No Minimum standards in higher education

If Judy Eaton believes that the proposed CFR revisions would “set explicit federal standards for what counts as quality at institutions,” then she profoundly misunderstands the legislative intent of the Higher Education Act amendments of 1992 (HEA Part H, Program Integrity).

HEA legislation specifically mandates the Secretary to require accreditors to have “minimum standards” for the institutions that they accredit.

The areas for which accrediting standards are required by the HEA are: student achievement, curricula, faculty qualifications, facilities, fiscal capacity, student support services, recruiting/admissions practices, measures of program length, student complaints, Title IV student loans. See 34 CFR 602.16(a)(1).

Rather, the question (for the Regionals) revolves around what the minimum standard is for having a “minimum standard” in these mandated areas, and therefore has nothing to do with the Secretary setting standards, as Eaton seems to think.Since Sec Riley’s adoption of standardless-standards, the accrediting guilds have gotten a free ride. If an accreditor said that they had a standard in place, then the Department did not and could not question it any further, even if the accreditor had no actual standard!

This is, of course, an untenable situation for any public interest regulator to find itself in. Consequently, there was virtually no regulation of the HE guilds.

But I think the fact that there is now this debate about the most important of the HEA minimum standards (student achievement) adds to the growing realization that the accreditors (whom I style as accrediting guilds) are self-regulated and monopolistic, and because of this, students and the public cannot take for granted that their institutions meet minimum standards in any of these regulated areas. This is why the situation must change.

Glen S. McGhee, Dir., at Florida Higher Education Accountability Project, at 9:10 am EDT on March 28, 2007

“they will develop some uniform value-added outcome tests”

This sounds simple, but is near impossible to accomplish with any sense of being meaningful. Would students majoring in English, mechanical enineering, and teacher education all take the same test? What would the test measure? What subjects? Who is going to pay for it (large-scale testing is extremely expensive)? How would we know that institutions were responsible for test scores, and not prior learning the students came to the institution with? Will there be any test consequences to the college student? If not, why would the student take the test seriously. This lack of consequences is the same problem we already witness with much of the statewide testing that occurs as a results of NCLB.

Yes, there needs to be acountability in higher education, but lets make sure we clearly understand the intended and *unintended* consequences of any decisions made.

Jim, at 9:50 am EDT on March 28, 2007

Bright line

I think it is eminently reasonable for the Department to push accreditors to require institutions to have some standardized measure(s) of the general intellectual skills of college graduates that would enable comparisons of performance across campuses that serve students with the same entering characteristics. Some institutions do better than others at educating similar students, and there is no other way to learn how good a job they’re doing or how to do it better.

But it is way too soon to ask accreditors to establish a “bright line” below which student performance should not fall. We simply don’t know enough about how students in the aggregate DO perform to say how well they SHOULD perform. And by pushing this point, the Department is damaging the credibility it established at the recent, very productive summit meeting, where its representatives vowed to make this a collaborative process.

Margaret (Peg) Miller, at 10:06 am EDT on March 28, 2007

What does this lead to?

Educators aren’t opposed to standards or the measurement of learning outcomes, but with these overtones coming from the same Administration that has forced No Child Left Behind on the country, and has brought failed state programs to the national Federal level, I’m nervous about the cards the Administration still has up their sleeves. After years of Republican opposition to the very existence of a Department of Education, this White House is trying to use it as a Ministry of Education that micromanages and brings Federal intrusion into a system primarily funded at the local, state and private levels.

