Accreditation

Counterpoint: What About the Students?

Constantine Curris’s Inside Higher Ed essay about transfer of credit this week confirms in print what many of us in the national accreditation sector already know: that many institutions base their decisions on credit transfers arbitrarily on the accreditation status of the “sending” college, with complete disregard for the students’ capabilities or the course equivalency of the credits the student seeks to transfer.

What is particularly alarming about the article’s portrayal of the transfer of credit issue is its reliance on history, its almost exclusive emphasis on the burdens imposed on the registrars, and, most importantly, the article’s absolute disregard of the effect that current arbitrary transfer of credit decisions have on the millions of students who attempt to change institutions in order to complete or advance their educations. Should not this national debate focus first on the students and the national education policy goals of helping them complete their educations in the most timely and cost efficient manner, while also ensuring the quality of their educations? If so, then resolving the transfer crisis by prohibiting the arbitrary denial based solely on accreditation makes eminent sense.

While Curris acknowledges the increase in student mobility and in enrollments generally, he seems content to justify current transfer policies on the historical basis for such determinations and on a time in particular when accreditation by “region” served a specific purpose. However, the increasing number of “contemporary” students enrolled -- students who are older, sometimes employed, part-time, and mobile -- is undeniable, and federal education policy and institutions must adapt to and accommodate these students.

Indeed, this fact should not be viewed as a burden, but rather as a responsibility and benefit to this country’s citizens, their educational aspirations and achievements, and to the U.S. economy’s increasing need for continuous educational upgrades. Curris’s article, however, confirms the entrenched and fundamental unwillingness of many institutions to voluntarily adapt their policies and practices on transfer of credit.

Here are the facts: Denial of credits results in the denial of access, as well as in increased education costs when students are forced to pay twice for the same course. These obstacles to completing or improving academic credentials come at a cost not only to those individuals, but also to the taxpayers who often foot the bill for the repeated coursework, and to our economy in the form of the affected students’ delayed entry to our nation’s workforce.

Indeed, in a 2005 report prepared by the Government Accountability Office on the transfer of credit issue confirms the national agencies’ own experiences. The GAO found that “84 percent of postsecondary institutions had policies to consider the accreditation of the sending institution when assessing transfer credits.” An official at the Department of Education recently indicated that the single largest number of complaints the Office of Postsecondary Education receives are from students wondering why their credits were denied by receiving institutions.

Accreditation and the accrediting agencies should play an important role in facilitating, not denying, credit approvals as Curris suggests. All recognized accrediting agencies -- whether regional, national or specialized -- are subject to the same criteria and approval processes by the Department of Education. The Council on Higher Education Accreditation (CHEA) and other organizations, like the American Association of Collegiate Registrars and Admissions Officers, have jointly and formally adopted a policy confirming that institutions should evaluate credits for transfer without discriminating based on the sending institution’s accreditation.

And, yet, the credits of students who attend nationally accredited schools continue to be denied on the basis of accreditation. Curris says that this denial is not necessarily about discrimination against proprietary schools. He is right -- this debate is not about the proprietary institutions. It is about the students who choose to attend institutions that have met Title IV eligibility and are accredited by agencies that meet the same criteria for U.S. Department of Education approval as the regional accrediting agencies. Curris seems skeptical of the types of schools the national accrediting agencies accredit -- in fact, many of these schools and their students look very much like the two year programs and students found at regionally accredited community colleges.

Instead of making arbitrary transfer decisions based on accreditation, the focus by institutions in these decisions should instead be on the students and the quality of credits they received. Even if institutional resources are tight, receiving institutions should be examining the course equivalency of the sending institution and student competency; students deserve this level of basic attention to objective measures. There is no legislation or regulatory solution proposed that would deny or affect the very important autonomy of an institution to make an independent judgment on the merits of the transfer request. The legislation that had been proposed merely asked institutions to give a student’s record a fair review.

This is a national problem requiring a national solution. Articulation, policy statements and other private sector arrangements, while helpful, do little to ensure that students nationwide will be fairly and consistently treated when considering a transfer. To support legislation in this in this area would provide affirmation to students, institutions, and accreditors that Congress intends to support student achievement, mobility, and access to an affordable education, as a matter of national education policy.

That Curris, as the head of one of the country’s major associations of public colleges, would argue otherwise is dismaying.

