Symposium Entry

Give credit where credit is due

November 4th, 2015

Accreditation agencies are neither pawns nor anti-progress. But the process could use some clarification.

Higher education’s accreditation community, in particular the six regional accreditors that serve as gatekeepers to Title IV financial aid, has been a summer target for criticism by Congress, the Obama administration, and various special interest groups.

On one side, accreditors are portrayed as pawns of their respective “clubs” (made up of the institutions they accredit), quick to serve the interests of members, but slow to admit new ones, or to punish any “bad actors” in their midst. On the other side are those institutions, typically for-profit organizations, seeking easier access to federal funds for customers of their various products, who say that accreditors are “too tough” in granting accredited status. In the view of these critics, accreditor caution and sense of stewardship around tax dollars is positioned as a barrier to creativity and innovation, if not the doing of entrenched Luddites.

Accreditors and Innovation

The charge that regional accreditors are slow to embrace innovation and new approaches to degree completion are largely without basis and run contrary to history.

In 1986, the Western Association became the first regional accreditor to recognize an online degree program—20 years before the U.S. Department of Education accepted the model for Title IV eligibility. The Higher Learning Commission (aka, “North Central”) was the first to accredit a national, for-profit, online institution and, most recently, the New England Commission led the way in supporting financial aid for competency-based education. In each of these instances, it has been the Department of Education, and not regional accreditors, that has created the bottleneck—as is currently the case with additional CBE Title IV approvals.

What few of those with negative opinions understand is the purpose of these non-governmental, non-tax supported bodies has been historically to serve as objective arbiters of academic quality. The evolution of the U.S. higher education into the premier system it is—and a model of inspiration to the developing world—is a testament to their success as assurers.

Reauthorization and Calls for Reform

With reauthorization of the Higher Education Act now before Congress, the question becomes whether to place greater responsibility on the accreditors for regulatory compliance enforcement, or renew their mandate for quality reviews and continuous institutional improvement. To expect that accreditors can do both is unrealistic. Rare will be the institution that asks for accreditor guidance knowing that they could be punished for the very deficiencies that prompted the request.

One alternative proposal to the existing process would be to delegate the standard setting and gate-keeping role of accreditation to each state. This, of course, would set the stage for the nightmare of dealing with 54 (50 states, the District of Columbia, and three territories) different sets of rules, as is the case for online learning programs under this administration’s “State Authorization” requirements. The impact on credential recognition, credit acceptance, and mobility could be disastrous, if, for example, one state refuses to recognize determinations of another. Choice will also be reduced as program providers, traditional and post-traditional alike, refuse to incur the costs of multi-state compliance. “State Authorization” for online learning serves as a reminder of what forcing states to take certain actions has created for the marketplace: Institutions have withdrawn from high-regulation states and millions of dollars in compliance expense have been added to the cost of a degree.

Another option would be to centralize accreditation under the federal government, as this administration has attempted to do. Here, the risk is subjecting higher education to the ideological priorities of the political party in power (e.g., “no one should profit from the provision of education”). In this formulation, it’s not hard to envision calls for withholding financial aid for certain courses based on subject matter, title, or required texts. Considerable cost would also incur if a federally-managed system replaces the current voluntary, membership-funded one.

Recommendations

I have personally gone through the reaccreditation process, multiple times and in multiple regions. I have served on accreditation teams, both as a member and as a leader. And I can say from first-hand experience that the attainment and maintenance of accreditation is a rigorous process. There is no rubber stamping or back scratching, as some allege. Neither is there a protectionist “cartel.” Newcomers must demonstrate a commitment to standards, a criterion which applies equally to every institution.

A first step in improving the process would be to recognize that there are areas for improvement in regional accreditation, short of accepting all the innovations that have emerged. Areas for change include:

1)      Frequency of visitations. The current standard of 10 years between visits is far too long.

2)      Enhanced financial analysis by visitation teams, including use of licensed CPAs for visits to those which operate as businesses.

3)      Mandated coordination between regional accrediting bodies and the states within their borders.

4)      Greater transparency as to the outcomes of site visits and actions taken by the review boards that act on visitation reports.

5)      Greater effort to educate the public on the function of accreditation and how it works.

6)      A hierarchy of types of accreditation for Title IV access, starting with an expedited “provisional” status for those wanting to offer new models of delivery.

7)      Broader array of possible disciplinary actions (with real teeth) for “bad actors,” including suspension of Title IV entitlement for varying periods, depending on offense.

8)      Clarity to ensure that regulatory compliance will remain within the realm of government and entities having police powers.

In summary, when some see you as “too tough,” and others think you’re “too lax,” you may actually have it about right. Regional accreditors have served our nation well. Congress would also do well if it were to focus more on transparency and enhancing the ability of regional accreditors to perform their duties, rather than transforming them into a federal higher education police force.

John Ebersole is president of Excelsior College, a private, nonprofit, distance learning institution in Albany, N.Y.