Accreditors Without Borders

American accrediting agencies are increasingly evaluating foreign colleges and programs that are unattached to U.S. institutions. Proponents of the exportation of U.S. accreditation argue that it has a role to play in improving the quality of universities and professional programs worldwide and in promoting the mobility of students and faculty; critics contend that, without care, the accreditors could find themselves in a compromising position.

They argue that the expansion of U.S. accreditation abroad is neocolonial on the one hand and hazardous on the other: can standards built on values underlying American higher education be upheld with integrity in other cultural contexts?

But if it is neocolonial, it’s also, in the words of the higher education scholar Philip G. Altbach, “a neocolonialism of the willing”: by all accounts there is substantial demand for American accreditation on the part of foreign institutions, which see it as a way to distinguish their programs and attract students interested in coming to the U.S. for graduate school or work. Interest is coming not only from institutions like the American Universities of Beirut or Sharjah (both of which are accredited by the Middle States Commission on Higher Education), but also from non-American-style, non-English-speaking institutions such as the Universidad Mayor, in Chile (also Middle States-accredited).

“It’s ironic that as much as accreditation is attacked here at home, it’s still seen as the gold standard abroad,” says Kevin Kinser, an associate professor of education at the State University of New York at Albany.

Kinser sees the expansion of U.S. accreditation abroad as a positive thing, on balance. “International education is already existing, and we have no good transnational quality assurance regime, so the more the existing quality assurance agencies can adapt what they do to be able to work internationally and transnationally, I think that helps move us along a path where we can think about education in an equivalent way across multiple contexts.”

Kinser also notes the competitive aspect of this: “If the U.S. accreditation regime is not active internationally, then the British and the Australians will be. So there’s an element of saying, ‘Whose quality assurance model, whose perspective of quality education is going to be out there in the world and be something the world is going to look to?’ ”

Indeed, Richard E. Sorensen, the dean of the business school at Virginia Tech and a former chair of the board of AACSB International, a Florida-based accreditor of business programs, recalls that the main impetus pushing AACSB to begin accrediting foreign programs about 15 years ago was competition from a European accreditor that had begun to approve programs outside Europe.

“The question we brought to the membership was, do you want to be a North American organization or an international accrediting organization? If we don’t do anything, in two years we’ll be a North American accrediting organization,” Sorensen says. Today, AACSB is among the most internationally active of the U.S.-based accreditors: 176 of its 672 accredited programs are based outside the U.S., in 43 countries. The vast majority of the nearly 200 programs that are in the process of accreditation are based abroad. In the U.S., by comparison, "the potential for growth is almost insignificant," Sorensen says.

The accreditors of course have a financial stake in expanding the size of their client base. Yet there are concerns about the capacity or expertise of U.S.-based accreditors to engage in overseas accreditation. Accrediting agencies -- which are not subject to federal oversight when they evaluate programs overseas -- are  handicapped in working in countries where reviewers lack a strong understanding of the higher education system and fluency in the local language (and which they fly in and out of -- a problem that Kinser argues accreditors should address through the creation of overseas offices in the regions where they work). It's comparatively easy for accreditors to get in over their heads, as when one agency, the American Academy for Liberal Education, came under scrutiny some years back for approving an institution in the Republic of Georgia with ties to an unaccredited Hawaiian institution that had been closed down by that state's regulators.  

"The challenge is when you're accrediting abroad, do you give the same scrutiny to your institutions and programs that you give to U.S. institutions or programs?" asks Judith Eaton, the president of the Council for Higher Education Accreditation, an association of colleges that recognizes institutional and programmatic accreditors. "Do you have the capacity? These are important questions that we are looking at and need to continue to look at."

The questions are more pressing than ever. The most recent data from CHEA, from 2011, show that U.S.-based accrediting agencies at that point approved a total of 857 foreign institutions or programs in 70 countries. This is over and above the 720 branch campuses or other overseas programs that accreditors then reviewed as part of the scope of U.S.-based institutions’ accreditation.

