Advice for U.S. on Accreditation

When we last checked in on the National Advisory Committee on Institutional Quality and Integrity, which advises the U.S. education secretary on accreditation issues and grants federal recognition to accrediting agencies, Congress had essentially shuttered the panel, amid concerns that the Bush administration's Education Department had excessively politicized its work. Congress's renewal of the Higher Education Act scuttled the 12-member committee, whose members were appointed exclusively by the education secretary, and reconstituted it as an 18-member panel with six members each appointed by the secretary, leaders in the Senate, and the House of Representatives. Under the law, the panel's duties would be little changed, although its influence on the secretary's decisions about which agencies to recognize is, as some perceive it, diminished.

On Monday, the U.S. Education Department announced that it was seeking nominations for the new (and improved?) NACIQI (nuh-SEE-key), as it is called. With that in mind, Inside Higher Ed approached a group of experts on accreditation for their insights into what they would like to see the federal panel do going forward -- and the sorts of people the government should seek to do that work. The responses from association leaders, policy experts, critics -- and a knowledgeable faculty member or two -- are below.

Feel free to add your own responses as comments appended to the end of this article.

Brent Ruben, Ph.D., professor of communication and executive director, Center for Organizational Development and Leadership, Rutgers University:

Much of the intrigue associated with the previous committee seemed to be an outgrowth of questions about the ideological, and perhaps a political agenda of the Committee or of some of its members. With the passage of time, and the gradual but undeniable influence of the Spellings Commission and the follow-up activities of the Department, two things seem apparent: 1) The push to be more evidence-based, systematic and transparent has been embraced by a growing number of members of the higher education community; and 2) The assumption that pressures for change and accountability were motivated solely by partisan politics and would quickly fade with a new party coming to power has proved a very oversimplified view.

One would hope that this means that the new NACIQI and its members can be begin their work on a sound and positive footing. Hopefully, this new group will be able to distinguish themselves not only for rigor and discerning counsel, but also for a breadth and depth of knowledge and advice that reinforces the many encouraging changes that are underway within the accrediting community and our institutions.

For these aspirations to be realized, members should be broadly familiar with the challenges facing the higher education community, and also with the challenges confronting students in their efforts to take full advantage of the many benefits we have to offer. They would hopefully recognize the value of accreditation for assuring compliance with baseline standards, but also for fostering, documenting, and encouraging continuous improvement and innovation at all levels and in all venues.

Ideally, the group as a whole would be a mix of practitioners and big-picture people--people on the front lines who know about the issues from both an institutional and sector perspective combined with those who have operational understanding of what is involved in the implementation of any policy (data, curricular, programmatic). Because the new NACIQI will be advisory only to the Secretary of Education, it is also essential that the appointees be independent-minded and free of conflicts of interest.

Judith Eaton, president, Council for Higher Education Accreditation:

Above all, my hope is that the National Advisory Committee on Institutional Quality and Integrity is populated by individuals, each of whom brings a broad range of experience to this important task. We need men and women who have worked in colleges and universities and in accreditation. We need individuals from business and public service who have experience with higher education and accreditation. Over all, the 18 people making up the committee should reflect expertise in higher education, in all types of accreditation, in nonprofit and for-profit business and in federal and state government. We need people who are intellectually engaged and have background in the vital issues of the day for higher education and quality assurance.

Second, NACIQI needs to be the voice of the public when advising the Secretary of Education about the recognition of accrediting organizations. It is through the advisory committee that the Department of Education comes to understand the public’s need for accreditation and the public’s views on pressing issues in higher education such as access and success, accountability and student achievement. Absent this public voice, government officials with responsibility for federal review of accreditation -- and the hundreds of billions of dollars at stake each year -- lack key information and guidance. Absent this public voice, taxpayers are denied the full benefit of rich and robust accountability and transparency.