Author/s: 
Elise Scanlon and Roger Williams
Author's email: 
info@insidehighered.com

Elise Scanlon is executive director of the Accrediting Commission of Career Schools & Colleges of Technology, and Roger Williams is executive director of the Accrediting Council for Continuing Education & Training.

Untangling Quality Assurance in Higher Education

On September 24, a perceptive federal judge in California pointed out the obvious and cleared a lot of thick overgrowth from the landscape of postsecondary oversight in the United States. In brief, Judge Margaret Morrow concluded that a state cannot treat regional accreditors differently from each other in order to favor colleges based in the state over those based elsewhere.

Judge Morrow’s preliminary opinion in Daghlian v. DeVry, with which I agree for the most part, concludes that differences among regional accreditors are insufficient to sustain California’s contention that the state can in effect exempt locally based colleges from state oversight because they are accredited by the Western Association of Schools and Colleges (WASC), while requiring colleges based elsewhere to get state approval to operate because they are accredited by a different regional accreditor.

This decision may cut part of the knot that has plagued proposed revisions of California postsecondary approval laws. WASC has been actively opposing some of the changes, even though they don’t affect WASC schools, apparently on a camel’s nose theory: any hint of state interference in collegiate self-governance must be sprayed with hot and cold running lobbyists. Ultimately, WASC is lobbying the tide not to come in.

The DeVry case may therefore serve to drag into the open one of the less-well-understood aspects of education law and policy. One of the commonest fallacies in higher education, and one which is amazingly ill-understood even by professional educators, is that colleges get to offer degrees because their accreditor allows them to. Not so. Colleges, including private ones, get to offer degrees because state governments give them the authority to do so.

Let me say that again for maximum clarity: Private colleges in the United States have no inherent right to issue degrees. That right comes to them through a grant of authority from a state government. With the exception of Congress and Indian tribes, I know of no other source for degree authority in the United States. The authority may come as a charter, a constitutional provision or a statute, but it must have an origin in state law. No accreditor can give that authority and no accreditor can take it away. Nor can the federal government do either, except for its own colleges.

The federal government recognizes this area of state supremacy in its regulations governing accreditors. A federally recognized accreditor is prohibited by federal rules from accrediting a college unless that college has appropriate state authority to issue degrees prior to accreditation. That is why one current California proposal to allow schools accredited by the Western Association to operate without a separate grant of state authority cannot work. This chicken chasing its own egg is a turkey. Judge Morrow’s preliminary decision serves to add top-quality stuffing to this defunct bureaucratic poultry.

California (and every other state) must formally give authority to issue degrees to every college based in the state that wants to grant degrees. Instead, it seems simpler for states to just punt the function of postsecondary approval to the local accreditor. Sorry, it can’t be done that way. Likewise, accreditors have no ability to grant degree authority to a foreign school -- only the government of the nation, or its properly designated authority, can do that.

In theory, every state diligently determines which colleges can issue degrees and, ideally, exercises at least some baseline quality control. In practice, this does not always happen, and in California today, it can’t happen, for there is no state agency in existence to issue the approval. The consequences are significant.

Right now as I write, it is impossible to start a new degree-granting institution in California, because any such institution requires state approval. It requires state approval not only to get accredited, but to have any legal authority to issue degrees. And it can’t get this approval. On these grounds alone, California is flirting with a Commerce Clause problem: The legislature has de facto protected all existing California colleges from competition. Florida tried this a few years ago and was squashed in federal court.

Also, any California institution that comes up for renewal by its current accreditor has to show that it has current state approval to issue degrees. Some won’t be able to. Even if all parties accepted the convenient but illegal fiction that WASC can stand in for the state, Judge Morrow has killed any attempt by the state to claim that WASC accreditation works as a stopgap but that accreditation by the North Central Association’s Higher Learning Commission doesn’t.

With luck, one side effect of the DeVry case will be to hose out once and for all some of the fictions that states, colleges and accreditors have erected around the curiously opaque process of college and program approval. When the false fronts have collapsed -- the collegial slurry panned for its limited nuggets and the agencies of various states (e.g., loopholed Alabama, grandfathered New Mexico, AWOL Hawaii and disinterested Idaho) subjected to the need to perform -- we can hope for useful changes.

