Nov. 15, 2006

First on the Docket: Accreditation

It’s quiet. Too quiet.

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Those who have been following the work of the Secretary of Education’s Commission on the Future of Higher Education — be it with excitement or, more commonly in higher education, trepidation — might be forgiven for feeling either forlorn or relieved at how little has been said and done about the panel’s agenda since the commission formally completed its work in August. After nearly a year of meetings, reports and occasional high drama, the aftermath of the panel’s report has unfolded largely in a vacuum.

Trying to figure out where things go from here — how the Education Department carries out the commission’s work — is a challenge. The commission’s report, while filled with broad proposals and recommendations, was hardly a roadmap for action. And Margaret Spellings’ most expansive comments on the report — a late September speech at the National Press Club — offered many supportive statements but laid out an agenda that was heavy on rhetoric but relatively light on specific, detailed proposals.

Department officials and many college leaders acknowledge that the process of carrying out the panel’s recommendations is likely to be a scattered one, overarchingly overseen by the department but made up of many small steps by many players: the department doing some things, college associations or groups of institutions stepping forward and taking their own actions, and the like. More than one observer of the situation has uttered the phrase “let a thousand flowers bloom” to describe how the implementation phase might unfold.

The first concrete step in the process occurs at the end of this month, when the Education Department holds a half-day forum on the Spellings commission’s recommendations on accreditation. The November 29 forum in Washington, to which the department has invited several dozen college officials and experts (and quite consciously not invited others, though the meeting is open to the public), is designed to “identify strategies on how the accreditation community and its stakeholders can implement” the commission’s recommendations, according to the agenda.

Accreditation, the system that higher education uses to regulate itself, took a pounding in one of the “issue papers” that the commission’s chairman, Charles Miller, solicited early in the panel’s work. The paper, which essentially called for junking the current system and replacing it with a “national accreditation framework,” was panned — even by accreditation’s many critics — as too harsh and extreme.

And while the language the commission used concerning accreditation softened over the course of its deliberations, its final report still embraced the view that accreditation too often impedes rather than encourages innovation and quality, that accrediting agencies focus their analyses of institutions too much on financial and procedural questions and too little on whether students learn, and that the whole process is too secretive and needs more sunshine.

“Accreditation reviews are typically kept private, and those that are made public still focus on process reviews more than bottom-line results for learning or costs,” the panel said in its report. “The growing public demand for increased accountability, quality and transparency coupled with the changing structure and globalization of higher education requires a transformation of accreditation.”

The panel’s core recommendation to fix those perceived problem was summed up in one, long paragraph:

“Accreditation agencies should make performance outcomes, including completion rates and student learning, the core of their assessment as a priority over inputs or processes. A framework that aligns and expands existing accreditation standards should be established to (i) allow comparisons among institutions regarding learning outcomes and other performance measures, (ii) encourage innovation and continuous improvement, and (iii) require institutions and programs to move toward world-class quality relative to specific missions and report measurable progress in relationship to their national and international peers. In addition, this framework should require that the accreditation process be more open and accessible by making the findings of final reviews easily accessible to the public and increasing public and private sector representation in the governance of accrediting organizations and on review teams. Accreditation, once primarily a private relationship between an agency and an institution, now has such important public policy implications that accreditors must continue and speed up their efforts towards transparency as this affects public ends.”

What that paragraph boils down to, accreditors, college officials and experts on higher education generally agree, are a few key goals: pushing accreditors to push colleges to measure in comparable ways how well their students are learning; ensuring that accreditors make those student learning outcomes more central in their judgments of how well colleges are performing; and making those learning outcomes (and the results of accreditation decisions generally) public.

Exactly how the Education Department might seek to bring about those changes — and the role this month’s meeting might play — are far less clear.

Vickie Schray, a Spellings aide who was the commission’s deputy director for management and planning, insists that the Education Department has no preconceived notions about what it expects from the November 29 session. She described it as a “conceptual conversation” at which knowledgeable observers about accreditation can “really get [their] hands dirty” and find “solutions on how to move forward.” “The focus is clearly on looking at what we’re doing and how can the accreditation community put greater emphasis on performance outcomes, particularly in student achievement.”

Many accreditors and college officials have responded gruffly to the commission’s repeated assertions that they are not paying enough attention to how students learn. They note that virtually all accreditors have clear standards that require colleges to provide specific evidence that they measure student learning, and take steps to improve programs based on the results of these measurements. “I don’t think there’s any question but that we’ve made our processes more rigorous,” Ralph Wolff, president and executive director of the Western Association of Colleges and Schools, said last June in response to the commission’s white paper blasting accreditation.