While the advisory committee has, by law, a regulatory role, this needs to be carried out with keen awareness and respect for the long and successful history of higher education and accreditation in the United States. It is essential that the committee operate within a context of respect for responsible institutional independence and academic freedom, as well as investment in the diverse higher education enterprise that has served the nation so well. Accreditation has been central to the sustained effectiveness of higher education. The committee’s work should build on – not conflict with – the responsible independence that accrediting organizations need to carry out the complex task of peer/professional review that is the hallmark of U.S. quality assurance and improvement. The committee may prod accrediting organizations; it should not prescribe. The committee holds accreditors accountable for achieving results; it should not dictate how those results are to be achieved.

The advisory committee is a key venue in which appropriate public accountability and responsible academic leadership meet. We look forward to working with the new NACIQI.

Anne Neal, president, American Council of Trustees and Alumni (and former member of NACIQI):

Who protects the public interest? That is the question. In today’s Federal Register, the Department of Education asked “interested parties” for nominations to NACIQI, the National Advisory Committee on Institutional Quality and Integrity. Overseeing billions in federal student aid, NACIQI is not a household word. Mom and Dad pay the taxes that fund those billions — but they don’t know about NACIQI, they wouldn’t consider themselves “interested parties,” and they wouldn’t likely qualify for NACIQI membership. Yet they care about educational quality. They assume federal oversight is open-minded and independent. They expect their hard-earned tax dollars to support the public interest, not special interests.

If only they knew. Since it was established, NACIQI has been filled with “interested” parties who are often themselves “regulated” by accreditors and who are more attuned to politics than accountability. The state of affairs is assured by the powerful education lobby, which spent over $100 million last year to defend its interests.

It’s time that changed. Going forward, I hope for nominees knowledgeable about higher education – but not beholden to it. Nominees who will bring independence of mind and a focus on educational quality and public accountability. In short, it’s time for disinterested nominees. In the corporate world, conflict of interest is taken seriously. We expect to see independent auditors. Alumni, trustees, and taxpayers should expect no less from higher ed.

David Scobey, Director, Harward Center for Community Partnerships and Donald W. and Ann M. Harward Professor of Community Partnerships, Bates College:

My inclinations are to encourage more of an advising/convening role for the Commission, in addition to its necessary role in accrediting the accreditors. Lack of transparency in accrediting seems to me among the biggest problems that the regional agencies and NACIQI needs to tackle. The regional accrediting agencies raise good issues in their work with campuses and enforce some accountability in what are essentially confidential conversations with campus leadership; but everyone, even faculty and campus administrators, experiences them as mysterious, unaccountable, commanding lots of periodic effort, but also external to the ongoing, everyday practice of campus educators. And the conversations that happen between campuses and accreditors have zero visibility in the larger national and public conversation over higher education. As a result, public stakeholders view campuses as unaccountable and irresponsible, in part because the accreditation process does not make visible the critical self-reflection, accreditors' feedback, and institutional response that takes place.

There is good reason for this: accreditation has been designed to provide candid, confidential, critical feedback to institutions without embarrassing or endangering the institution--which would in turn discourage frank engagement with problems and challenges. But the "social compact" between higher education and the larger public has gotten frayed; the outcry for more accountability (often simplistic, but wholly understandable) testifies to the legitimation crisis. A more transparent and public conversation about what counts as good education, how it should be assessed, and what colleges and universities do to document and improve their practice is needed to reweave the social compact and re-secure the resources needed to do our job well. Unless higher education institutions enlarge the accreditation conversation to raise these issues, I fear, the accountability debate will be dominated by voices with basically instrumental and damaging notions of the value of higher education: notions that treat higher education as a machine for basic skill building, credentializing, and job training.

I don't believe that the regional agencies by themselves can lead this public dimension of the conversation about what counts as good educational practice and how it is assessed and improved. But NACIQI -- alongside its important oversight relationship to the agencies -- might well help to catalyze that conversation. I do not mean that the Commission should appoint itself as the de facto creators of a set of Federal higher education guidelines. But it might help to convene conversations that bring together front-line educators, accreditors, and public stakeholders about how to make accreditation less of an auditing process and more of an iterative conversation about educational quality. That would point to representation on NACIQI by more than simply accreditation researchers and practitioners: by college faculty, students, and parents, representing a diversity of academic sectors.

