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Can You Say NACIQI?

December 5, 2006

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In the alphabet soup of acronyms of Washington higher education, most people could probably go a long time before running across -- or caring about -- the federal panel known as NACIQI. But while the National Advisory Committee on Institutional Quality and Integrity is probably not poised to become a household name in the faculty lounge or the campus dining hall, it is clear that the profile of the panel that advises the U.S. education secretary on accreditation is about to enjoy one of its periodic moments of greater visibility.

Judging from Monday's meeting of NACIQI (nuh-SEE-kee), the first since Education Secretary Margaret Spellings and the report of her Commission on the Future of Higher Education put major changes in accreditation near the top of their reform agenda, that visibility is likely to turn up the pressure on accreditors and colleges to provide tangible proof that they are educating their students.

Also likely to increase, if Monday's meeting was any indication, are questions about just how hard the advisory committee can push in that direction without running afoul of federal laws and Congressional prerogative.

The advisory panel is charged, among other things, with granting (or withholding) federal recognition for individual accrediting agencies, and therein lies its power: Without the approval of NACIQI, an accreditor's stamp of approval of a college does not carry with it the all-important right for the institution's students to receive federal financial aid. Although the work of the panel and a now-defunct predecessor have occasionally flared into controversy -- such as when it sought to limit one regional accreditor's imposition of a diversity standard in the early 1990s -- the advisory committee has largely operated out of the limelight.

That may be about to change, because Spellings has made clear -- most recently at last week's forum she called on accreditation -- that she sees the panel as one way the Education Department might be able to carry out its effort to compel colleges and universities to collect and report better data without the need for new laws or federal rules.

This view, which several participants at last week's accreditation forum urged, holds that NACIQI can, using its existing standards for judging whether individual accrediting agencies deserve recognition, begin to force accreditors (and, by extension, colleges) to produce, collect and publish more and better information about student outcomes. Legal experts are divided on just how far the department might be able to go along those lines, but most agree that the NACIQI standards are broad and unspecific enough that there is "a lot of running room."

At the start of Monday's three-day meeting, Carol D'Amico, executive vice president of Ivy Tech Community College and chair of NACIQI, told her colleagues, "I think we're now out of the closet in terms of our role in the whole issue of accreditation and quality. I think the secretary has high expectations for this group going forward."

The advisory committee had already been pushing in the direction of more accountability for learning outcomes over the last year or two, but Monday's meeting of the panel offered several signs that that trend may be accelerating. The panel's new vice chair, Geri H. Malandra, interim executive vice chancellor for academic affairs at the University of Texas System, is closely tied to Charles Miller, who as chairman of the Spellings commission had tough words for accreditors and colleges on the learning outcomes issue.

Perhaps more importantly, some of the reports the panel's staff prepared for this week's meeting were perceived as pushing accreditors harder and further on measuring learning outcomes than they have been pushed before. And the one accreditor that had a chance to respond Monday -- the Western Association of Schools and Colleges' Accrediting Commission for Senior Colleges and Universities -- was firm in pushing back.

The staff report for the Western accreditor found four areas in which the agency needed to improve, including a need to "clarify how it will evaluate the quality of an institution's effectiveness based on the student outcomes data it collects and to outline in its procedures its expectations for institutional improvement (student learning) throughout the accreditation cycle." Although the staff recommended that the Western association be re-recognized for the standard five years, it urged that the accrediting agency be required to report back in a year on its progress in fixing the perceived deficiencies.

When it was his turn to speak, Ralph A. Wolff, president and executive director of the Western association's senior college commission, conceded three of the department's four points but challenged the finding on student outcomes data, which he and other officials from the accrediting group said essentially would require it to tell colleges what performance measures they should meet. He defended the agency's "exceptional record" in holding the colleges it accredits accountable for their performance in educating students, and accused the committee's staff of changing the standards midstream.

"I want to say that you, as an advisory committee and decision making committee, when new rules are applied, I would raise the issue of consistency and fairness, that they be applied equally and consistently to all accrediting bodies," Wolff said. "To have it applied singly to our agency, we would submit, unfairly burdens our institutions beyond what we are are already doing."

Members of the committee, its staff and the Western association proceeded to spend nearly an hour trying to reach agreement on exactly what the commission was asking for, and how big a chance it represented from what the committee has asked previously. John Barth, the Education Department's director of accreditation and state liaison, said that Western officials themselves had identified "triggers," such as graduation rates, that they would use to gauge colleges' performance at various points in the accreditation process. "What we are requesting of the agency" is that it identifies "a somewhat brighter line about how they'd let us know how they're going to make a decision about [how a college has performed on] those triggers."

