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More Meaningful Accreditation

April 22, 2009

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CHICAGO -- Sylvia Manning has heard all the complaints about accreditation before -- heck, she thought a lot of them herself during her nearly 40 years as a college administrator. Colleges find the process to be a mere obligation because it focuses on minimum standards and too often produces little of value to help the institutions improve. Critics who want more higher education accountability question whether accreditation is rigorous and transparent enough. Potential educational innovators say the process is inflexible and discourages creative approaches.

The critiques flow largely from the fact that higher education accreditation seeks to do two totally different things: ensure a minimum level of quality (with the accreditors in effect playing a compliance role on behalf of the federal government) and encourage individual colleges to improve themselves.

Manning, who nine months ago became president of the country's largest regional accreditor, the Higher Learning Commission of the North Central Association of Colleges and Schools, almost immediately appointed a committee to rethink the commission's approval process with those and other critiques in mind. This week, at the commission's annual meeting here, she unveiled a proposal to overhaul the accrediting agency's process for renewing its approval for already accredited colleges.

Its most distinctive feature is that it would clearly separate "compliance" from "improvement." Colleges would be required to build "portfolios" of data and materials, documenting (through more frequent peer reviews) their compliance with the association's many standards, with much of the information being made public. On a parallel track, or "pathway," colleges would have the flexibility to propose their own projects or themes as the focus of the self-improvement piece of their accreditation review, and would be judged (once the projects were approved by a peer team) by how well they carried out the plan. (Colleges the commission deems to be troubled would have a "pathway" chosen for them, to address their shortcomings.)

The commission's goals in this proposal, which Manning makes clear is nascent and open to significant comment and potential revision by the group's members, are to ensure rigor and transparency in the compliance part of the review process (by potentially increasing the frequency with which colleges' portfolios are reviewed and making results public), reduce the paperwork burden on institutions (by making the portfolio electronic and limiting the written report for the portfolio to 50 pages), and make the process more valuable for colleges by letting them largely define for themselves where they want to improve and what they want to accomplish.

In lifting the veil off the proposal in a presentation to presidents of member colleges at the commission's annual meeting Sunday, Manning began her presentation with her riff on a Beatles song. It has troubled her, Manning said, that so many colleges seem to view accreditation as having little enough value that they wouldn't necessarily seek it if they weren't required to have it for their students to receive federal financial aid. Manning chanted: "Would you still need me, would you still feed me, without Title IV?"

"We want to make accreditation so valuable to institutions that they would do it without Title IV," she said in an interview after the presentation. "The only way we can protect the improvement piece, and make it valuable to institutions to aim high, is if we separate it from the compliance piece."

The Higher Learning Commission is not the first of the country's six regional accrediting groups to go in this direction; the Southern Association of Colleges and Schools' Commission on Colleges, in revamping its process for accrediting colleges in 2002, required each college to develop its own "quality enhancement plan" that is separate from its compliance review, and the Western Association of Schools and Colleges has also moved along these lines.

Officials at the North Central accreditor said they had learned from their peers. But they also said they hoped that the breadth of the commission's proposal would contribute to the sense that regional accreditors are listening and responding to the needs of their member colleges and, where appropriate, critical policy makers.

Serving Two Masters

Accreditation was broadsided by the Education Department of Margaret Spellings, whose Commission on the Future of Higher Education accused higher education's peer review process both of failing to fulfill its federally delegated role of quality assurance with sufficient rigor, and of stifling institutional creativity and innovation with excessive straitjacketing. In her speech Sunday, Manning said that commentators often say that accreditation's dual roles of quality assurance and improvement lead to "creative tension," but that she wasn't at all sure that tension created anything helpful.

Mainly what happens in the current structure, she said, is that the compliance role is so onerous and so dominates the process that, in too many cases, colleges fail to get anything meaningful out of the improvement portion. That, she said, is why separating the two is so essential.