Bernard Fryshman, professor of physics at New York Institute of Technology and executive vice president, Association of Advanced Rabbinical and Talmudic Schools:

Our independent and diverse system of higher education depends on accreditation serving as a barrier against the Department of Education’s direct involvement in colleges and universities. NACIQI members sit at the crossroads of government and accreditation and must ensure that regulations never become a lever, permitting government to intrude into the workings of higher education.

NACIQI members must also be mindful of the implications of a regulation and the way in which its application will play itself out in the classroom. The connection is not always clear, and that is why members should be intimately familiar with higher education, and the values and outcomes which go well beyond simply helping a student prepare for employment.

People serving on NACIQI should not be intimidated by words like “regulation” and “statute.” Law, as applied to education, is a guide, not a set of blinders. The regulations were intended to be interpreted and implemented by people who are fair, perceptive, and with good judgment. NACIQI was never intended to be comprised of lawyers.

NACIQI is an advisory committee and the Secretary of Education is best served when NACIQI members express opinions which sometimes are at variance with the position taken by ED. NACIQI is not intended to be a rubber-stamp body, but rather to exercise knowledge, caring, and discernment in examining an agency against the regulatory template.

Members must be broad enough in their outlooks to be flexible and realistic. They must be able to recognize, for example, that "one size does not fit all." A requirement which might not be difficult for an agency accrediting 1500 schools might be a crushing burden for an agency accrediting 50.

NACIQI members should be open to conversation and should help make the recognition process a healthy, collegial interaction rather than one between petitioner and a hard, unblinking government.

Optimally NACIQI will have some accreditors as members. Even if not, NACIQI members should be familiar with the process and aware of the limitations accrediting agencies sometimes face. In an effort to reduce the cost associated with accreditation, many agencies have a meager staff. Asking an agency to address NACIQI concerns (with report) within one year and still carry out all its accrediting responsibilities might not be possible. A knowledgeable body of members will actively seek to avoid unnecessary hardship in the implementation of the regulations.

The success of NACIQI will depend upon the selection of people who are independent thinkers, knowledgeable, confident, and able to engage in the world of ideas.

Steve Crow, former president, North Central Association of Schools and Colleges' Higher Learning Commission:

NACIQI should serve the secretary of education as a competent, impartial advisory group, knowledgeable enough about accreditation to appreciate its need to be independent in providing higher education quality assurance, yet committed enough to the public purposes and role of accreditation to expect it operate with transparency and accountability.

1. NACIQI should have some members who have actively participated in accreditation activities: for example, presidents of colleges or universities who actually were involved in accreditation activities at the campus level, people with experience serving as peer reviewers, and/or people who have served as "representatives of the public" on accreditation agency boards.
2. NACIQI should have members who understand the tremendous diversity in U.S. higher education and, consequently, the decentralized programs of quality assurance related to that diversity. I don't see these appointees as "representing" the interests of a particular sector, but, instead, familiar enough with them to appreciate some of the differences in the agencies that accredit within those sectors.
3. NACIQI should have some members who have a breadth of experience in studying and reflecting on the larger public policy issues related to education generally and higher education specifically.
4. NACIQI would be well-served to have a couple of members who rely on accreditation as evidence of educational quality, such as foundation program officers or corporate human resource managers.
5. I might suggest as well that NACIQI would be well-served to have someone who understands the role of states in the triad (federal, state, higher education).

My concern over NACIQI in the past has been the tendency by various secretaries to select people (1) with a higher education reform agenda in mind (often consistent with the vision of that secretary), (2) with so little real knowledge of the system that they defer often to the analyses of Education Department staff, and (3) with a regulatory mindset that does not allow for much more than a rulebook emphasis on compliance. This has sometimes resulted in too much enmity and antagonism.