Between 2007 and 2011, the total number of international programs approved by U.S. accreditors more than doubled. CHEA has created an International Quality Group in light of this growth. “We really do have an international quality assurance community and the more we can work together internationally, the more we can address common issues,” says Eaton. She adds, too, that the growth of accreditation of foreign programs is tied to the issue of U.S. universities’ own internationalization: “We talk about how internationalization of the curriculum is so important; we talk about the desirability of faculty exchanges and partnerships. Accreditation helps with all of that because you have a place to turn to for quality.”

Number of U.S.-Based Accreditors That Have Approved Non-U.S. Institutions and Programs in Other Countries

Source: Council for Higher Education Accreditation, 2011

Yet while there’s been an overall expansion, some accreditors, such as the American Bar Association’s Section of Legal Education and Admissions to the Bar, have opted not to wield their stamp overseas. The Liaison Committee on Medical Education has no plans to expand its scope beyond its traditional domain of the U.S. and Canada, while the veterinary accreditor’s recent approval of programs in Mexico and the Caribbean has been a source of controversy.

The pharmacists are attempting to carve out a middle ground, launching a new certification process for international programs that differs from accreditation. Meanwhile, one regional accreditor, Middle States, has ended a pilot program in which it accredited foreign institutions with no ties to its U.S. region, while another, the Western Association of Schools and Colleges, is only beginning to expand its activities abroad. Inside Higher Ed interviewed representatives of these accrediting associations – and others – about the promises and pitfalls of foreign expansion in a globalized higher education context.

Regional vs. Programmatic

The issues at hand differ somewhat with regard to the regional accreditors – which approve entire institutions in their respective geographic regions of the U.S. –  vs. the programmatic accreditors, which evaluate programs in professional fields. Five of the six regional accreditors have international member institutions, although each agency has a different approach.

The Higher Learning Commission of the North Central Association of Colleges and Schools is the one association that does not accredit any international institutions; its spokesman, John Hausaman, declined a request to interview commission officials but noted in an e-mail that “the jurisdiction established by our bylaws limits us to accrediting institutions that [are] based in our 19-state North Central region.” The college commission of the Southern Association of Colleges and Schools, which accredits six foreign institutions and lists three others as applicants, has a history of working with colleges in Latin America; in more recent years, it has expanded its reach to include the Middle East.  

The New England Association of Schools and Colleges is comparatively restrictive in its criteria, as it accredits only foreign institutions that declare themselves to be American-style and where the primary language of operation and instruction is English. Middle States will accredit only those foreign institutions that are licensed by a state in its region. (Seven foreign institutions accredited by Middle States are licensed to operate by the State Board of Education in Delaware.) 

From 2002 to 2007, Middle States experimented with opening its doors more broadly, accepting nine foreign institutions that were not licensed by states in its region as candidates for accreditation. Six of those institutions, in Canada, Chile, England, Taiwan, and the United Arab Emirates, have achieved accreditation; two are candidates and one bid is dormant. While the institutions that were brought in during that period will remain in Middle States’ fold, the association’s spokesman, Richard Pokrass, says the decision not to admit any new foreign institutions had to do with issues of capacity.

“The commission decided that it’s just too time-consuming and labor-intensive,” Pokrass says. He describes challenges of travel and language barriers. Some of the foreign applicants found it to be time-consuming and expensive to translate the documents that are required for accreditation into English, per the commission’s requirements.

And Middle States would periodically receive complaints about institutions it accredited in languages other than English. In the case of Spanish, a staff member could usually translate, but otherwise Pokrass says he had to write back to the complainant, in English, asking him or her to resubmit in the language of the accreditor.

One Middle States-accredited institution, Zayed University, in the United Arab Emirates, was in the news last summer after an American journalism professor who called for increased press freedoms was kicked out of the country. Although Middle States standards describe academic freedom and freedom of expression as being “central to the academic enterprise,” Pokrass emphasizes that in this case it was reportedly government officials who initiated the professor’s dismissal (as opposed to officials within the institution) – and Middle States has no authority over a government’s actions.  

