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Fundamental Differences

December 20, 2007

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After an unexpectedly contentious opening session of its biannual meeting in Washington Tuesday, the Education Department's advisory committee on accreditation settled down on Day 2. But a few key flashes of debate laid bare divisions among its members about such fundamental questions as the nature of higher education accreditation and the purpose of the panel, known as the National Advisory Committee on Institutional Quality and Integrity. And by suggesting "policy areas" for the committee to discuss at its spring meeting, some panel members virtually ensured that the federal advisory group will remain a battleground over the role and rigor of accreditation.

At the center of the activity on Wednesday, as she was the day before, was Anne D. Neal, one of the newest members of NACIQI (pronounced nuh-SEE-key), which advises the education secretary on accreditation matters and, perhaps most importantly, recommends which accrediting agencies the Education Department should formally recognize. That recognition is important because without it, 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.

In her day job, Neal, as president of the American Council of Trustees and Alumni, has questioned the wisdom of linking accreditation to access to the federal treasury, arguing that regional accreditation, in particular, has done little to ensure the quality of American colleges and their graduates. In some ways that made her an odd selection to join the panel, given that she essentially has advocated blowing up the system in which she was now a central cog. How would that work?

Uncomfortably, it is now safe to say. At the first meeting she attended, last June, Neal, no shrinking violet, asked aggressive yet thoughtful questions about the accrediting agencies that appeared before her. This time around, Neal went on the offensive, especially on Tuesday, when -- at a time when department officials were hoping to dial down the committee's rhetoric to discourage Congress from reining the committee in -- she asked officials from two regional accrediting groups question after question aimed at showing that the agencies are unwilling to require the colleges they monitor to meet minimal standards for student learning.

On Wednesday, with two more regional accreditors appearing before the panel, Neal dove into the same basic line of questioning, asking officials from the Northwest Commission on Colleges and Universities whether the agency's new "alternative," "outcomes-based" model of assessing institutions' quality and success would impose any judgment by the agencies' officials or merely accept "success" as being whatever an individual institution defined it to be. "This would still be the institution outlining its goals and seeing whether it is achieving its goals, right?" Neal asked. "We should not assume that it has reached any level of qualitative objectives set" by the agency. "We should just assume that it has met the level it has set for itself?"

Sandra E. Elman, president of the Northwest commission, answered the question the way accreditors usually do, by noting that every institution is different and that it would be inappropriate to set the same minimum standards for two institutions with different missions and different student bodies. It is essential, she said, that institutions base their own expectations and ways of measuring those results on their own missions.

"But can I assume that my graduate is going to be literate, know how to write, be exposed to math, be taught by senior faculty?" Neal pressed. "What if they decide not to establish those as part of their mission?"

Elman sought to reassure Neal that every college her agency accredits would see producing literate students who know how to write and do math as part of their mission and would hold themselves accountable for doing so, and that the accreditor, through its system of reviewing colleges, would "hold our institutions up to fulfilling their missions."

Neal seemed unpersuaded: "How many schools have you closed down on something other than financial issues?" she asked, implying that regional accreditors were loathe to conclude that institutions are not doing their job at educating students. Elman acknowledged that the two institutions whose accreditation had ended in the last decade had been cited primarily for financial reasons.

But Neal's barrage seemed to incite a defense, not only of the Northwest Commission but of the federal recognition process, from Lawrence J. DeNardis, president emeritus of the University of New Haven and one of the longest-serving members of NACIQI. In recommending that the committee renew the Northwest Commission's recognition for five years, DeNardis, without referring to Neal, said he "sees in Northwest another example of something I have been seeing for several years now: the transformation by yet another regional [agency] of efforts to change and reform in constructive ways the traditional accreditation model."

"For those of us who have labored" in higher education -- seemingly a subtle shot at Neal and some other recent appointees to the accreditation panel who have no campus administrative or faculty experience -- "we know these are not achievable easily or quickly," given how slow higher education is to change, "nor is there one right way," DeNardis said. "These are agencies operating in the independent sector without heavy government prescription, and by peer review. And they are to be honored and encouraged."

Neal took issue with DeNardis's description of the agencies as independent entities, noting the fact that a college must be accredited by a government-recognized agency (or one recognized by the Council on Higher Education Accreditation) to award federal financial aid. "These are gatekeepers of billions of federal dollars," she said. "I would suggest to you that they are in fact agents of the federal government. I would disagree with your characterization."

