Explaining the Accreditation Debate
As a federal panel negotiating possible new regulations on higher education accreditation ended its (seemingly endless) three-day meeting at a suburban Washington hotel Wednesday, it appeared to have accomplished little. The negotiators reached agreement on just 2 of the 12 issues on their agenda. And the nearly 20 hours of discussion and debate was often mind-numbingly heavy on the minutiae of accreditation, so "in the weeds" that it was not uncommon to see the hardy lobbyists and other interested parties in the cheap seats nod off now and then, when they weren't distractedly tap-tap-tapping on their Blackberrys.
Given the apparent lack of progress and the score of 3 out of 10 on artistic merit, it would be easy to write off what happened during the three days as a waste of time, and to move on to the next article (you and me both).
But appearances aside, what unfolded during the second of three meetings of the Education Department's rule making committee does matter, or at least could matter, to professors, college administrators and anyone with more than a passing interest in higher education.
It matters, at the very least, for what it reveals about the goals of this Education Department, about why accreditation has become the primary battlefield in the aftermath of Education Secretary Margaret Spellings's Commission on the Future of Higher Education, and about the argument over what "quality" means in higher education.
The federal rule making process on accreditation is a central part of the Education Department's strategy for carrying out the recommendations of the Spellings Commission, especially its core conclusion that colleges and universities need to do a much better job measuring and proving that they are successfully educating their students.
Education Department officials, who know that they have a 20-month time span (and almost inarguably a narrower window of meaningful power) in which to make changes before a new administration takes over, decided early on (prodded by Charles Miller, who headed the Spellings panel) that accreditation was their best option for having the most impact, and fast.
That's (1) because the department already directly regulates accrediting agencies (through a process of recognition in which accreditors must prove that they are upholding their standards); (2) because the agencies, through their own processes for approving institutions or programs, monitor most colleges and universities in the country, so getting the accreditors to change their standards and behavior can indirectly influence what happens on most campuses.
And (3) because the department believes it can change its rules for accreditors without seeking Congress's approval, which would add many potential layers of complication and potential opposition, especially now with an opposition party in control. With that in mind, the department announced last fall that it would empanel a committee of negotiators -- accreditors, state officials, public university leaders and its own staff members -- to contemplate possible changes in the federal rules that govern accreditation.
So what kind of change does the department want to see in accreditation and, in turn, in higher education? The Spellings Commission posited the argument that as American higher education's system of self-regulation, accreditation was in large part responsible for academe's overemphasis on reputation and underemphasis on measurable performance and "outcomes" -- especially in terms of student achievement.
Accreditation operates through a "peer review" system in which an individual institution studies and critiques itself (according to the accrediting agency's standards) and the accreditor and its team of reviewers, using their "professional judgment," gauge whether the institution is meeting its own goals and the agency's broadly defined standards. The process is used largely to help institutions improve themselves, but it also serves as the closest thing higher education has to an externally applied stamp of approval. Although it rarely happens, the agencies have the authority to pull an institution's accreditation, and with it the ability of its students to receive federal financial aid.
The commission's report -- and department officials in embracing it -- have suggested that that current system is far too mushy and subjective. Measurements of quality need context, they argue: Successful, perhaps, but compared to what? What is “good enough”?
Colleges, they say, should be collecting and publicly reporting much more quantifiable information about the performance and success of their students -- and doing so in ways that make it possible to compare their outcomes to similar institutions, which accreditors should do using "bright line" standards for minimally acceptable performance. And this information should be accessible and readily comparable not just for accreditors, but for the public (and policy makers -- like, say, the Education Department) as well, "to assure the public [about higher education's quality] and provide consumer protection," as Vickie L. Schray, the Education Department aide who led this week's negotiating session, said Wednesday.
Department officials had made their objectives for accreditation clear for months, but only late last week did the department put forward an aggressive series of proposals to achieve those goals, for consideration at this week's session:
- Requiring accreditors either to set minimal levels of acceptable performance on student learning outcomes for the colleges they oversee or, at least, to declare whether levels an institution set itself were sufficient.
- Forcing accrediting agencies to collect and analyze more regularly than they do now information on key performance indicators.
- Giving Education Department officials and the department committee that recognizes accreditors more authority to review, and to review more frequently, whether accreditors are upholding their standards.
- Demanding that accreditors release much more information about their own standards and expectations to the public, and that they require the institutions and programs they accredit to publish information about their performance on measures of student achievement.
As they had for months, as the department’s plans became clear, college officials and many accreditors balked this week at what they characterized as the agency’s expansive efforts to put a federal imprint, through dictates, on accreditation. For the first time, said Judith S. Eaton, president of the Council for Higher Education Accreditation, “this sets explicit federal standards for what counts as quality at institutions” (at least at institutions that are regionally accredited -- officials of national accrediting agencies, which monitor mostly for-profit colleges, note that the government did this to them more than a decade ago).
While many accrediting officials and college leaders alike expressed alarm at the department’s proposals, their responses also exposed differences between the two groups of officials, probably dictated by the very different situations in which they find themselves.