Richard Winn, associate director of the Western association's college commission, said it would be a "major new regulation" for NACIQI to ask accreditors to set what he called "bright line indicators" for what is acceptable performance for an institution. Requiring accreditors to set benchmarks for performance by the colleges they oversee, Wolff said, would represent a new and unacceptable level of federal intrusion. Referring to Spellings's statement at last week's accreditation forum that the department planned to “do this with you, not to you,” he added: "To impose that on a single agency at this point, with no further discussion, would be to us unfair."

A recent addition to the accreditation panel, Arthur Keiser, president of the for-profit Keiser Collegiate System, said he thought it was legitimate for accreditors to set minimum levels of performance. Citing a hypothetical institution that graduates as few as 3 percent of its students, he said, "I don't think institutions can abrogate their responsibility.... It is not acceptable for us to say that that institution is demonstrating success. At some point we have to be able to say that that [level of performance] is just not acceptable. That's our role. We can't just ignore this thing."

Lawrence J. DeNardis, president emeritus of the University of New Haven and one of the longest-serving members of the advisory committee, suggested a compromise in which the Western association, given its "pioneering work" in measuring student outcomes, would prepare a report about how its member institutions most effectively use data on student success to gauge their performance, in exchange for dropping the finding that it had fallen short of the NACIQI standard. "I would ask that they press ahead and provide some thoughts to us that might be useful systematically," DeNardis said, encouraging the Western association to "be at the cutting edge."

After a bit more discussion -- including a warning from Keiser that "the [regional accrediting groups] cannot hide behind the notion that we cannot collect data" -- the advisory panel unanimously approved DeNardis's compromise.

Having helped to defuse that conflict, DeNardis had some more general words of caution for his fellow members of the advisory committee -- and, implicitly, it seemed, for Spellings and her colleagues at the Education Department. "Clearly the secretary wants to move in certain directions, and there is strong support in this body for many of those recommendations, as they will be clarified over time," he said. "But perhaps there are some things that we cannot do by administrative fiat, and that are better done by engaging the impressing accreditation system that we have."

And while he acknowledged that the accreditation system is at a point where "major changes are indeed in order," DeNardis, who once represented Connecticut in Congress, suggested that there may be real limits on how much change NACIQI, and the Education Department itself, can accomplish on its own. "Excellent concepts, even if they pass muster eventually, need to be institutionalized before they are operationalized," he said. "And they need to be institutionalized first with members of Congress, who will want to play a role" in defining and approving them.

Day 2 of the advisory committee's meeting today could bring more discussion and debate about how far the Education Department should go in requiring accreditors to measure student outcomes. Among the many issues raised in a highly critical audit of the American Academy of Liberal Education is this one: "The agency needs to more clearly define what AALE itself considers acceptable levels of institutional success with respect to student achievementr based on an evaluation that includes external outcomes, both quantitative and qualitative."

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Comments on Can You Say NACIQI?

  • Accrediting the accreditors
  • Posted by feudi pandola on December 5, 2006 at 8:10am EST
  • We need to be very careful with this concept. I work in a sector within the nursing educational continuum that has been nearly "accredited" out of existence due to pure snobbery and prejudice over the past twenty five years. Diploma nusing schools throughout the country have been closed in droves since the seventies primarily because the diploma educational model did not suit the accrediting agencies small minded concepts of what constitutes nursing education. Pennsylvania had over 100 schools in 1975. We have about 25 left.

    The result?

    The worst nursing shortage in the history of the country with Pennsylvania patients suffering the worse due to our elderly population.

    Do we really need yet another level of federal intrusion into higher education?

  • Balance
  • Posted by Jeremy on December 5, 2006 at 9:16am EST
  • Yes, there is a problem with a shortage of nurses...but, consider the other side of the equation - what if unaccredited schools graduated large numbers of unqualified nurses?
    A nursing shortage is a problem, but so is the granting of degrees to the unqualified.

  • Regulatory Agency Capture by Special Interests
  • Posted by Glen S. McGhee , Dir., at Florida Higher Education Project on December 5, 2006 at 9:16am EST
  • This revealing look at the NACIQI re-recognition process demonstrates, I would argue, the extent of “agency capture” of the US DOE by the accrediting guilds. Agency capture refers to the situation where regulatory agencies eventually become advocates for the very industries they are responsible for overseeing, losing their objectivity in a kind of mutual groupthink.
    But this is to be expected. Since the US Bureau of Education was first formed in the 1860s, it has largely functioned as little more than a mouthpiece for higher education.