“It’s something that the commission understands will happen in certain countries, and it works with institutions to ensure that wherever possible there is some semblance of academic freedom, but in some places it can only be taken so far,” Pokrass says.

Others argue that academic freedom is a bedrock principle upon which U.S. accreditation standards are built. Sandra E. Elman, president of the Northwest Commission on Colleges and Universities, worries that some accreditors are creating a bifurcated path by accepting circumstances at foreign institutions that they wouldn’t tolerate domestically:  “That’s dangerous for the integrity of our accreditation process,” she says.

The Northwest Commission is open to working with foreign universities but to date has granted candidate or accreditation status only to two colleges in Canada, which of course exist in a context quite similar to that of the U.S. A few years ago, Elman conducted an information-seeking trip to the Middle East after institutions in Kuwait and Abu Dhabi expressed interest in possibly seeking Northwest accreditation. In one case, Elman says a law requiring gender segregation would have rendered the institution ineligible for accreditation; in the other, the institution would have been unable to meet the accreditor’s standards regardless of where it was located.

“While on the one hand it’s important to reach out and work with institutions around the world for all the reasons that we know and we study in Political Science 101, we will not do anything to create unfair practices for our institutions,” Elman says. “We have important standards, as do the other regionals, that pertain to governance, that pertain to academic freedom, and we’re not going to do anything to compromise those principles.”

Eaton, the president of CHEA, articulates similar concerns, in particular around issues of academic freedom and governance.

“If academic freedom is substantially different in another country, and some accreditor has an academic freedom standard, and says, ‘Oh, we’re going to accredit this institution or program with that difference,’ is that a good position to be in?” Or, she says, “In the U.S. an institutional accreditor would not be comfortable with the government deciding curriculum standards, with the government hiring the faculty. That happens in some countries. So if you’re using the same standards regarding institutional autonomy, are you creating a problem for yourself?”

There is a divide between those who believe that accreditation standards must be applied in exactly the same manner at home and abroad and those who believe that there is room for accommodation of country and local context. (After all, as many point out, accreditation is always a matter of considering whether an institution meets an agency’s standards in light of its mission, hence why a community college, a faith-based institution and an Ivy League university can all share the same accreditor’s stamp.)

In launching a new initiative to accredit foreign institutions, the Western Association, or WASC, plans to use the same standards it uses for institutions in its domestic region, but has developed eight protocols for the interpretation or adaption of its eligibility criteria and standards in foreign contexts.

For example, the protocols note that with regard to its standard on academic freedom, “The traditions of freedom of inquiry and expression that characterize American higher education may not have been as formally expressed and protected in other cultures,” and poses three questions for the commission and site visiting teams to consider in evaluating a foreign institution: “Are there formal policy statements consistent with the WASC position on the protection of academic freedom?”; “Is there a record of actions, either formal or informal, showing that faculty have been free to pursue academic inquiry or to express themselves freely with regard to their academic duties?”; and “ In confidential conversations, do faculty members express an ability to disseminate their scholarly findings through publication or through classroom interactions?”  

The protocols also offer interpretative guidance on such issues as cultural differences in institutional and academic governance, faculty qualifications, and the meaning of the baccalaureate degree (which in Europe, for example, is typically three years in duration).

Per the document outlining the protocols, “the issues … are approached from the perspective of a functional equivalency. This implies understanding the underlying principle or core value of the WASC Criterion or [criteria for review] and envisioning how it might apply within the context of the international institution.” As William M. Plater, WASC’s senior adviser for international affairs, explains, “The commission recognized that what we were going to do is not try to impose an American set of presumptions upon others but instead what we are going to try to do is articulate very clearly what our standards are, what our values are. And if there’s a match between the institution’s objectives and ours, then we’re willing to interpret or adapt our criteria to include them as long as we can be certain that the principles on which our accreditation is based can be maintained or observed.”