As initially conceptualized, the commission's revised process would have institutions build electronic portfolios made up of (1) an annual institutional data update the accreditor already uses, (2) a collection of "evidence of quality and capacity" drawn from existing sources (other accrediting reports), federal surveys and audits, and a "50-page, evidence-based report that demonstrates fulfillment of the criteria for accreditation," based largely on the information in (1) and (2), commission documents say. A panel of peer reviewers would "rigorously" review the data (without a site visit) at various intervals -- how much more frequently than the current 10-year accreditation review would probably depend on the perceived health of the college -- and make a recommendation on whether to approve the institution for re-accreditation.

And importantly, given criticism from the Spellings Commission and others about the perceived secrecy or at least opaqueness of accreditation, the commission would create a "dashboard" of information from the portfolios that would be widely published.

The "pathways" process would carry on in conjunction with the portfolio review. The Higher Learning Commission had created one alternative to its standard accreditation process, the Academic Quality Improvement Program, a decade ago, and over the years colleges or members have proposed more than a dozen others, Manning said. The goal of the revised process, she said, would be to give institutions deemed to be in solid condition wide berth to use the time and energy the accreditation process requires to best effect for their own purposes (within reason and with the approval of the commission).

A college that was already intending to undertake a strategic planning process might use the accreditation self-study for that purpose; another might decide it wanted to focus on assessment of student achievement, design a project and set goals for what it hopes to accomplish, and have the results reviewed by peers at the end. Another possibility that particularly excites Manning and Lynn Priddy, the commission's vice president for accreditation services, would be to have several institutions collaborate on a joint project, as several colleges have requested. "People have asked us, 'Why couldn't we band together with institutions we would choose, peers or those with shared interests, to do a joint self-study around a shared project or a shared aspiration?' " Manning said.

One major step of peer approval would occur near the beginning -- "we need a way to ascertain that what is done is significant and has scope; we can't deal with institutions saying, 'We propose to study how we're going to re-carpet all the residence halls,' " Manning said -- and then another after the results of the study have been posted, with a visit aimed at documenting the project's achievements and outcomes.

Only a college that gained the recommendation of its peers on both the "pathway" and the portfolio pieces of the process, as commission members envision it, would earn continued recognition. The two parts would be linked in some fashion during the process, but exactly how is one of the many details HLC officials acknowledge they haven't fully worked through, as they begin what is likely to be a three-year process of developing and refining the reaccreditation proposal.

Cheers and Concerns

Reaction to the commission's draft proposal from officials of its member colleges, judged from the responses to Manning's presentation and comments from provosts and professors in the hallways and exhibit hall, was largely positive. Many commenters said they appreciated the idea of increased flexibility, and several said they would welcome the opportunity to use information prepared for other accreditors to fulfill North Central's demands.

As with the prospect of any significant change in the often change-averse world of higher education, though, there were qualms. One speaker wondered how much information would be made public; another asked if the commission's staff would be qualified to judge the potentially immense diversity of the pathways institutions might propose.

And several seemed concerned that the changes might be perceived as deemphasizing the "compliance" aspects of the commission's accreditation process. "The portfolio portion really should be what's tied to continued accreditation," said one member of the audience. "As soon as you tie the pathway portion into that, you make it a very different exercise, as we're going to want to make a good case, to make ourselves look good."

How will the Department of Education respond? another asked. "If we go too far into the pathways approach and leave out too much" of what we do now in terms of quality assurance, he said, the government "may decide to take that area over and require more regulation."

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Comments on More Meaningful Accreditation

  • Quality of Evidence
  • Posted by David Eubanks , Dean of Exotic Plumbing on April 22, 2009 at 7:45am EDT
  • As a newly minted accreditation liaison in 2003 I had full exposure to the range of requirements. The well-defined ones are easiest to deal with. The spectrum extends to educational outcomes, which are not-well defined. I applaud anything that allows the institution more discretion to customize how the fuzzy elements are defined (i.e. locally) and reviewed. I've argued [http://highered.blogspot.com/2009/04/part-four-philosophy.html] that learning outcomes, for example, are more philosophy than science, and that unconstrained review by an accreditation team can lead to an arbitrary outcome--an effect I call Blue Hat Syndrome [http://highered.blogspot.com/2009/02/blue-hat-syndrome.html].