"I suspected you might," DeNardis said. Then, clearly agitated, the former member of Congress added a poke at Neal: "Having gone through a significant reauthorization of the Higher Education Act, with your husband at my side, I think I do understand what's at stake here. What we are trying to do is to strike a balance." Neal's husband is Rep. Thomas Petri (R-Wisc.), who has proposed legislation in the current Congress that would let colleges opt out of the formal accreditation process by making a slew of additional information about their operations available to the public.

Neal was the lone committee member who voted against renewing the accreditation of the Northwest Commission and the other regional accrediting agency whose status was considered Wednesday, the Accrediting Commission for Community and Junior Colleges of the Western Association of Schools and Colleges. That outcome left the clear impression that Neal is a bit of an outlier in believing that the federal recognition process and the regional accrediting system are abject failures, although other members -- including one or two who had left Washington after Tuesday's discussion -- clearly share some of her views.

But if Neal seemed to make relatively little headway at this week's meeting to change the outcome of the advisory committee's deliberations, she took steps to try to ensure that the underlying nature of the process gets a closer look. Invited by the panel's co-chairwoman, Geri H. Malandra, to nominate "policy topics" that the committee might discuss at its spring meeting, Neal suggested that members contemplate whether the current regional setup of the accreditation system makes sense, or whether colleges should have "greater institutional choice of accreditation selection." (She has suggested in other venues that more competition might compel speedier change by accreditors.)

Patrick M. Callan also suggested adding to the policy list the question of whether it set a new precedent Tuesday in requiring the North Central Association of Schools and Colleges to inform the Education Department if it suspected financial aid fraud by one of its member colleges, without notifying the college itself -- a policy that deeply troubled some college and accrediting officials.

With those two issues, said Malandra, "we've got the beginning of a very good policy agenda" for the next meeting.

In an interview after the meeting, Neal implied that she might seek to broaden the agenda further. "I'm going to keep asking questions, and trying to have a debate," she said. "I hope it's a valuable service."

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Comments on Fundamental Differences

  • Just the tip of the iceberg
  • Posted by Glen S. McGhee , Dir., at Florida Higher Education Accountability Project on December 20, 2007 at 8:50am EST
  • It is important to bear in mind the original stated objectives of Part H, the “Program Integrity” section of the 1992 Amendments to the HEA, pertaining to accrediting agency requirements.

    Surprisingly, these “minimum standards” are not limited to student learning outcomes, but range much further. They, in fact, encompass many institutional elements the should be used for compliance testing and monitoring by accreditors, but are not.

    Interestingly, student learning is one of the last criteria to be listed in the original legislation:

    ” … the standards of accreditation of the agency or association assess the institution’s –

    (1) curricula;

    (2) faculty;

    (3) facilities, equipment, and supplies;

    (4) fiscal and administrative capacity as appropriate to the specified scale of operations;

    (5) student support services;

    (6) recruiting and admissions practices, academic calendars, catalogs, publications, grading and advertising;

    (7) program length and tuition and fees in relation to the subject matters taught and the objectives of the degrees or credentials offered;

    (8) measures of program length in clock hours or credit hours;

    (9) success with respect to student achievement in relation to its mission, including, as appropriate, consideration of course completion, State licensing examination, and job placement rates;

    (10) default rates in the student loan programs under title IV of this Act, based on the most recent data provided by the Secretary;

    (11) record of student complaints received by, or available to, the agency or association; and

    (12) compliance with its program responsibilities under title IV of this Act, including any results of financial or compliance audits, program reviews, and such other information as the Secretary may provide to the agency or association.”

    This recitation, I think, shows just how far Congress has been outmaneuvered by the accrediting guilds, and I am sure the American public will find it hard to believe that there are no “minimum standards” for “measures of program length in clock hours or credit hours” – yet this is the price we pay for “diversity” in higher education.

    Even if we had measures of program length, how would this be applied to distance learning?

    So, student learning is just the tip of the iceberg.

  • Sauce for the Goose AND Gander
  • Posted by Don Langenberg , Chancellor Emeritus at University System of Maryland on December 20, 2007 at 11:25am EST
  • I must say that I find entertaining the continuing debate about the core issue here, who should determine the performance standards of a university. In particular, I find inconsistent, even hypocritical, the argument by many of my academic colleagues that the university itself should be the sole arbiter of its own standards. If that is the sacred principle some believe it to be, then should we not expect universities to put their actions where their mouths are by allowing each student to determine his/her own grades. After all, what's sauce for the goose is sauce for the gander.