What should emerge from this helpful legal reality check on the role of states and accreditors? First, absolute clarity that each state is legally responsible for the private colleges based there. That includes program quality. No more hibernating under the accreditorial dust storm. Accreditors are owned by their dues-paying member schools and should never be expected to serve as enforcement arms of state or federal governments. They are arms of the colleges, dedicated to advancing the interests of their member schools. There is nothing wrong with that, but let’s give it the right name: a club of schools with similar interests and approaches, not an enforcement body (certainly not of federal standards), and not remotely capable of handling student complaints.

States that have perched primly in the back pews, hands clasped and eyes downcast while the U.S. Department of Education brutalizes accreditors into doing oversight work for which they are unsuited, unfunded and unprepared, need to stop shirking their duties and hoping that the feds will do it for them. Who on earth, looking with unclouded eyes at the federal government, would entrust it with quality control?

I have argued for some time that the Department of Education should make its own decisions about financial aid eligibility based on its own standards, properly enforced by itself. That is a different and appropriate role: You want our money? Here are our rules.

Right now, the Department of Education is incompetent, in the technical sense, to perform college oversight. They can deal, sort of, with the most obvious cases, but they have no real structure in place for meaningful Title IV eligibility oversight. Regional accreditors need not fear losing their recognition, since the feds have no replacement process in place. Therefore regional accreditors and the larger national and specialized accreditors can ignore most federal noises.

Finally, the federal government has no business assuming a duty that constitutionally belongs to the states. The federal government would love to move in on territory that has belonged to the states for over 200 years. It is trying to persuade accreditors to do the dirty work. The states should not let this happen. If Judge Morrow’s case is nominally about the comparability of accreditors, its real impact may be on states that have taken their responsibilities lightly for too long.

Author/s: 
Alan Contreras
Author's email: 
newsroom@insidehighered.com

Alan Contreras works for the State of Oregon; his views do not necessarily reflect those of the state. His blog is The Oregon Review.

Content Control -- This Time From Friends

I’m glad I missed the era that demanded Latin and sometimes Greek of those who sought a proper education. I did have to take music, one of whose requirements was the ability to identify the sounds of different musical instruments.

I flailed about helplessly in what sounded like a cacophony of sounds and I remember with particular pain my struggle to single out the Contrabassoon. My teacher brooked no excuses and warned that those who failed to acquire taste and culture inevitably ended up in the cesspools of iniquity. He was evidently right: I learned to identify the sound and I did not descend to the aforementioned cesspools, although I have sometimes wondered what they're like.

My efforts weren't in vain. I learned important lessons about perseverance and emerged from this high school class with an enhanced sense of confidence.

I now know that these qualities could have been honed in a much friendlier but equally demanding way. The same is true with all the many traits we identify with a postsecondary education. Critical thinking, discernment, appreciation of culture … all are characteristics that can be acquired in a variety of ways.

More precisely, there are no orthodoxies in higher education. The qualities of mind that the 1828 Yale Report describes as the “habits of thinking,” which “are to be formed by long continued and close application,” can emerge using content very different from what we consider to be the norm.

When Richard Brodhead (now the president of Duke University) was dean of Yale College in 2004, he put it this way in a commencement address: “By a conservative estimate, the things members of the class of 2004 collectively learned in Yale courses that you have already forgotten is probably equal to the sum of human knowledge gained since the early Renaissance.” He added: “Such inevitable forgetting is not a scandal in education, because the original act of learning taught something more deeply valuable and left a deeper trace: trained deep habits of mind that survived the specific content that was originally attached to them and can then be put to a different use”.

Actually, even content that is retained is increasingly irrelevant in a world where nothing sits still, least of all knowledge. This does not negate the effectiveness of the liberal arts; to the contrary, the liberal arts have proven their worth in creating the transformation of self which is for many, the ultimate goal of higher education. But the liberal arts are not necessarily alone.

Every school has a faculty that follows and fulfills a tradition of centuries of successful teaching and scholarship; this faculty should have the final say in determining the content of the school's offerings. Consistent, of course, with the requirements of each discipline and the standards of quality of the accreditor.

This should leave us with a sense of humility. We may know what we want to do in our own school, but we certainly cannot tell others what to do in theirs. Even if we agree we must provide the same kind of intensity, rigor, and intellectual demand, we cannot require the same educational experiences and the same content.

It's all the more surprising, then, that the American Association of Colleges and Universities (AACU) and the Council on Higher Education Accreditation (CHEA) should seek to specify content in their recently released “New Leadership for Student Learning and Accountability."

