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Can You Say NACIQI?

December 5, 2006

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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