  • Never Ventured, Never Gained (Then Lost)
  • Posted by Tom Flint , Director of Accreditation at Kaplan University on December 20, 2007 at 11:25am EST
  • The question of how many institutions have lost accreditation for reasons other than finances is only one side of the coin. As Alan Contreras has frequently observed, there are hundreds of institutions now operating that have never attempted to become accredited, not even by the allegedly less-prestigious avenue of national rather than regional accreditation. If the expectations and standards of the regional accrediting agencies were as loose or non-existent as implied by some, one must ask why there aren't so many more institutions getting regionally accredited, given the benefits of doing so. It is difficult to avoid the conclusion here that some colleges that have the means and patience to attempt to earn regional accreditation never do so because their research shows that they cannot meet the regionals' standards.

  • Fundamental Differences
  • Posted by Greg Troll, MD , Associate Dean, Academic Affairs at touro University on December 20, 2007 at 11:25am EST
  • As someone somewhat on the periphery of higher education, I find this a curious debate. While I am more in sympathy with the accreditation agencies that are trying to recognize and use a more robust process of educational effectiveness, I would have to admit that neither the emperor (if the accreditation agencies and universities are to be seen, somehow, as the establishment), nor the emperor's critic, are that well attired. If there is a tautology in allowing universities to set their own outcomes, standards and goals, there is also a paradox in those who, if I'm not mistaken, demand "accountability" but would mostly employ normative large scale exam methods that, after all, only compare members of a cohort with each other. What such standards of "accountability" seem to ensure is a trend toward the suppression of diversity and a narrowing of educational content and discourse. If we wish to set standards of competence, a laudable goal, we need to rely on establishing criteria. These are applicable for procedural or task based skills, but fall down on competencies (like critical reasoning and communication) that involve more qualitative assessment. There is a place and a need for both, but I think creativity and the higher order competencies seem to flourish much better in the kind of environment outcomes that effectiveness-based accreditation is trying to reinforce. If the concern is a sweetheart deal between regional accreditors and colleges that favor mediocre non-performance with the taxpayers' dollars, and so would only be corrected by rigorous benchmarked national exams, I have to wonder- will those exams deliver? Will they guarantee a literate, competent, creative new generation prepared for the workplace and society of tomorrow? Or will they reinforce the unfortunate trend of a generation of educational bulemics who are conditioned to perform from one exam to another with little ownership or engagement in the content they binging and purging for our approval? This is the reality educators face on a daily basis and are trying to overcome with innovation and measurement. If the critics of this process have more than demagogic aspirations, they will have to consider those points as well their own. Ultimately, there is some validity on both sides, however obscured by polarized rhetoric.

  • Translation of "continuous quality improvement"
  • Posted by Marc Bousquet , author, How the University Works, at Santa Clara University on December 20, 2007 at 11:25am EST
  • Yes, if only "quality improvement" for administration meant what it means for the rest of us--say, a good solid majority of tenure stream faculty with smallish classes and time to do research and review the research of their peers.

    But "quality" is the new "excellence." (If you haven't read the late Bill Readings' University in Ruins, you're missing out.) Its usefulness is that it means whatever management wants it to mean. Don't believe me? Download education-management guru Bill Massy and the Sloan Foundation's "Virtual U" training game. Play it.

    What you'll find is that "continuously improving quality" in the world of Bush, Baldridge, and Spellings--means continuously improving cheapness and continuously improving administrator control, including over curriculum. The administrative literature is quite open about the meaning of the "quality movement." It's an "opportunity for enhanced control."

    Winning the quality game means fewer faculty facilitating less actual learning and more "presentation of information" that will be found on standardized tests. (Just as in NCLB--the k-12 folks have been fighting this battle for a generation already.)

    http://howtheuniversityworks.com

  • Minimum Standards
  • Posted by Mildred Savidge , Director of Outcomes Assessment at Excelsior College on December 20, 2007 at 11:30am EST
  • I believe Dr. Neal, and others who share her views, do a disservice the the accrediting agencies and the colleges by implying that no one has a minimum standard for higher education. Those of us working in the field take the issues of student achievement very seriously, and we do not consider it our job to 'push people through the system' or award someone a credential simply because they attended school long enough, paid enough money, or amassed enough credits without making sure that the graduate has met the standards set for the program. No accredited institution of higher education that I am aware of wants to graduate a student that is illiterate, cannot perform basic math, and cannot engage in problem solving. Any graduate who fits that profile is a blight on the reputation of the institution.