The recognition process should instead provide the opportunity for useful dialogue and the potential for encouraging accreditation to be responsive -- as it most surely can be -- to changing public policy needs and expectations. In short, it posits a healthier partnership of shared responsibility for quality assurance in higher education, making it a vehicle to make the collaborative nature of the triad more effective in furthering public policy interests in higher education.

Michael J. Offerman, vice chairman, Capella Education Company and president emeritus, Capella University

The new NACIQI needs members who bring an informed, balanced, creative, and broad perspective. It is critical that the member is well informed about the underlying assumptions, processes, and purposes of accreditation. The best way to ensure effective knowledge is to choose members who have considerable experience in both institutional and programmatic accreditation. The balance they need to bring to the Committee is to respect the necessity of quality assurance and accreditation while seeking creative and contemporary approaches to assess and assure quality.

Their orientation should not be that of a policing body, but of an advisory committee dedicated to continuous improvement in the way that American higher education assures high quality standards through the accreditation process. It is crucial that the member can get beyond the parochial needs of their institution and even their sector of higher education. Finally, it is important that the member have experience with state licensing approaches involving more than one state so that they can understand the differences and variations that exist from one state to another as they advise the Secretary about the relationship between the accreditation and certification of institutions and state licensing requirements.

Charles Miller, former chairman, Secretary of Education's Commission on the Future of Higher Education

The current accreditation system has two primary purposes: One, assuring a known level of quality in our higher education system and two, serving as a gatekeeper for federal funds. The power as gatekeeper essentially creates the role of regulator. In recent experience in finance and other fields, this kind of self regulatory function is fraught with dangers. Unless the system produces sufficient data in a transparent manner with the capacity to make public comparison of results with other practitioners, it will ultimately fail. Today's accreditation system is short on appropriate data, it is not transparent and it actively resists comparisons. This semi-secret guild system is outmoded and inadequate and allows a culture of insiders to protect rather than improve higher education institutions.

This particular form of gatekeeper -- or regulator -- severely limits the advancement of new models of higher education, focusing primarily on traditional inputs and setting standards on historical experience. There is no prospective form of accreditation such as an initial public offering in the securities markets. There should be some way that would allow willing operators to supply significant amounts of capital and related educational services in an innovative model, fully described and disclosed, which would qualify for accreditation for an extended period prior to commencement of those services. That would allow willing consumers to freely judge the risks and opportunity and make an informed decision.... a decision which would be based on information generally equal to or better than that available to students today. As a result, accreditation today is the biggest barrier to innovation and change in higher education.

There is a built-in catch-22 for innovators and entrepreneurs -- you can't be accredited (get access to public money) until you have proved yourself in advance. You can't prove yourself in advance -- prospectively -- unless you are accredited (or have access to piles of private risk capital for an extended number of years with little opportunity to operate effectively at an economic scale). Innovators today can only resort to buying existing failed institutions -- which are accredited -- and trying to inject their new models of higher education, essentially a backdoor maneuver which only shows the emperor has no clothes. A sound system for accreditation would be one which fully and effectively informs the public and policy makers who are the consumers and providers of funding and fully informs institutions on a comparative basis in order to identify and achieve minimum levels of quality and enhance quality over time. If the system also included a method for prospective accreditation, perhaps with continued reporting, review and registration, it would allow innovative capital to combine with the genius available in higher education to create the new best system of higher education in the world.

To get specific, I nominate Robert C. Dickeson to serve as a resource on accreditation. Bob wrote some papers for the Spellings Commission after stepping down as head of research for the Lumina foundation. He has had experience as a college president, a consultant and with accreditation. He recently presented a paper at the 2009 CHEA Annual Conference entitled "Recalibrating The Accreditation-Federal Relationship." He is thoughtful and measured in his approach to a complex issue, although his ideas have created anxiety because he has been successful in identifying the flaws in the current system while suggesting innovative reforms.

Susan Hattan, consultant to the National Association of Independent Colleges and Universities:

I come at the question of the “new NACIQI” as one who believes that — for all its flaws — accreditation continues to be the best means for promoting quality while respecting diversity. It is uniquely suited to higher education as it has developed in this country because it does not equate uniformity with quality — thereby encouraging innovation and adaptation to change.