The actual words, on first glance, seem innocuous. While recognizing that educational goals vary, AACU and CHEA decided that these goals should include “the study of science, social science, the humanities, and the arts."

The flaws appear at once. Selecting the above content areas means ignoring mathematics, behavioral science, computer and information literacy, world religions, the environment, medicine and law, each of which could play a major role in enriching graduates’ lives.

The selection of content also ignores the fact that a package of 120 credits, which must also include the courses needed for the major, provides for a largely superficial understanding in each specified area of general education.

Has anyone looked at the courses that pass for an exposure to science in a general education sense? One prestigious publisher described a text for non-science majors as offering “an alternative route to science literacy for those with an interest in photography art and music." The table of contents is imaginative and well structured. But is the outcome “science literacy"? Seriously now! It is, for most, a dead end. Are we perhaps better off preparing students to aspire to read, to explore, to gather for the rest of their lives? I don't know, and suggest that AACU and CHEA may not know either.

It would seem that the education community should reject this attempt at specifying content with the same respectful vigor as was the case in rejecting the Department of Education's attempt to specify measures of learning outcomes. Content control is unwise, no matter who is proposing it.

In the same sense, we must learn to ignore content mandates by handwringers. There are many good reasons to study foreign languages, but globalism isn't one of them. Unless we are prepared to require college graduates to master six or seven tongues, including two dialects of Chinese.

Nor should global competition serve as an engine of content change. The world is competitive, because American business leaders shipped abroad the technology and industries that our graduates created. There is something very special and unique about American higher education and even after a decade of other countries’ producing more scientists and engineers then we, it is they who copy our ideas and discoveries, not the other way around.

Finally, we should stop reading our own press releases. A recent report breathlessly warned that people who lack a basic understanding of science cannot function in modern society. I am happy to relate that people without any idea of science live happy, fulfilling and satisfied lives. Impressive and numerous are the fortunes made by people who never learned to appreciate Maxwell’s Equations or the Krebs Cycle.

We must recognize and celebrate the immense diversity that defines American higher education. Our colleges are part of a fermenting vat of ideas, and the content, strategy, outcomes, and resource wars that take place in any Faculty Senate would do the Middle East proud. But the key here is that the probing and experimentation, the trial, monitoring and error all take place within the walls of independent institutions.

We have the best system of higher education and a smoothly functioning system of accreditation capable of keeping it that way. Our graduates -- our products -- prove this unequivocally. And until someone proposes a change that is established through scientific standards as safe and effective, we must stand fast in the face of efforts to dictate change, particularly insofar as content is involved.

Author/s: 
Bernard Fryshman
Author's email: 
newsroom@insidehighered.com

Bernard Fryshman is an accreditor and a professor of physics.

Sparrows in the Lion's Den: Welcome to NACIQI

(Editor’s note: When Congress renewed the Higher Education Act last summer, lawmakers scuttled the National Advisory Committee on Institutional Quality and Integrity. which advises the U.S. secretary of education on accreditation issues. The panel is soon to be reconstituted with new members appointed by the secretary and by leaders in the House and Senate. The column below offers advice to those making the selections, and to their eventual selections.)

Accreditation long preceded the establishment of the U.S. Department of Education, and it is only within the past 50 years that a nexus was established between accreditation and the ability of a postsecondary institution to award federal student financial aid. Congress, in helping needy students attend college, needed to determine which schools are of sufficient quality to participate in programs under Title IV of the Higher Education Act.

Since we do not have a Ministry of Education, this determination required that the Department of Education frequently look over the shoulder of accrediting agencies to read their lists of quality institutions. Accrediting agencies receive no federal support and therefore are, in a very real sense, simply doing the department a favor in sharing these privately determined and privately supported lists.

There is another side to the story, of course. Accrediting agencies are supported by the schools and colleges they accredit, and are anxious to have the department consult their lists, keeping their accredited institutions eligible to participate.

One further element. Since anyone can create an accrediting agency, there must be standards whereby an accrediting agency is determined to be a “reliable authority” -- i.e., accrediting agencies must be recognized by the Secretary of Education. This has spawned a series of regulations surrounding accreditation; every recognized agency must meet a number of requirements, submit appropriate reports, and petition for renewal of recognition every five years.

