As the Education Department prepares to reconvene a panel contemplating possible changes in federal rules governing accreditation, a group of state higher education officers is questioning the wisdom of the department's aggressive approach to using federal regulation to change the behavior of colleges and accreditors.
The statement from the State Higher Education Executive Officers, which represents the leaders of statewide governing and coordinating boards, is noteworthy in part because the group has been among the higher education associations most supportive of the Secretary of Education's Commission on the Future of Higher Education and the department's efforts to carry out its recommendations.
While many groups of colleges and universities (particularly private ones) have balked at some of the Spellings Commission's findings and proposals and at some of the department's tactics post-commission strategy, the state higher education leaders have generally expressed support for overarching department goals like heightened transparency and accountability and improved systems for reporting student learning data.
In that vein, even the new statement from the SHEEOs, entitled "Roles and Responsibilities in Student Learning and Accreditation," goes out of its way to underscore that state higher education leaders are largely sympathetic to the goals the department is trying to achieve in the federal rule making process: better ensuring that colleges are educating their students, for instance, and making it easier for students to transfer their academic credits from one institution to another. "The material issues raised by the department in this rule making process require responsible action by the states, institutions, the academic disciplines, and accrediting associations," the letter says.
If the state higher education officers largely endorse the department's objectives, though, they take issue with its means for achieving them. "We believe ... that expanding the scope and force of federal regulation will not be an effective response," the statement says. "States, institutions, and accreditors can and should address them using the means already at their disposal."
The letter also encourages the federal government to respect the roles of institutions, the accreditors and state governments (for public institutions). "The federal government should not seek to materially shape or constrain the work of institutions and the states in delivering instruction, setting learning objectives or degree requirements," the SHEEOs write.
"The line we're drawing here is that the federal government can't and shouldn't try to accomplish all of these ends through the accreditation process," Paul E. Lingenfelter, president of the SHEEO group, said in an interview about his group's new statement. "It's asking too much of accreditors, and the blunt instruments of federal regulation are not the right tools for dealing with these issues."
Those words are consistent with the arguments that many college leaders and accrediting officials have made in taking issue with the Education Department's stance during the months-long rule making process. They have asserted that by seeking changes in federal rules that would require editors themselves to set minimum standards for the performance of the colleges they oversee, most notably on how much their students learn, the department would essentially set explicit federal standards for what counts as quality at institutions, representing an unprecedented level of federal intrusion in academic policy making and altering the traditional role of accreditation as one of self-governance aimed at institutional improvement.
But while colleges and accreditors may embrace the SHEEOs' view that the government should not change federal rules to dictate changes in measuring student learning or transfer of credit standards, they are unlikely to welcome the state officers' overall argument that it is time -- as the Education Department argues philosophically -- for colleges and accreditors to set "more explicit minimum standards for the knowledge and skills required for different degrees," and for the academic community, "through accrediting associations," to hold degree granting institutions accountable "for rigorous academic standards resulting in demonstrable student achievement."
"Student learning is taken for granted at too many institutions, including some of the very best ones, because they just have a great deal of confidence in what will naturally happen given the quality of their faculties," said Lingenfelter. "But I think they can do better, and benefit from a little more discipline and rigor."
Transfer of Credit
As is true on the student learning issue, the SHEEO statement favors the goal of the federal rule making process of making it easier for students to transfer of academic credits, but disagrees with the department's plan for achieving it. During an April meeting, the members of the rule making panel deadlocked (because of one negative vote) over a compromise proposal that would have required accreditors to ensure that the colleges and programs they oversee do not discriminate in their transfer policies against academic credits of students from nationally (rather than regionally) accredited institutions.
The SHEEO letter agrees that "a fair assessment of credit for prior learning will not arbitrarily deny consideration of credit based solely on the accreditation status of another institution." But the state officers' statement asserts that the transparency and fairness of implementation of an institution's policies on academic credit transfer "should not, however, be 'bright line' issues for determining [an institution's] eligibility for accredited status," which is a result the government's approach would produce.