DS, at 12:26 pm EDT on March 28, 2007

A few things to think about: There is an underlying assumption among some that colleges are not interested in self-evaluation or improvement, but this is simply not the case with many. One down side to viewing the ‘92 legislation as requiring accreditors to have standards with cut-off points, e.g., a pass/fail point, is that your may turn the discussion into one about compliance rather than educational quality. If a college thinks that what is must do is be above a certain mark, then they will do that, but it does not encourage them to go beyond that, particularly large institutions. Standard can also mean an area of inquiry, rather than simply a pass/fail line. We need to keep in ming the tremendous diversity in missions among colleges in the US. Another underlying assumption is that colleges are producing parts for a workforce. While it is obvious that people need to have jobs to sustain themselves, this has not been the approach taken by liberal arts colleges, which have very different goals in mind, literally creating a mind that and think in a variety of way. This approach has historically produced a huge number of the greatest minds, politicians and successful business persons in our history. Assessment at these institutions is not easily done through simple quantitative measurements. It takes a good deal of “judgment” of peers to understand the various dimensions of success at a liberal arts college. This really is an attempt to federalize a portion of higher education. It must be remembered that if these new criteria are adopted it will put the USDOED staff, e.g., life long technocrats and the politically driven and appointed NACIQI panel in the drivers seat. As they will be the ones deciding what is in fact good enough, rather than the colleges or peers. This has the potential to affect missions, the curriculum (less diversity of views, or dependent upon who is running the USDOED) and college access — graduation rates, for example, could cause a college to stop admitting students that their mission wants them to embrace, because a certain number could cause their accreditation to be withdrawn. It is already written into the regs that standards on faculty and curriculum are fair game for accreditors to judge a college upon. With the increased oversight and new rules, how will theses be interpreted by future appointees? or by the staff, which has virtually no knowledge of any particulars. The general approach is to treat HE as a merely a consumer protection issue. But colleges have traditionally had much broader goals than just workforce preparedness. Further, no one is claiming that the best liberal arts or national universities are not producing quality students, it is really the tiers below that. But will this discussion and new regs address the educational quality of an institution? It is not at all clear at this point. There is not discussion about what graduates should know with regard to content or “skills.” But any type of assessment tool is inherently limited to those aspects of the college experience. To know what the “value” added to a student is a much more complicated endeavor and this push by the Secretary will not likely get to that unless accreditors adopt educational criteria, though even that would now have to be approved by the USDOED and the NACIQI. Intellectual diversity could greatly suffer and students that might have gone on to a liberal arts college or a university and blossomed, even though the “data” on them might be poor, will be funneled into vocational programs and colleges.

Jeff A. Martineau, Director at AALE, at 2:06 pm EDT on March 28, 2007

Dept. of Education — Do we want one or not?

DS comments: After years of Republican opposition to the very existence of a Department of Education, this White House is trying to use it as a Ministry of Education that micromanages and brings Federal intrusion into a system primarily funded at the local, state and private levels.

Federal spending accounts for about 1/3 of higher education funding, and as a taxpayer I would expect some care be exercised in how that money is spent. The threat hanging over institutions from the Dept. of Education is loss of Title IV funding eligibility. If a university doesn’t want to be held accountable, they can always refuse to accept federal student aid funds. But few of us would choose to do so.

Instead of protesting that the Dept. of Education has no standing to start demanding proof of achievement to continue eligibility, we would be better served focusing on where the minimum line should be drawn and how to effectively measure it. As long as the measure is on learning achievement on campus, rather than simply on test achievement of graduates, then a constructive standard is certainly possible to create. Not easy, but possible.

Bob Duniway, Dir. of Institutional Research at Seattle University, at 2:56 pm EDT on March 28, 2007

Open Access vs. Success Rates

If we restricted admissions to valedictorians with at least 1350 on the SATs we could easily achieve the near 100% success rates that schools like Harvard and Smith have.

That is not our mission. When we accept people who either have a high school diploma or have turned 18, and who often are working two or three jobs, then the percent that complete an associate’s degree in two years is going to be small, and a poor measure of our contribution to society.

This new “standards” push is simply the government looking to cut costs by blaming the colleges for the level of preparation of our students.

Robert Leopard

Robert Leopard, Monroe Community College, at 4:50 pm EDT on March 28, 2007