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Mark DeFusco

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Morphing Accreditation

Accreditation is the primary barrier to innovation in American higher education … the biggest barrier to real competition. Accreditation is the biggest barrier to real change.  –Charles Miller, Chair of the Spellings Commission

Consistent with this approach are the general assumptions on which accreditation processes are based, including: first, that each academic institution should define its educational purposes and be evaluated primarily according to those purposes, and not by any single common standard; second, the institution itself should play a major role in accreditation through the self-study process; and third, that persons with academic expertise should participate in inspection that allow accrediting bodies to evaluate quality. Accreditation, along with many other aspects of higher education, thus reflects a typically American preference for “bottoms up” solutions, where decisions are made by individual institutions. –UNESCO International Institute for Educational Planning

I can’t believe I am writing this blog.

While I believe that Charles Miller was, and is, substantially correct, I must also confess that our more than century-old habit of self analysis and collegial improvement has made the American higher education system the envy of the world—as evidenced by the UNESCO report’s recognition of our regional, voluntary, and wholly independent system as a model for the world. I am troubled by what is becoming of accreditation—the hope that it will be a guarantor of quality. Accreditors were never intended to serve this function and in fact are ill-equipped to move in that direction without substantially changing their character. It is this character of collegiality and trust that comes from careful and respectful feedback from peers that has made this process a moment for improvement. To change this in favor of consumer protection misses the boat on the purpose not only of accreditation but on the true purpose of all higher education.

Regional accreditors find themselves under siege. The first hints of this came several years ago when the Inspector General (IG) of the United States Department of Education, disagreeing with a specific Higher Learning Commission (HLC) finding about a member school, publicly challenged the commission’s ability to distinguish quality. It seems well beyond the authority of a civil servant to question the results of independent deliberation. If the IG had a problem with procedure, then perhaps that is cause for investigation. If one has a problem with conclusions, well get in line. People of good faith can often disagree with what facts mean, but the HLC was required to follow their standards developed over decades by informed members and thus saw the facts (in this case, awarding of credit) differently than the Department. Not reporting to the Department, one can understand why there would be disagreement.

Recently, the Harkin Commission has been merciless of accreditors, wondering how schools, with what Harkin considers questionable business practices, can continue to be accredited. In most cases, the issue of specific business practice rarely comes up in the self study or the comprehensive visit because the primary focus is the academic quality of the program and whether the institution is able to carry out its stated mission and objectives. Short of brief investigation of financial viability, accreditors have little data about the daily functions of how the business is run, and frankly that is beyond the scope of their charge. They do not have the resources to go into greater depth—nor the inclination. It would be analogous to your therapist asking you for your financial statement before she could actually help you improve. The UNESCO report emphasizes that the strength of the system is that it is privately organized and maintained. Accrediting bodies are self-supporting, deriving their budgets from member dues and fees. (The UNESCO report was astonished that one of the regional accreditors had an operating budget of under $2 million and a staff of just 12, monitoring 160 institutions with over 650,000 students.)

This is not the first major morphing for regional accreditation. Developed at the turn of the last century, many of these bodies developed as a consequence of administrators of America’s burgeoning colleges having real problems with the students applying to their schools. In fact, most accreditors started out by developing standards for secondary schools, so that not knowing much about potential applicants, colleges could begin to deal with the vastly uneven preparation of high school graduates. In the 1930s and 1940, they turned the focus of quality onto themselves, in large measure so that they could gain an idea of quality and equivalence so that transfer of credit could be organized and orderly. The Serviceman’s Readjustment Act of 1952, popularly termed the “GI Bill,” saved many colleges in financial danger as a consequence of the war. (Remember, most colleges of those days served only men—and they were off doing other things.) As a jobs bills (giving the American economy time to absorb returning men) the bill allowed returning veterans a sum of $500 a year for educational costs and a $50 a month stipend for living expenses. As a result, there was a growing bevy of enterprises that provided “education” to unsuspecting students. After complaints made their way to the Veterans Affairs, the Government Accountability Office (GAO), the Bureau of the Budget, and two special committees of the United States House of Representatives, the US government looked to the self-regulated and voluntary associations of public and private institutions to help decide who was legitimate and who was exploitive.

The genesis of today’s present crisis occurred with the passing of the Higher Education Act in 1966, which made accrediting bodies the gatekeeper for eligibility to administer federal financial aid. In this way accreditation began to be a two-edged sword. While it was originally designed to promote institutional self-improvement, this new role gave accreditors the imprimatur for a member college to operate (colleges would be nearly impossible to fund without federal financial aid—though a few exemplary institutions do). The growth of for-profit institutions which were national in scale and which defied the regional organization of accrediting bodies, and the development of online nonphysical universities which by their very nature did not fit within a region, added complication to a process that simply asked if institutions did what they said they did.

The sheer volume of aid distributed (last year estimated at $175 billion annually) and the size of the industry (with 20 million customers generating $450 billion in revenues) demands quality oversight. The “triad” of regulatory oversight that we have depended upon has been challenged (state authorities allow for the authorization of institutions to grant degrees and often provide consumer protection, the Department of Education as underwriter of student aid and guarantor of loans provides underwriting guidance, and regional accreditors speak to educational quality). Some have warned that higher education is the next “bubble” and therefore are calling for more and more strident regulation.

NACIQI (National Advisory Committee on Institutional Quality and Integrity) has released its Draft Final Report for Higher Education Policy Recommendation. It contains recommendations that would severely compromise the mission and character of the accreditation process. Judith Eaton, speaking for accrediting bodies through the CHEA (Council for Higher Education Accreditation) issued a careful response that questions a government-driven approach to quality but rather provides evidence of student achievement, transparency about institutional and student performance, and establishes expectations and results of teaching and learning by continuing to rely on faculty as the primary source of authority for academic judgment.

This will mean a serious faculty who focuses on the serious concerns of the entire higher education constituency (not just a narrow discipline or department but the entire venture). Failing that, government in its profound wisdom will establish rules that no one will be able to live with (have you been through a line at the airport recently?). It will call on a faculty that is proactive and concerned with more than teaching load and schedule. Andrew Delbanco of Columbia University, in a recent article titled “College at Risk”, outlines a compelling argument about the purpose of college. It is unarguable that the nature of college is changing. Most often folks in the Academy are unprepared and unwilling to deal with that change (Delbanco quotes the English classicist F. M. Cornford and his first law of academe: “Nothing should ever be done for the first time”). But for colleges and the bodies that accredit them to remain credible and authoritative, they must be prepared to evaluate the changes that every marketplace makes as technology and consumer needs change. In this way colleges can continue the important mission to be a place where a student’s plea is answered—”Oh that the Lord would show me how to think and how to choose.”

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