To the dismay of some college lobbyists and other campus officials, some accreditors on the negotiating panel simultaneously argued against expanded federal intrusion into accreditation and sought to find compromises that might both protect their autonomy and satisfy the department’s goals. (Department officials generally rebuffed their suggestions, which would require colleges to use and report “quantitative and qualitative measures” of student performance and set their own “expected levels of performance,” then have accrediting agencies ensure that the colleges “demonstrate acceptable performance.”) College and university officials grumbled that the accreditors were throwing them under the bus.
Accreditors, though, are most directly in the firing line and face the most direct scrutiny from the government, which several of them have felt intensely in recent hearings before the National Advisory Committee on Institutional Quality and Integrity, the Education Department panel that recommends to the education secretary whether the agencies deserve the department’s stamp of approval. In recent years, and especially at its Spellings Commission-influenced December meeting, the panel is widely perceived as having begun to alter the standards it used to assess accrediting agencies, to hold them more accountable for measuring student learning (before, of course, the department has formally changed the standards it is seeking the change through this week’s rule making process).
Steven D. Crow, executive director of the North Central Association’s Higher Learning Commission, was in the unenviable position this week of being the main regional accreditor on the negotiating committee, and as a result, he was expected by many in higher education to lead the fight (with Eaton) against the department’s proposals. Fight he did, but he also put forward the alternative that college officials so disliked.
Going forward, he said he expected that most accreditors “will explore the power of benchmarking [one college’s performance against other institutions] as a tool of self-improvement,” and also as a method of quality control. They will be willing to do that, Crow said, “in part because it’s the price that’s being exacted” by the Education Department in carrying out the Spellings Commission’s report. “But it’s also in part because the question of when do you know ‘what’s good enough?’ is a question we in higher education have found difficult to answer – and yet it seems like a reasonable question,” he said.
Higher education associations and leaders of private and elite public higher education, meanwhile, who were significantly underrepresented on the negotiating committee, are not willing to make such a concession. The accreditors might be because “they seem to feel a greater sense of inevitability about [the department’s imposition of quantitative measures of student learning on all institutions] than I believe is the reality,” said Susan K. Hatton, a senior consultant to the National Association of Independent Colleges and Universities. But most college officials, she said, “do not regard the federal government coming in with a vision that you need cross-cutting comparisons and bright-line, fixed, rigid standards for measuring all colleges” as an inevitability.
Critics of the department's approach acknowledge that it sounds reasonable to expect an accrediting agency to say that every college should graduate some proportion of its students within four or six years, that graduates of colleges that train teachers should have passage rates of X or Y percent on state licensing exams, or that colleges that train IT technicians should be able to place some percent of graduates in jobs.
But however reasonable that sounds, they say, it falls apart when you get specific. Elite private colleges should probably graduate 95 percent of their students, but a rural, historically black college reaching out to students from poor performing high schools is going to have a lower rate. Set a rate around the expectations of the first institution and you deny accreditation to the second; set a rate around the second and you let the first one off easy. Subtlety might not appeal to Margaret Spellings, these critics say, but American higher education is so diverse that the kinds of rules she wants don't work.
They also worry that the most easily quantifiable potential measures -- job placement rates and others tied to the mission of higher education as a producer of workers -- capture only a small part of what colleges and universities do. How to measure the essence of the other important things students learn when colleges are successful -- a sense of citizenship, global understanding, ethics?
Added Matt Owens, director of federal relations for the Association of American Universities: “Do we really want our college students being taught to a one-size-fits-all test? That is the direction the department's proposals take us. Let's talk about how we can help institutions improve and ensure that they are accountable for achieving their missions. These recommendations are about making institutions the same. That is just not acceptable.”
Department officials said during this week’s session that they would return with new regulatory language at the third of the negotiating committee’s three rule making sessions (April 24-26), with the goal of having new federal rules approved by November to take effect in July 2008 -- just a few months before the election that will formally end the Bush presidency and the current Education Department’s time in office.
What happens between now and then is likely to depend very little, if at all, on what college leaders or accreditors say; department officials have duly noted their objections for months now and pursued their current course undeterred.
Perhaps the only potential impediment to the department’s fairly significant transformation of accreditation and, in turn, how colleges are held accountable by accrediting agencies for measuring and reporting student learning lies a few blocks away from the Education Department’s Washington office -- on Capitol Hill.
Members of Congress have signaled that they are watching the department’s moves on accreditation and the Spellings Commission’s agenda closely, and warned department leaders not to overstep their bounds. There may be no more important consumers of the department’s ultimate language on accreditation rules than the men and women who work in the offices of Sens. Edward M. Kennedy (D-Mass) and Michael B. Enzi (R-Wyo.) and Reps. George Miller (D-Calif.) and Howard P. (Buck) McKeon (R-Calif.), who lead their parties on the Senate and House education committees.
Both panels have vowed to draft legislation to renew the Higher Education Act this calendar year, and they could do much to support -- or scuttle -- what the department is trying to do.