The Department of Education has developed a great deal of expertise in executing this process, staffed by policy analysts who examine petitions, participate in site visits, draw conclusions, and prepare a report.

All of this plays itself out before the National Advisory Committee on Institutional Quality and Integrity, known as NACIQI. Although this is nominally an advisory committee, the Secretary of Education has usually followed the recommendations of this body, so the individuals sitting on NACIQI have a great deal of influence on the process, and therefore, on all of American higher education.

Suffice it to say that the precarious balance between a government needing to consult the lists of recognized accrediting agencies, and the desire of accrediting agencies to be so recognized, can be greatly nuanced by the nature, knowledge and personal outlooks of the members of NACIQI.

Against this background one must admire the businessmen, legislators, lawyers and financial aid officers who will serve on NACIQI, often armed with little more than their own personal exposure to college, as background to the task of recognizing accrediting agencies.

If past experience is prelude, these will be intelligent, involved, alert and sensitive people. By the time their three year term of office is over, many, perhaps most, will have begun to understand the complexities of accreditation. They will have sensed the nuances of difference between agencies and between fields, understood the nature of peer review, and appreciated the manner in which accreditation enhances quality and leads to change -- and sometimes to improvement.

They will also have begun to appreciate the conditions leading to successful student outcomes and the role of faculty, students and facilities (inputs!) in a college’s successfully completing its mission.

Until these revelations happen, members will know little more than what they were told in Department of Education training sessions. They will know to watch for conflicts of interest, they will be introduced to the government lawyer who will be present to help them navigate the regulations, and they will hear about the conduct and impact of their sessions.

But they won’t get to meet accreditors first hand, and will not have an opportunity to participate in an actual, on site accreditation visit. They will possibly be addressed by people who will cast doubt on peer review, and who claim that expert judgment is not sufficient to establish the quality of programs and institutions. Numbers, they will be told, are needed instead. No matter how irrelevant, incomplete, inconsequential, or purposeless the numbers happen to be.

NACIQI members, at least in the early years, may not be in a position to challenge those assumptions, with questions like: Why were these particular measurements chosen? What have such numbers shown in the past? What improvements to teaching, learning, and policy resulted from their use? Where is evidence of the validity, reliability, and relevance of these measurements?

They probably will not have participated in conversations that questioned the cost/benefit of all this measurement. Nor will they realize that ”accountability” has not been defined, operationally or otherwise, and that the theories that govern public education policy, have rarely, if ever, been subjected to experimentation and test to scientific standards.

Polite, attentive NACIQI members will hear presentations from persuasive speakers who work at the peripheries of higher education, but not in it. They will not hear from the people who teach philosophy and English, art and accounting and engineering to ever increasing numbers of indifferently prepared students.

The Department of Education staff is not at fault: It’s simply that the accreditation agenda has been taken over by those who bring a regulatory mindset to the process. Hence, NACIQI rarely hears words such as “scholarly,” ”deep study,” ”well read,” and “erudite.” They do hear about measures, templates, benchmarks and graduation rates.

As in the past, NACIQI stands to be diverted, unless new members are prepared to defend the academy, to preserve accreditation, and, from the very outset, to challenge, to question, and to examine.

Transparency, in certain frameworks, is a blessing. In accreditation it can convert the site visitor (who benefits from open, frank and revealing interactions) to a regulator (who is reduced to checking off boxes in a rigid grid). “Does transparency have a chilling effect on the site visitor’s report?” is a question that might be appropriate for a NACIQI member.

When hearing about graduation rates, NACIQI might profitably ask whether human interactions (a legislator’s effectiveness, marriage, religious experience), and enterprises (hospitals, jails, retirement communities, colleges and universities) can, indeed, be reduced to numbers.

In a phrase, NACIQI must have people at the ready, from day one, to push back. When they hear talk about student engagement, for example, they must be able to ask questions like: “Does engagement create successful students or are successful students engaged?” And to ask about the experiments, to scientific standard, that support the answers.

NACIQI members must not hesitate to go beyond the surface to seek out the ideas and complexities of accreditation. They should not be intimidated by words like “regulations” and “statutes.” Law as applied to education is a guide, not a barrier or a set of blinders. The Higher Education Act expects that NACIQI members will be people of a variety of backgrounds who are fair and perceptive, with good judgment. NACIQI was not intended to be made up entirely of lawyers.