    So if learning outcomes get moved from the "compliance" section to the "improvement" section where they belong, this would be an improvement.

  • Posted by Glen S. McGhee , Dir., at FHEAP on April 22, 2009 at 9:45am EDT
  • No one has shown that, in fact, accreditation ensures minimum standards are met, not across institutions nor across programs, and certainly not at the level of individual classrooms. There is only the complete absence of studies telling us if accreditation works, and if so, how effective it is at achieving its goals.

    Some of this is common sense: how effective or consistent do you expect QA/QC to be when it is conducted once every 10 or more years? THere are no studies on this either.

    The move to separate "compliance" issues could have its origin with the federal government, which has in the past been concerned that it's Sec. 496 HEA standards have been overshadowed or marginalized by those of the accrediting agencies. NCA's NACIQI review is, I believe, a couple years away, so this might be in anticipation of this.

    Historically it is of interest to note that NCA has been the leading regional innovator of accreditation in the past, from the use of the total map when blanks were no longer used, but now is learning from its peers. Perhaps it's ridiculously large size (about 1,000 members) is making it lag behind its peers.

    The structural role that the accreditors fill for their members is far closer to that of an elite guild, such as the AMA, which defends the interests of its members, especially when it comes to maintaining the privileges that have increasingly come from the federal government. The strong reaction against the Spellings Commission corresponds with the kind of push-back that would expected from guilds defending their special privileges.

    But given the fact that review teams from member institutions are used to review other member institutions, using standards mutually agreed to by the members themselves, the present proposals do not begin to address the "moral hazard" problem inherent with this arrangement.

    Lastly, it is also unfair that low status institutions, with fewer resources and questionable legitimacy, should be targeted for increased scrutiny. Those that are struggling are the ones at the bottom of the institutional pecking order, and the guild should be looking out for them more. Making greater demands is not the way to go.

  • "Me-too" Window Dressing?
  • Posted by James Morgan , Associate Professor, CIS on April 22, 2009 at 10:45am EDT
  • Given that historically, marginal institutions have crossed deserts, swum oceans, climbed mountains to be accredted by the NCA rather than any of it's peer organizations, any changes to enhance improvement are to be applauded. OTOH, change simply as window dressing, to camoflage a real lack of rigor, is not to be applauded.

    I can see a future where institutions proud of their programs would leave NCA for accreditation with one of their more rigorous peers, leaving NCA with the leftovers.

  • accreditation by dues paying
  • Posted by Jeffrey , prof on April 22, 2009 at 12:15pm EDT
  • I am at a small college in the Middle States Association. We have just been reviewed.

    I note that Middle States only pulls accreditation from bankrupt institutions.

    Why should anyone take accreditation seriously when a business with no faculty and no library can be declared an accredited university?

  • Is AQIP really the solution?
  • Posted by Julia Williams , Executive Director, IRPA & Professor of English at Rose-Hulman Institute of Technology on April 23, 2009 at 9:15am EDT
  • I am in the throes of revising my institution's AQIP Systems Portfolio. We are beginning on our second round within AQIP. Although I am not composing a PEAQ Self-Study, I still feel like I am writing a document that fits AQIP requirements rather than a document that reflects my institution's efforts at quality improvement. I began the revision with the idea that we could present to AQIP the stories of our institution to create a responsive data dashboard, to build new outreach programs, and so on. Instead, I got a very clear message from AQIP that I should follow the headlines in the template. While I applaud Manning's attempts to improve the accreditation process, I don't think that AQIP is the solution. It may help institutions that need to create a culture of assessment at their campuses, but it poses a serious drag on institutions that have already achieved that culture.

  • accreditation
  • Posted by Charles Jannuzi on April 27, 2009 at 7:15am EDT
  • Accreditation ought to be developed specifically to evaluate specialities and modes of delivery. That means programs are accredited, not institutions. And since so much is being done with modular courses and distance learning over the internet, accreditation ought to be adapted to evaluate these phenomena.