My ideal candidate for membership on NACIQI would be someone with a judicial temperament who has a broad perspective on and understanding of higher education. He or she should have experience with accreditation at some level and a respect for the principles underlying it.

I say “judicial temperament” because I believe this would counter two of the problems that consistently arose with the “old NACIQI”: namely, excessive advocacy and inconsistent decision making. NACIQI was blown up due to a perception that it was being used as a means to promote an agenda of federal control and standardization. NACIQI is not, and should not be seen as, a platform for anyone’s individual change agenda. The issue of inconsistent decision making has received far less attention, but has created real issues for accreditors who find there are no real “precedents” upon which they can rely. Expectations have seemed to change with each new review.

My ideal candidate must be someone with the background and skill to offer close scrutiny and rigorous questioning of accreditation agencies, without forcing them down a specific path or methodology for assessing institutional adherence to standards. NACIQI has at times been described as the agency that “accredits the accreditors.” As such, the qualities I have described for my “ideal candidate” are the same ones I would hope to see in a thorough accreditation review -- a tough review and questioning by peers and a fundamental respect for the principle that quality can take many shapes and forms.

Alan L. Contreras, administrator, Oregon Office of Degree Authorization:

The federal government should not use accreditors as its proxies; it should establish its own set of criteria for Title IV eligibility and enforce those standards. That clean, honest, straightforward approach being much too radical a change for the federal government, we are left with the need to make sure that NACIQI serves a useful purpose.

In theory, the reconstituted NACIQI’s mission includes advising the Secretary of Education about the role of accrediting bodies, standards for recognizing such organizations and the relationship of state licensing processes to accreditation. For this reason, it is essential that NACIQI include, among its 18 members, people who actually work in accreditation, or recently did so. One significant advantage to using recent retirees is that they are aware of current norms and expectations, but they are not answerable to any authority but their own judgment.

One obvious choice would be Steve Crow, recently retired from the North Central Association. Another would be Amy Kirle Lezberg, formerly of the New England Association and now a respected private consultant. Both are also experienced in international postsecondary quality issues and are good problem-solvers.

It would be helpful to have someone with experience in international postsecondary evaluation (Lezberg, or perhaps Dale Gough from AACRAO or Stephen Hunt from the Department of Education if an employee is eligible to serve), because U.S. accreditors are increasingly engaged outside the U.S. and in one recent case the overseas behavior of an accreditor generated a great deal of controversy. That will happen again. In the world of recent retirees, Jim Frey, former head of Education Credential Evaluators of Milwaukee, is a universally respected expert on international quality control. It is difficult to have a meaningful discussion about international qualitative oversight without significant input from people who actually do it, and staff input is not quite the same as a seat at the table.

Among state regulators -- one of whom clearly needs to be on the new panel, given that its charge expressly includes linkages with state licensing processes -- my top choice would be David Linkletter, recently retired as postsecondary approval officer for the State of Texas. His views would be based on decades of experience, unquestioned personal integrity and commitment to a factual basis for decisions. There are also many good choices of active state regulators with long experience in what governments should focus on in postsecondary evaluation. Renea Eshleman (South Carolina), Bill Crews (Georgia), Leroy Wade (Missouri), Gina Wekke (Oklahoma), Paula Unger (Pennsylvania) or myself would be good choices, as would many of our colleagues in other states.

At least one member of the body should be a faculty member from an accredited degree-granting institution, ideally someone like George Gollin who has knowledge of accreditation in both an institutional and policy setting. There is also some virtue in making sure that there are at least a couple of people on the panel who are known skeptics of accrediting bodies, to keep the rest from becoming complacent.