    First off, you will notice that no accreditor lost their place on the Secretary’s list. This is due, in part, to what has been called the “Atomic Bomb” problem, which refers to the devastating effect accrediting agency derecognition would have on the finances of colleges and their students. Over the years, this politically unacceptable consequence has acted as an effective deterrent, preventing the delisting of any regional accreditor and most others as well. This problem continues to cripple the quality control function of OPE, and it also completely undermines the gatekeeping credibility of NACIQI. Not until the Atomic Bomb problem is solved can any high hopes that the Secretary may have for NACIQI be realized.

    And what were the accrediting guilds complaining about? The Western Association objected to AAEU requirements that “essentially would require it to tell colleges what performance measures they should meet.” This, of course, runs counter to the “process model” of accreditation put in place with the passage of the 1992 amendments to the Higher Education Act (HEA). This has resulted in what amounts to a renewal process conducted by NACIQI that rubber-stamps the departments own AAEU staff recommendations, although it is not unusual for an insider like Pruitt to hand the guilds what they want on a silver platter.
    What is needed, of course, is something entirely different, modeled after the public utility commissions, as recommended by the Puffer Report. That way taxpayer interests, and not just those of the accrediting guilds and their institutions, would be represented.

  • Emperor has no clothes?
  • Posted by Bart on December 5, 2006 at 11:21am EST
  • In the world of U.S. academia -- ~ 20% remedial rates, 24x7 ESPN, heavy drinking 45% of the time, 710-seat classrooms, helicopter parents -- they're arguing about five-year plans?

    What about the basics? Like three hours outside work for every credit? Reading prior to lectures? Academic material that is relevant to global realities? Y'know -- discipline?

  • Discipline?
  • Posted by Randy on December 5, 2006 at 1:51pm EST
  • Doesn't exist in higher education anymore. Colleges and universities just keep asking for more money from the government while raising tuition and fees. If Vedder is right that for every dollar increase in Pell we see a 30-40 cent increase in tuition, it simply reinforces the idea that something is broken in American higher education.

  • Who Accredits Alternative Ed Programs for College Athletes?
  • Posted by Frank G. Splitt , Member at The Dral=ke Group on December 5, 2006 at 3:35pm EST
  • In “Some Prompts for a Congressional Hearing on College Athletics” [1], I said, with reference to NCAA President Myles Brand’s Nov. 13 response to Bill Thomas' letter of Oct. 2, 2006: "It is important to note that the NCAA testimonials do not tell how the NCAA accomplishes its (primary tax-exempt) purpose of maintaining the athlete as an integral part of the student body.”

    To say the least, it would be interesting to have the reaction of accreditors to this lack of ‘evidence’ and to the alternative education programs for athletes wherein the academic credentials and classroom experiences of athletes are so different from those of real college students."
    Can you imagine the impact on alternative education programs for athletes if accreditors required schools to measure what athletes actually have learned? That's exactly what is required of engineering departments in Accreditation Board for Engineering and Technology (ABET) Engineering Criteria 2000.

    It would also be interesting to know the accreditation organization responsible for accrediting the general studies degrees described by Jon Solomon in his Oct, 29, 2006, Birmingham News article, "Athletes make academic end run." Solomon found general studies and 'Jock' majors prevalent in Alabama schools during the newspaper's investigation this fall. No doubt, similar degree tracks have been engineered for athletes in other states.

    Of further interest would be:

    1. A determination of how the National Advisory Committee on Institutional Quality and Integrity (NACIQI) [2, 3], and the Council for Higher Education Accreditation (CHEA) [4], go about recognizing accrediting organizations. For example, recognition by CHEA affirms that the standards and processes of the accrediting organization are consistent with the academic quality, improvement and accountability expectations that CHEA has established. Just how does CHEA do that?

    2. NACIQI’s and CHEA's position re: the use of the Collegiate Learning Assessment and the Graduate Record Exam as outcome measures of student learning.

    3. NACIQI’s and CHEA's views on possible breaches of academic integrity at multiple levels in America's higher education enterprise. As Walter Byers, who served as NCAA Executive Director from 1951 to 1987, said when speaking of a college’s reporting on the necessary progress that has been made on the rehabilitation of at-risk high school graduates: “Believe me, there is a course, a grade, and a degree out there for everyone.”

    School administrators seem to believe that outcomes assessment is none of the government's business -- ignoring the fact that all schools benefit, in one way or another, from government programs. They are quick to appeal to the privacy provisions of FERPA to avoid disclosure of any information that could prove damming or embarrassing, especially in the case of the academic performance of the athletes in their money-making sports programs. An apparently misinformed NCAA President Myles Brand sought refuge in FERPA in his vacous reply to Bill Thomas' question: "Would requiring the public disclosure of the professors, courses, and academic majors of athletes help insure that they receive a quality education?