    While we may set our own standards, doing so does not mean that our standards are not high, nor that our standards do not ensure that our graduates are competent individuals who can perform the skills expected of them in their chosen field. Our accrediting bodies insist on definitions of standards and on proof of adequate measures of appropriate student outcomes. While they do not define a minimum standard for us, the visiting professionals who review college materials and visit colleges make sure that colleges meet the professional standards expected in the field. Dr. Neal's insinuation that such is not the case is an insult to the accrediting bodies, the professionals who conduct reviews and site visits, and accredited colleges and universities across the country.

    The need for higher education to be accountable for its outcomes is clear. But the setting of a minimum standard is a very sharp double-edged sword. While setting such a standard may remove one or two institutions from Title IV funding or raise the standard somewhere, it can also lower the standards at hundreds of institutions who have set their standards high above the minimum. Once you set a minimum standard, you can ensure that everyone meets it. The problem is, if that's all it takes, there is no incentive built into the system to make anyone want to achieve more than that. Competition between institutions may help keep standards higher, but I fear that setting such a standard could have a negative impact on higher education, rather than a positive one. I truly hope that the current climate of setting minimum standards never reaches higher education.

  • Part H
  • Posted by College Official on December 20, 2007 at 2:00pm EST
  • Mr. Megee's post notwithstanding have you ever been on the recieving end of an accreditation visit at a college?

    I have, and every single one of the 12 items enumerated by Mr. Magee was examined during the review process.

    As far as "minimum standards", I believe it has always been the intent of those promulgating regulations for the regionals to leave them the flexability to deal with standards as best fit the individual institution.

    If Acme college can move students from point A to point B, it was not the federal governments business whether it was by bus, train or plane (prop or jet).

    I firmly believe in transparency and responsiveness to the students and communities needs. However, "accountability" sounds to me like one of those nifty, double entendre, business speak buzzwords that adds up to if "you don't dance to our strings we won't let you dance". Let's not confuse that with doing what is best for students, colleges or communities.

    As a side note, I have knowledge of an accreditation visit which DENIED the request by a private two year college to become a four year degree granting institution on the grounds that they were unprepared to do so. I believe that the regionals are doing exactly what they are supposed to be doing.

  • Its the lack of transparency
  • Posted by Glen S. McGhee at FHEAP on December 20, 2007 at 2:00pm EST
  • Mildred,
    What minimum standards? Name one. (The only one I know about was violated with a college plagarized their self-study last year.)

    And this discussion shouldn't be limited to objective min stds -- but extends to the lack of transparency and the lack of accountability for the processes used in institutional evaluation and assessment.

  • Posted by mkt on December 21, 2007 at 6:10am EST
  • "What minimum standards? Name one."

    That's precisely the point. It would be a very bad idea for the Federal government to promulgate minimum standards, as Anne Neal desires. For precisely the reason that Mildred Savidge describes: schools which are currently above those standards will have an incentive to REDUCE the quality of their teaching, because they would be able to save costs without jeapordizing their accreditation.

  • Posted by Mildred Savidge , Director of Outcomes Assessment at Excelsior College on December 21, 2007 at 2:00pm EST
  • Glen:
    The "minimum standards" I was referring to do not currently exist. My point was that to establish such a standard, as some people seem to think prudent, would be a disaster for higher education. Look at public education as an example. While the poorest schools may have made some improvement, many of the better schools have actually lost ground. This is what happens when the meaning of accountability gets translated as "make sure every student meets the minimum" and teachers, schools, and districts are compared on the basis of test results. Teachers are pushed to become automatons whose purpose is to get the best test results, instead of creative people who help students learn a broad range of information about their topic, in addition to making sure they have all the basic information they need to go to the next phase of their life or education. Do we really want higher education to go in that direction?

  • What about unqualified faculty?
  • Posted by Glen S. McGhee , Dir., at FHEAP on December 21, 2007 at 7:40pm EST
  • If you are afraid that minimum stds in HE will be too low, simply raise the bar. Just raise the standard -- it sure beats not having any.

    One of the challenges in the South regards qualified faculty (see link). There used to be a SACS standard that instructors be competent to communicate verbally and in writing to their students. That standard has now been eliminated.

    Out-of-field teacher problem in secondary education is being addressed, and you can now find out whether or not your child has a qualified or unqualified teacher, due to the reporting requirements of NCLB.

    To this extent, yes!, HE needs to learn from the increased accountability and transparency. On OOF, see the papers at: http://www.gse.upenn.edu/faculty/ingersoll.html

    The situational dynamics that Richard Ingersol has identified are also operating in postsecondary education. Higher ed policy makers simply haven't faced up to it yet. Maybe next year.