor of Spanish and Foreign Language Education at Shippensburg University, at 3:41 pm EDT on March 23, 2007

Learning

How are we to measure leadership development? How are we to measure cognitive complexity? How are we to know if our graduates can solve ill-defined problems? How are we to know if graduates can evaluate the ethics of proposed solutions to problems? How can we measure spiritual development? How about intellectual creativity? These are only a few of the important outcomes of higher learning. Certainly we want our citizens to havae achieved high levels of development in each of these domains. Yet no single battery of testing can tell us about our progress in promoting higher learning as such.

Furthermore, there are quite a few business leaders on this committee. Why are there no civic leaders? There is no justification for privileging business interests over those of civil society—not in a “democracy".

David Ayers, Assistant Professor of Higher Education at UNCG, at 4:00 pm EDT on March 23, 2007

Answer to Jim

Jim:

The list of members of the steering committee is appended to the article about the education secretary’s summit Thursday, which also appeared on the site today:http://insidehighered.com/news/2007/03/23/summit

Best,

Doug Lederman

Doug Lederman, Editor, author of this article at Inside Higher Ed, at 4:00 pm EDT on March 23, 2007

Students = Widgets

Students simply are not widgets, and accountability models taken from business are misguided. They are, however, politically persuasive, and I find it interesting that those who favor free market economics and deregulation of industry now are convinced that state control of education and hyper regulation of academic institutions is the only sensible thing to do.

afdtk, at 9:16 pm EDT on March 23, 2007

AALE and the Regionals

The history of the student learning outcomes, in so far as they initially relate to proprietary schools receiving Title IV funds, goes back to the massive student loan defaults of the late 1980s and 1990.

These standards first appear as part of the 1992 amendments to the Higher Education Act, along with a dozen other standards that were meant to end high rates of student loan defaults. Specifically, the legislative intent was for the US Department of Education to require that accreditors have “minimum standards” for student learning, and faculty qualifications.

But in the uproar over the SPREs, which were also part of the same legislation, both the Department and Congress were forced to retreat. In the confusion, the Department also backed-down from implementing the Part H, Program Integrity standards, leaving in place instead minimalist “process” standards, or what are really standardless-standards.

What’s happening now is that the Department is playing catch-up, and attempting to regain some of the ground that it lost during the SPREs debacle, in slightly different form.

This complex prior legislative history is why recent events appear to be contradictory. This is why “In truth, benchmarks have never been required of either AALE or the regionals, and neither possesses them.”

But the fact that the accrediting agencies “do not presently possess such measurements” should not obscure the original legislative intent behind Part H of the 1992 HEA, after which, as they say, the train left the tracks. Congress itself bears much blame for this through its laxity and poor oversight, as history will show.

But you are quite right to point to the relative small size of AALE as a factor in its treatment by AAEU/NACIQI: the Atomic Bomb problem, and the deterrent incentives to protect it from outside threats, do NOT apply, making it vulnerable to changing cross-winds in HE regulation.

My own hope is that, eventually, the accrediting guilds will be transformed more and more to resemble what Claude Puffer called “public utility commissions” in higher education, and come to understand the consumer point of view, rather than to simply defend that of their member institutions. What we are witnessing is the attempt to gradually reform a one-hundred year old institutional guild, no small feat by any means, and by no means an assured success either.

Glen S. McGhee, Dir., at FHEAP, at 9:21 pm EDT on March 23, 2007

All of these attempts at monitoring student outcomes share the flaw that institutions and teachers are not alone responsible for student learning. Students surely share some responsibility for their own outcome. I agree with afdtk’s comment. A free market approach to higher education is surely the best. If colleges and universities have a good reputation, so will their high GPA students. The tension between the proposal to tighten regulations for regional accreditation on the one hand and then to make that accreditation meaningless by insisting on credit portability from unaccredited institutions does make this whole thing smell funny.

Eugen, Liberal Arts Professor, at 1:25 pm EDT on March 24, 2007

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