Facilitating Flow

Issues of interoperability of standards can arise with programmatic accreditors as well. AACSB’s membership is voting next week on new proposed standards that are written with the intention that they will allow more room for evaluators’ individual judgments. As Sorensen, the chair of the committee that developed the proposed standards, explains, a proposed change that would give institutions more freedom in carving out “units of accreditation” – in layman’s terms, in deciding to pursue accreditation for some business programs but not others – arises in part from a finding that at many institutions in Asia and Europe, accounting and management programs are run as separate entities. AACSB has made exceptions for some of these programs under its current standards, as well as exceptions with regard to its curricular standards in evaluating three-year undergraduate programs.

Aside from business, the engineering accreditor, ABET, has been the most active in the international arena, currently accrediting 324 programs at 64 institutions in 23 countries outside the U.S. Michael Milligan, the association’s executive director, says he sees ABET accreditation as helping to enable the flow of engineers. “The U.S. is a big importer of technical talent,” he says, adding that American companies that wish to hire local graduates for their research centers and manufacturing facilities in other parts of the world are guaranteed “a certain level of quality” in regard to graduates of ABET-accredited programs.

Milligan emphasizes, however, that accreditation is only one slice of ABET’s international activities. It also collaborates with quality assurance agencies around the world (it has signed memorandums of understanding guiding such collaborations with accreditors in 17 countries) and is a signatory to four mutual recognition agreements, which acknowledge the “substantial equivalency” of other national accreditors’ review processes.

“We feel this is very important because there are so many programs that we couldn’t possibly accredit half of them,” Milligan says. “The way that we assure quality assurance throughout the world in engineering and computer programs is by partnering with other organizations and trying to make sure that our programs are equivalent enough that if students graduate from a program in one part of the world it can be recognized elsewhere.”

Meanwhile, the Accreditation Council for Pharmacy Education has launched a new process for certifying (but not accrediting) international pharmacy programs, in response to the numerous requests for consultations it was receiving from institutions and government officials abroad. “We’ve probably had about 15 different countries that have sent representatives to our office to identify what we were doing, [and ask] how does accreditation work?” says Peter H. Vlasses, the executive director of the council.

“The requests for help became greater and greater to a point where about two-and-a-half years ago our board did a detailed analysis of, is this something that we should do more than just to be good international citizens, but rather take on as a strategic targeted activity? In the end the purpose was to help pharmacy evolve in other countries, to help quality assurance mechanisms in other countries evolve, and to help pharmacists be better qualified to provide patient services.”

In explaining the decision to opt for certifying international programs, rather than accrediting them, Michael J. Rouse, the commission’s director of international services, explains, “The Pharm. D. standards were really written with the U.S. health and education systems in mind and we felt that there would not be that many programs around the world that could actually meet those standards.” (The ACPE does currently accredit one international program, at an American-style university in Lebanon, that officials describe as a highly unusual case.)

Rouse adds that -- unlike in the case of engineering -- “We did not want a situation that would facilitate the migration of pharmacists to the United States. We felt it was quite important to not have a direct link between what we were doing and the right to practice in the United States” (as graduates of ACPE-accredited schools are eligible to sit for state licensure exams). Instead, ACPE has developed a separate set of criteria for certification, which is intended to be more broadly applicable than the accreditation standards. 

Other accrediting agencies have eschewed the evaluation of foreign programs altogether. The council for the American Bar Association’s Section of Legal Education and Admissions to the Bar voted last summer not to pursue accreditation of foreign law schools, after a committee recommended that such a move would detract attention and resources from the section, that “it would be difficult, if not impossible, to acculturate students in foreign law schools in the culture, values, and ethics of the American legal system,” and that “a decision to accredit foreign law schools would require the Accreditation Project to engage in the difficult task of developing and implementing appropriate standards and  processes, including the means of monitoring compliance with the Standard’s academic freedom and other U.S.-centric requirements.” The committee's report noted that 67 percent of law school deans surveyed said the agency should “probably not” or “definitely not” become international in its scope.