That accreditors feel they’ve done a lot more to require colleges to measure student learning, and that colleges feel as if they report a great deal to their accreditors about how successfully their students learn, is true enough, says Judith P. Eaton, executive director of the Council for Higher Education Accreditation, which represents accreditors. But that doesn’t mean they are doing all that the commission and the department want.

“When accreditors say they’re doing all this stuff, they’re right. And when institutions say we’re being assessed, they’re right,” Eaton said. “But what the report is calling for is a bit different. It’s talking about collecting what the actual outcomes are, and using that to say, ‘This institution is doing a good job.’ And it wants comparability, such that institutions would use similar enough measures that they could be compared to other institutions with similar missions. That is going to take something of a shift in accreditation.”

That’s a shift that many accreditors — and many college administrators and professors — may well be uncomfortable with. But Margaret A. Miller, a University of Virginia higher education researcher who is among the experts invited to this month’s Education Department meeting, says that her experience helping the State of Virginia decide how well colleges were educating students persuaded her that comparability is essential.

“Institutions are collecting assessment data, but it’s unintelligible,” Miller said. “The only way you can answer how any program or institution is performing is through the comparability question. ‘Compared to what?’ is the key question.”

Getting There

While there is general agreement about where the department would like to go (if not unanimity about the wisdom of that course), the path it might take to get there — and how much is done voluntarily rather than mandated by regulation or law — is uncharted.

This month’s accreditation forum is clearly the first step. Jane Wellman, a higher education researcher and consultant who had a hand in writing the Spellings commission’s report and is invited to the forum, says that department officials are probably hoping that the discussion “sparks a conversation” that gets the participating college and accrediting officials to agree on some things they might do on their own. “If the accrediting community and leaders of higher education move on their own toward the direction of more attention to learning outcomes and greater accountability, that’s all to the good from the secretary’s perspective,” Wellman said.

(Getting agreement from those invited to this month’s meeting may be possible in part because of who is invited, and who is not. While department officials had not as of the time of publication provided a full list of those who were attending, because some invitations were still out, it is clear that most of those invited to participate are friendly to the department’s goals — and that many of those who have been most critical of the commission have been excluded. Among those not on the invite list are David Ward, president of the American Council on Education, even though it is the umbrella group for higher education. Ward was on the Spellings commission but was the lone dissenter in the panel’s final vote, a decision, says Miller of UVa., that probably “opted him out of the conversation.")

If consensus doesn’t emerge from the accreditation forum, the department has two other options, Wellman, Eaton and others agree. The first would be to seek changes in law (through the Higher Education Act) that would force more attention to outcomes and greater public disclosure. While some lawmakers (even among the Democrats who will control the 110th Congress) may be open to that course, there is widespread agreement that department officials are likely to save the relatively few legislative chits they’ll have with the new Congress for their top legislative priority: renewal of the No Child Left Behind program for elementary and secondary education.

Perhaps a likelier scenario — which the department signaled in August in announcing a possible agenda for negotiated rulemaking to carry out recent changes in federal law — is that Spellings and her aides seek to use regulatory powers to compel changes in accreditation. While the department may actually have to change some federal rules to achieve its goals, which would require the rules to be negotiated with college officials, it is also possible, Wellman says, that some of its aims may be accomplished “just by changing enforcement of existing regulations.”

That could conceivably be achieved, Eaton says, if the National Advisory Committee on Institutional Quality and Integrity — the Education Department body that is charged with recognizing the right of accrediting bodies to operate — becomes more demanding in what it requires individual accreditors to ask of the colleges they oversee. The advisory panel’s standards already call for accreditors to prove that they require colleges to prove that they are showing “[s]uccess with respect to student achievement in relation to the institution’s mission, including, as appropriate, consideration of course completion, State licensing examination, and job placement rates.measure student learning.”

It is quite possible, she and others say, that the advisory committee could, in the process it uses to certify (or decertify) accreditors, prod them to demand more specific (and consistent) outcomes measures from colleges. That would largely depend on whether lawyers for the department decide that its officials can alter the advisory panel’s standards without going through the formal rulemaking process.

Many people will be closely watching the department’s moves on accreditation (and the Spellings panel’s recommendations as a whole) — and not just the accrediting and college officials who are wary of the department’s direction. Even before last week’s election, members of Congress warned Spellings in a letter to move cautiously in trying to regulate her way through the commission’s proposals. Some college officials seem to be hoping that the Democrats will be less likely to support the Education Department’s accountability agenda generally, including the accreditation proposals, but that is far from a sure bet.

The accreditation forum will be held on Wednesday, November 29, from 11 a.m. to 5 p.m., in the 10th floor auditorium of Potomac Center Plaza, 550 12th Street, S.W., in Washington. Those college officials who were left off the invitation list should not fear: It is open to the public.

— Doug Lederman

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