Russell S. Kitchner, associate vice president for regulatory and governmental relations, American Public University System:

Experience is a great teacher, and for that reason this committee will benefit from the expertise of seasoned accreditation professionals. However, experience is what makes greyhounds chase a mechanical rabbit around a track, all the while knowing they won't catch it. Therein lies the benefit of having thoughtful, but perhaps fresh minds at the table, particularly in leadership positions where their lack of experience won't be summarily discounted as a function of ignorance. Wisdom and expertise are not necessarily mutually exclusive, but neither do they always accompany one another.

In many dimensions of domestic policy our government has been moving increasingly in the direction of exerting regulatory pressure in matters of education and learning (the two not being synonymous). I suggest that it should consider a refresher course in social motivation, which likely would remind it that human enterprise thrives on empowerment, not oppression. Regulations, while occasionally both appropriate and necessary, will not engender a culture based on the intrinsic value of doing the right thing. Consequently, the committee on which you are focused should be as unencumbered as possible by the sort of image that accrued -- deservedly or not -- to the Spellings Commission.

Conversations about this topic often reflect the fundamental confusion between certification and accreditation. With no disrespect intended, political persons typically seem inherently averse to dealing with subtleties, preferring instead the convenience of broad rhetoric. Thus, the notion of accreditation -- that process of determining if an institution is adequately positioned to fulfill its mission effectively -- is confused with certification, which often is an attempt to measure the degree to which an entity is, in fact, fulfilling someone else’s mission effectively. This difference is more than a matter of semantics, and historically, only the former concept was the purview of accreditors; the latter was the business of the marketplace.

If an institution failed to meet expectations, the result would be that students, donors, distinguished faculty, et. al., would go elsewhere, leaving the institution to wither and fade away. Somewhere along the way, given their propensity for overly simplifying complex issues, politicians moved the accreditation conversation into a fundamentally different realm, and neither accrediting agencies nor their institutional members should have taken the bait. The place for quality assurance should have remained in the marketplace, and with specific program evaluation associations such as the American Medical Association licensing medical programs, the American Bar Association approving law schools, and other various, subject-specific associations and agencies certifying program integrity within their areas of expertise. Our current path leads to a slippery slope, if we have not already begun the descent. Our best hope is that the committee proposed by the Department of Education will seize the opportunity first to revisit this dimension, come to a wise conclusion as to what we should expect of accrediting process, and bring us back from what will otherwise be a painful process of interminable and inevitable balancing of competing interests and quantifiable metrics, all at the expense of what actually constitutes learning and personal development.

Ingrid Walker, director of general education and associate professor, University of Washington Tacoma; former official at two regional accrediting agencies:

As the top of the higher education regulation system, NACIQI would serve accreditation best if it had the ability to set a tone for change in accreditation. It’s greatest impact could be to step back and consider where its regulatory influence is most needed at this point in time. Accreditation is in need of revision, top to bottom. Some agencies have tried to do so with new systems of review. Despite best efforts, however, many of the agencies and their member institutions are not benefiting from their considerable investment in these processes.

Certainly, the details of the accreditation process need revision. However, NACIQI should be regulatory at a broader level -- considering how and why accreditors engage with institutions over time.

To best do this, NACIQI should include professional educators, people who have served most of their careers inside universities and colleges. This vision across higher education is what is needed most because the individuality that we prize as the gold standard of U.S. higher education is also our Achilles heel. The regulatory process would be well-served by people who are familiar with the myriad U.S. higher education institutions and accreditation and how the HEA and negotiated rules are parsed and implemented on the ground level. Many people have this experience; for example, the Boards of Trustees of the regional agencies have some high-powered individuals in higher education with deep experience in this area.

The oversight role of NACIQI is critical because accreditation agencies have a great deal of influence but little competitive interaction with their peers. Regional accreditation is a process that is vital to U.S. quality assurance in higher education. And while that phrase annoys academics, as an academic who has seen what passes for educational oversight at many institutions, I argue that it’s needed. But we should find it to be a process that’s developmentally useful and cost-effective. Accreditation involves millions of dollars a year, in institutional funds as well as federal student aid. It's time we stop and rethink it. I would like to see some leaders on NACIQI who have that vision, ability and mandate.