 “It was not, ‘not ever,’ but ‘not now,’ ” says Barry Currier, the ABA’s interim consultant on legal education. “I think everyone understands that things are globalizing, the practice of law included. Maybe [at some point] that leads to the accreditation of foreign-based law schools. Maybe it leads to more reciprocal arrangements with accrediting groups in foreign countries. Maybe it just requires schools here and abroad to do more comparative work. There are many potential ways to respond to the increasing globalization of the profession.”

Dan Hunt, the senior director of accreditation services for the Association of American Medical Colleges and co-secretary of the Liaison Committee on Medical Education, which accredits medical programs in the U.S. and Canada, says that the LCME has been active in working with the World Federation for Medical Education in promoting the development of accreditation systems in other countries, but that it has no plans to expand its own scope of authority.

“It is our strongly held position that the variations in cultural resources and disease patterns and the ways in which students are prepared for medical school mean that accreditation should be local,” says Hunt. He adds that the LCME doesn’t want to do anything to facilitate the “brain drain” of doctors from the developing world to the U.S.: there already is a process for graduates of foreign medical schools to qualify for licensure (as is also the case in pharmacy), “but we don’t want to make that access automatic.” 

By contrast, the American Veterinary Medical Association’s Council on Education has come under criticism for recent accreditations of programs in Mexico and the Caribbean, particularly in light of concerns regarding an oversupply of newly trained veterinarians in the U.S. and their growing debt burden. In an e-mail interview, David Granstrom, the director of AVMA’s education and research division, says, “Accreditation is about the evaluation of educational quality only. Accreditation cannot be used to control the marketplace.”

An AVMA task force has been examining the issue of accreditation of foreign veterinary schools. Its report is not yet public, but Granstrom cites the findings of a task force charged with evaluating this same issue in the 1990s, which determined that “global economics, expansion in the trade of animals and animal products, and the continued emergence and spread of diseases without respect for national borders mandates an increased role for the AVMA and its members.”

“The reasons cited to continue foreign accreditation have only intensified over the past decade,” Granstrom argues.

Yet a report prepared by U.S. Department of Education staff when the COE came up for federal review in December underscores the fact that in accrediting foreign institutions, American agencies like the COE are not accountable to any government. While accreditors have to answer to a federal oversight committee for their domestic accreditation decisions, the Department of Education's authority does not extend to the accreditation of foreign institutions. Indeed, the above-mentioned report states that the department had received complaints that the COE had accredited several foreign programs that failed to meet its standards (a charge Granstrom denies), but reiterates that the COE's "foreign accrediting activities are outside the scope of the agency's review for continued recognition.”

However, CHEA, a voluntary association that also recognizes U.S. accreditors, does have three standards in its recognition criteria that apply to the accreditation of foreign institutions or programs. It requires that a recognized agency “accredits institutions and programs in institutions that have legal authority to confer higher education degrees, whether U.S. or non-U.S. institutions,” that it has “standards, policies, or procedures that, when the accrediting organization engages in international activities, assure reasonable efforts to communicate and consult with appropriate governmental and nongovernmental accreditation or quality assurance entities in other countries,” and that it has “policies that call for substantially equivalent application of standards and policies to U.S. and non-U.S. institutions and programs alike.”

“I suspect that we may be giving the imprimatur of U.S. accreditation to places that may not really deserve it,” says Altbach, director of the Center for International Higher Education at Boston College and a longtime critic of accreditation of foreign institutions by U.S. accreditors (and a blogger for Inside Higher Ed).  That said, Altbach points out that one subtlety that could be lost in foreign countries is that accreditation isn’t a stamp of exceptional quality in the U.S.;  rather, it reflects a grade of “good enough.”

“We accredit some pretty lousy institutions here,” Altbach says. “I’ve always referred to U.S. accreditation as a kind of a basement below which you cannot sink, and that’s fine. Because there should be diversity in the system, and it shouldn’t be too horrible.”

But as he notes, the problem is that U.S accreditation is perceived as a sign of prestige abroad. “It doesn’t have to take Harvard to be accredited here, and yet when you’re accredited by ABET or whoever in Kazakhstan, the local population thinks you’re as good as Harvard because that’s what they think accreditation means.”