Education is an analog process that cannot be properly understood or described in terms of discrete digital elements. Even if a qualitative question can be posed, NACIQI members should be prepared for a quantitative response.

At one particularly painful period, accrediting agencies were being asked about the number of applicant schools they rejected. Some members of NACIQI seemed impatient with anything other than a simple numeric answer. Actually, rejection often takes place before a formal application is submitted. The head of the school makes contact, gets to spend a long time with an accreditor, learns enough about the process to know what may be missing, and how to get ready for the future. By the time most schools apply, they’re ready to succeed. A number tells a distorted story, if that!

There are many other such pitfalls; fortunately transcripts of previous NACIQI meetings are readily available, so that anyone can relive some of the highlights (or lowlights) of the past. Attending a conference of the Council for Higher Education Accreditation and/or spending time with accreditors will be invaluable as well.

In the end, the success of NACIQI will depend upon the selection of people who are independent thinkers, knowledgeable, confident, and able to clash in the world of ideas – knowing that every word they utter will be recorded, transcribed, and made available to everyone, everywhere.

Oh yes, by the way, welcome.

Author/s: 
Bernard Fryshman
Author's email: 
newsroom@insidehighered.com

Bernard Fryshman is an accreditor and a professor of physics.

Fixing the Babel of Multi-State Licensure

From time to time there is discussion in higher ed circles about the desirability of developing a system of college approval using interstate reciprocity based on a model code. The reason this subject comes up more and more often is that more colleges are operating outside their original state of licensure. Schools end up complying with a dozen different sets of state laws and, in many cases, pay significant fees to multiple jurisdictions. All of this has the net effect of increasing the cost of serving students.

Because of the exceptionally decentralized system of college operations and approvals in the U.S., there is no meaningful federal approval that can be relied on to guarantee that certain standards are met.

Reliance on accrediting bodies does not work for a number of reasons. First, accreditors are membership-based organizations; they are not set up to operate as enforcement agents. Also, they are not structurally or legally capable of resolving student complaints, which is a significant role that states currently handle. They have standards that vary somewhat from group to group. In many cases they do not have frequent enough contact with schools. Finally, they are not answerable to the public in any reasonably direct way.

I have heard college leaders argue that they should not be answerable to the public. It is important to remember that although faculty require the freedom to pursue truth where it may lead them without political interference, colleges as a whole are indeed answerable to the public. In fact, only a government can give them degree-granting power, under U.S. law. This is our only bulwark against diploma mills, and the admirable recent actions by Wyoming and Alabama governments to snuff some dubious colleges demonstrates its necessity.

I have heard accreditors argue that because their standards are acceptable to the U.S. Department of Education, states should treat those standards as automatically acceptable. This assumes that the Department of Education has sufficient academic standards that it requires accreditors to enforce, which it does not. The feds do a fairly good job of making sure that colleges who get federal aid are capable of handling it, but they are not in the academic program oversight business. I do not think that any discussion of interstate standards or reciprocity should get tangled up in a discussion of what accreditors or the feds do.

But what do the states do? I work as principal college evaluator for Oregon, and have also done evaluations for several other states. The things that states focus on, and which any interstate agreements would have to incorporate, tend to be detailed and prescriptive, unlike the bulk of accreditation standards.

For example, every three years Oregon requires our approved private-college programs to provide my office with detailed qualification information for every faculty member, full-time and part-time. We look at exactly what their degrees are, what their experience is, and what courses they teach. We often find colleges using faculty to teach in fields in which they are not qualified. We fix that problem.

That is just one example, but it is something that no other type of agency, state or federal, does, except in certain narrow contexts such as evaluation of grant applicants. Why do we do it? Because states are legally responsible for the quality of the educational programs at all colleges, public and private, that operate in our jurisdiction, and in many cases only the state has that responsibility. We have to do it because no one else does or can. We take that role seriously and for the most part (California and Hawaii being the most obvious exceptions) we do it well.

It is time for states to look carefully at each other’s laws and figure out a way to recognize each other’s work when it meets certain minimum standards. What should those standards include? Although there are many possible things to evaluate about a college, the core of any model code upon which reciprocity could be based would have to include the following.

Faculty qualifications. Without a careful look at who is teaching what, and whether they are qualified to do so, meaningful evaluation of a college’s quality is not possible.

Curriculum. Are the programs in each field structured in a reasonable way, comparable to the norm at similar institutions?

