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(Editor’s note: When Congress renewed the Higher Education Act last summer, lawmakers scuttled the National Advisory Committee on Institutional Quality and Integrity. which advises the U.S. secretary of education on accreditation issues. The panel is soon to be reconstituted with new members appointed by the secretary and by leaders in the House and Senate. The column below offers advice to those making the selections, and to their eventual selections.)
Accreditation long preceded the establishment of the U.S. Department of Education, and it is only within the past 50 years that a nexus was established between accreditation and the ability of a postsecondary institution to award federal student financial aid. Congress, in helping needy students attend college, needed to determine which schools are of sufficient quality to participate in programs under Title IV of the Higher Education Act.
Since we do not have a Ministry of Education, this determination required that the Department of Education frequently look over the shoulder of accrediting agencies to read their lists of quality institutions. Accrediting agencies receive no federal support and therefore are, in a very real sense, simply doing the department a favor in sharing these privately determined and privately supported lists.
There is another side to the story, of course. Accrediting agencies are supported by the schools and colleges they accredit, and are anxious to have the department consult their lists, keeping their accredited institutions eligible to participate.
One further element. Since anyone can create an accrediting agency, there must be standards whereby an accrediting agency is determined to be a “reliable authority” -- i.e., accrediting agencies must be recognized by the Secretary of Education. This has spawned a series of regulations surrounding accreditation; every recognized agency must meet a number of requirements, submit appropriate reports, and petition for renewal of recognition every five years.
The Department of Education has developed a great deal of expertise in executing this process, staffed by policy analysts who examine petitions, participate in site visits, draw conclusions, and prepare a report.
All of this plays itself out before the National Advisory Committee on Institutional Quality and Integrity, known as NACIQI. Although this is nominally an advisory committee, the Secretary of Education has usually followed the recommendations of this body, so the individuals sitting on NACIQI have a great deal of influence on the process, and therefore, on all of American higher education.
Suffice it to say that the precarious balance between a government needing to consult the lists of recognized accrediting agencies, and the desire of accrediting agencies to be so recognized, can be greatly nuanced by the nature, knowledge and personal outlooks of the members of NACIQI.
Against this background one must admire the businessmen, legislators, lawyers and financial aid officers who will serve on NACIQI, often armed with little more than their own personal exposure to college, as background to the task of recognizing accrediting agencies.
If past experience is prelude, these will be intelligent, involved, alert and sensitive people. By the time their three year term of office is over, many, perhaps most, will have begun to understand the complexities of accreditation. They will have sensed the nuances of difference between agencies and between fields, understood the nature of peer review, and appreciated the manner in which accreditation enhances quality and leads to change -- and sometimes to improvement.
They will also have begun to appreciate the conditions leading to successful student outcomes and the role of faculty, students and facilities (inputs!) in a college’s successfully completing its mission.
Until these revelations happen, members will know little more than what they were told in Department of Education training sessions. They will know to watch for conflicts of interest, they will be introduced to the government lawyer who will be present to help them navigate the regulations, and they will hear about the conduct and impact of their sessions.
But they won’t get to meet accreditors first hand, and will not have an opportunity to participate in an actual, on site accreditation visit. They will possibly be addressed by people who will cast doubt on peer review, and who claim that expert judgment is not sufficient to establish the quality of programs and institutions. Numbers, they will be told, are needed instead. No matter how irrelevant, incomplete, inconsequential, or purposeless the numbers happen to be.
NACIQI members, at least in the early years, may not be in a position to challenge those assumptions, with questions like: Why were these particular measurements chosen? What have such numbers shown in the past? What improvements to teaching, learning, and policy resulted from their use? Where is evidence of the validity, reliability, and relevance of these measurements?
They probably will not have participated in conversations that questioned the cost/benefit of all this measurement. Nor will they realize that ”accountability” has not been defined, operationally or otherwise, and that the theories that govern public education policy, have rarely, if ever, been subjected to experimentation and test to scientific standards.
Polite, attentive NACIQI members will hear presentations from persuasive speakers who work at the peripheries of higher education, but not in it. They will not hear from the people who teach philosophy and English, art and accounting and engineering to ever increasing numbers of indifferently prepared students.
The Department of Education staff is not at fault: It’s simply that the accreditation agenda has been taken over by those who bring a regulatory mindset to the process. Hence, NACIQI rarely hears words such as “scholarly,” ”deep study,” ”well read,” and “erudite.” They do hear about measures, templates, benchmarks and graduation rates.
As in the past, NACIQI stands to be diverted, unless new members are prepared to defend the academy, to preserve accreditation, and, from the very outset, to challenge, to question, and to examine.
Transparency, in certain frameworks, is a blessing. In accreditation it can convert the site visitor (who benefits from open, frank and revealing interactions) to a regulator (who is reduced to checking off boxes in a rigid grid). “Does transparency have a chilling effect on the site visitor’s report?” is a question that might be appropriate for a NACIQI member.
When hearing about graduation rates, NACIQI might profitably ask whether human interactions (a legislator’s effectiveness, marriage, religious experience), and enterprises (hospitals, jails, retirement communities, colleges and universities) can, indeed, be reduced to numbers.
In a phrase, NACIQI must have people at the ready, from day one, to push back. When they hear talk about student engagement, for example, they must be able to ask questions like: “Does engagement create successful students or are successful students engaged?” And to ask about the experiments, to scientific standard, that support the answers.
NACIQI members must not hesitate to go beyond the surface to seek out the ideas and complexities of accreditation. They should not be intimidated by words like “regulations” and “statutes.” Law as applied to education is a guide, not a barrier or a set of blinders. The Higher Education Act expects that NACIQI members will be people of a variety of backgrounds who are fair and perceptive, with good judgment. NACIQI was not intended to be made up entirely of lawyers.
Education is an analog process that cannot be properly understood or described in terms of discrete digital elements. Even if a qualitative question can be posed, NACIQI members should be prepared for a quantitative response.
At one particularly painful period, accrediting agencies were being asked about the number of applicant schools they rejected. Some members of NACIQI seemed impatient with anything other than a simple numeric answer. Actually, rejection often takes place before a formal application is submitted. The head of the school makes contact, gets to spend a long time with an accreditor, learns enough about the process to know what may be missing, and how to get ready for the future. By the time most schools apply, they’re ready to succeed. A number tells a distorted story, if that!
There are many other such pitfalls; fortunately transcripts of previous NACIQI meetings are readily available, so that anyone can relive some of the highlights (or lowlights) of the past. Attending a conference of the Council for Higher Education Accreditation and/or spending time with accreditors will be invaluable as well.
In the end, the success of NACIQI will depend upon the selection of people who are independent thinkers, knowledgeable, confident, and able to clash in the world of ideas – knowing that every word they utter will be recorded, transcribed, and made available to everyone, everywhere.
Oh yes, by the way, welcome.