    Without an independent outcomes assessment of student learning, the government has to take a school’s word on Graduation Rates and Academic Progress Rates for their athletes. NACIQI needs to force accreditors (and, by extension, colleges) to produce, collect and publish more and better information about student outcomes. Why? Because the NCAA will not require their member schools to do it. Disclosure of aggregated (Buckley-compliant) outcome assessments on the athletes in their football and basketball programs would expose the NCAA’s phony student-athlete scheme to the light of day.

    In the future, disclosure could enable the provision of tangible evidence justifying the NCAA’s tax-exempt status. But that won’t happen, unless and until disclosure is mandated by the Congress as part of a quid pro quo [5]and schools maintain the athlete as an integral part of the student body.

    In the meantime, parents, students, and other American taxpayers will continue to help foot the bill for million-dollar-plus salaries for coaches, 'stadium wars,' tax breaks for wealthy boosters, and other artifacts of the big-time college sports arms race.

    Web Links

    1. http://thedrakegroup.org/Splitt_Prompts_for_Congressional_Hearing.pdf

    2. http://www.ed.gov/about/bdscomm/list/naciqi.html

    3. http://insidehighered.com/news/2006/12/05/naciqi

    4. http://www.chea.org/

    5. http://thedrakegroup.org/Splitt_How_About_a_Quid_Pro_Quo.pdf

  • Huh? What?
  • Posted by Bart on December 5, 2006 at 5:10pm EST
  • " .. American taxpayers will continue to help foot the bill for million-dollar-plus salaries for coaches, ’stadium wars,’ tax breaks for wealthy boosters .."

    Yes. The Florida/Ohio State game is destroying college accreditation. Of course.

    For another another view on this odd turn off the road to accreditation --

    http://www.ncaa.org/library/research/athletic_spending/2005/empirical_effects_of_collegiate_athletics_update.pdf

  • NACIQI IS NOT CHEA
  • Posted by Glen S. McGhee , Dir., at FHEAP on December 5, 2006 at 8:15pm EST
  • Frank equates NACIQI, a statutory committee, with CHEA, a private association of accrediting agencies. Only NACIQI has an official role in the re-recognition process the places accreditors on the Secretary's list. CHEA has no real role that I know of. It could disappear tomorrow, nothing would change.
    Also, since the re-recognition procedure is a process-based interpretation of the statute (see 34 CFR 602), so-called "alterative ed" programs are irrelevant. As a result there are no "minimum standards" for faculty and courses that must be met, and that can be verified. You will, no doubt, find diploma mill quality at many individual classes. But, it is the accreditors that define what a "diploma mill" is, right?

  • Frank G Splitt
  • Posted by Craig C , political pundit at http://blogresponder.blogspot.com on December 5, 2006 at 8:20pm EST
  • Get off your anti sports high horse. The football programs in most universities pay their own way in spades. If the school gets a bowl bid, there can be millions in the picture. This pays for a lot of the esoteric stuff that occurs in college.

  • Sports and Money, Division i
  • Posted by R. Gudeman on December 6, 2006 at 9:16pm EST
  • The NCAA has posted a November 13, 2006 letter from Myles Brand, President of the NCAA, to William Thomas, chair of the House Committee on Ways and Means. In it Brand answers various questions relevant to assessing the "tax-exempt purpose of the NCAA." (p. 1)

    (www2.ncaa.org)

    Several relevant quotes:

    "In the 2004-05 academic year, the total operating revenue for the 117 Division I-A football programs was approximately $1.6 billion, an average of $14.1 million per institution." (p. 16)

    "Total annual operating expenditures for 2004-05 by Division I-A football programs were approximately $1 billion, an average of $8.7 million per institution." (p. 17)

    (NOTE: the following refers to all D-I sports) "If profitability were the standard for college sports, only 23 Division I institutions (based on data reported for the
    2004-05 academic year) would conduct athletics programs. Furthermore, if profit were the motive, even those 23 (of more than 1,000 member institutions) would likely only conduct football and men’s basketball programs.
    The data that identify these two dozen institutions with positive net revenues do so withoutaccounting for depreciation. Under generally accepted accounting principles, however, depreciation of athletics facilities should be deducted to determine a true profit. ...if depreciation were included, we estimate it would be fewer than 10 institutions of more than 1,000 member
    colleges and universities." (p. 18)

    R. H. Gudeman