Award of credit. Is credit awarded based on an appropriate amount of student work (for example, are schools prevented from giving a degree based on a weekend’s work)? Is credit awarded primarily based on teaching by the school’s own faculty? Is transfer credit limited to schools of demonstrably similar quality? Is credit by examination limited? Is so-called “life experience” credit strictly limited and carefully evaluated?

Admissions. Are admitted students capable of performing college-level work? Are they provided accurate information during the recruitment and admission process? Are any job placement claims backed by solid data?

Finances. Is the college solvent? Does it have adequate reserves to get through periods of falling enrollment? Are fees established and assessed in an appropriate manner, and only on a term-by-term basis? Are refunds available on an appropriate schedule, also term-by-term?

Are there other issues? Certainly, among which are student services, library access and the experience of college managers. However, the five categories shown above have proven to be the crucial ones in my years of experience as an evaluator. The reason is that a failure of performance in any one of these five almost certainly means that the college is not acting appropriately, cannot succeed and is likely to founder. Indeed, a major failure in any of these five should lead the responsible state government to take action to make certain that the college cleans up its act or is closed.

If I could be certain that another state was doing a good job of enforcement in the five core categories, would I be willing to allow a college based in that state to operate in Oregon without going through my own state’s detailed and expensive evaluation process? Yes, with a couple of provisos.

First, faculty teaching only at Oregon’s branch would have to be evaluated by someone, either my office or the state of origin. That is a fairly straightforward task and could be handled by either state, though if they are local residents it probably makes more sense for them to be screened by the state where they teach.

The larger issue is that of student complaints. One of the reasons that offices like mine exist is to provide students who have a bad experience owing to inappropriate actions by a college with a way to get complaints resolved without resorting to litigation. In effect, we are a mediator with a very large stick in the closet. In my ten years as Oregon’s chief evaluator, I have rarely had to use the stick, though I have occasionally cast an ostentatious glance in its direction for effect. Sometimes student complaints are simply not justified or don’t violate any state rule. Sometimes a student complaint uncovers a very significant issue that a college needs to fix. A state can compel corrective action.

It is impractical to expect a student in Oregon to get complaints resolved by a state agency in Indiana or Texas. It seems clear that any streamlined state approval reciprocity would need to leave a significant chunk of problem-solving in the hands of the state where the problem happened. That in turn would require that a model code and reciprocity agreement include arrangements for interstate cooperation in such issues. In practice, I work with my colleagues in other states (and several Canadian provinces) quite often already. We help each other with various kinds of issues. I have no doubt that states willing to sign a reciprocity agreement would be willing to help each other make it work.

So how do we begin? Well-meaning education organizations with little knowledge of the practicalities of how state approvals actually work will decide that they should simply invent such a system without bothering to involve actual regulators. To preclude this kind of bumblehandedness, we need the states to simply get to work on this project and develop a workable model code. An attempt to do this happened in the 1970s, but it was not timely. Today, with so many schools operating across state lines, the need has never been greater.

Author/s: 
Alan Contreras
Author's email: 
info@insidehighered.com

Alan Contreras works for the State of Oregon. His views do not necessarily represent those of his employer.

The Carnegie Unit: Articulate and Expressive

Skipping lightly over 350 years of history, we will take the bachelor's degree as the true given of American higher education. Since we do not have a ministry of education, the definition of this degree is imprecise, variable and sometimes even fluid, as independent and autonomous institutions experiment, compete, modify, and adapt.

There are bounds, of course. States and accreditors ensure that level and scope remain consistent with commonly understood and accepted standards. Not fixed, but clearly recognizable.

Lest we be diverted, we will also have to disregard the 100 year chronology of the Carnegie Unit (CU) and focus on its present role.

In the life of a student and in the career of a teacher, four years is a very long time. The term is a more tractable unit, and at a time when colleges all offered similar programs of limited variety, it probably sufficed. Students moved through college in lock step and there was less of a need for a measure of accomplishment on a course by course basis.

That's not true anymore, and the Carnegie Unit has emerged as a means of identifying accomplishment and progress towards a degree. But it is not a mute measure of elapsed time!

Again, the fundamental given of higher education is the totality of the degree. This involves a content path, a variety of teachers, courses building on one another, and it involves strategies developed over 100 or 150 years of experience. The degree structure encourages a slow but steady change in topics and emphasis to enable courses to remain relevant, fresh, and comprehensive. This in turn enables a students to leave college and enter a job, a career, graduate program, or the professions.

The degree encompasses a generally agreed upon quantity of material delivered over four years, and the CU provides an orderly means of breaking down this totality. The degree presents a coherent track, an organized program, and a series of accomplishments, and so too must the CU.

But the Carnegie Unit is intended to be used only in conjunction with other information. Along with curriculum, catalog description, prerequisites, grades, grade point average, and distribution requirements, credit hours can help describe effort, content, and accomplishment.

A credit hour makes sense only when there is a background of distribution requirements, junior or senior level course work, a degree map, and a topic under discussion. Making progress toward a degree depends on all of these characteristics. The three credits earned in Chem I cannot be offered to replace three credits in Accounting. Indeed, poor planning could leave a student with 150 or more credits and no degree!

Everyone within higher education understands the limits of the Carnegie Unit as well as its usefulness as a medium of exchange, or a lingua franca.

The CU enables useful and easy conversations to take place between departments and among schools. Without this shorthand, every interaction would have to encompass consideration of content, rigor, and intellectual challenge. With it, a course map can be agreed upon that lists 40 courses across 10 departments in an easily comprehensible manner, without the details and minutiae of each course.

The allocation of credit hours is neither mindless nor haphazard. Credit hours are determined by the quantity of material a student is expected to acquire, by the rigor, and by the intellectual challenge he or she will face. So too, the time and effort. History, experience and professional judgment all influence the decision to assign a certain number of credit hours to a certain quantity and intensity of material.

There is within each field and each subject area a commonly understood level of prerequisites, skills, and competencies that students must bring to bear in addressing a conventional college course. A norm is established, and vigorously protected. Experts in any given field can usually look at a curriculum, a textbook, or an examination and deduce whether or not the credits being offered for the course are consistent with common usage.

There are variations of course, but within reason. A student presenting three credits in Calculus 101 will find acceptance of these credits virtually everywhere.

There is a cross-fertilization enhancing the norm that occurs as students become faculty members elsewhere, as faculty members change campuses, as students transfer, as textbooks become widely available, as graduates enter professional programs, and as accrediting team visitors travel to different campuses. Comparisons and conversations, as well as experience, all help create a common credit hour currency which speaks volumes in academe, but only haltingly everywhere else.

For the most part, it is a tenured (and largely jaundiced) faculty that jealously protects the integrity of the courses they teach and the degree that they stand for. While there may be grade inflation in some schools, there is rarely credit hour inflation.

A teacher who does not complete his/her course's goals will at one point or another hear from a colleague teaching a more advanced course to students who do not have all the necessary prerequisites. A school whose students do poorly on the bar examination will examine all aspects of the program leading to graduation. This is all part of a vast self-correcting mechanism that protects students and protects the enterprise.

Also important is the textbook marketplace, in which a handful of texts have gained widespread acceptability at least partially because there is an excellent fit with commonly agreed-upon course descriptions and the number of credits assigned.

Difficulty with allocating credit hour appears at the peripheries. Programs that are unusual in their content or structure, weekend programs, accelerated programs, study abroad, experimental and innovative programs all have a common burden: assigning a certain number of credit hours which signifies accomplishment and progress towards a degree, and which are consistent with the norms of higher education.

Courses offered in conventional format are usually associated with a certain quantity of seat time. This, in turn, provides a template against which courses delivered in unfamiliar or unconventional format can be measured. Teachers who have offered the same course on campus and online know what to expect of students at the end of a course and will also be an excellent source of information for assigning a reasonable number of credit hour to the online (or weekend, or study abroad) course.

We do not live in a wild west environment. While there are innovative and nontraditional programs of all kinds, accomplishment is almost invariably measured against existing bricks and mortar classroom time. There are glitches -- but that's all they are. With several million different courses (and assigned Carnegie Units) offered each year, a handful of extravagant claims do not a national emergency make!

In this connection it's worth noting that it is not the role of the accreditor to "give guidance" in matters relating to credit hours. The assignment of credit hours is a faculty's prerogative and responsibility. It is the accreditor's role to ensure that this was done in a reasonable manner consistent with the field and with broad norms. This, of course, is why site visitors are comprised of experts capable of making such judgments.

For completeness, it's important to mention two parties which, by design, use the credit hour as a simple measure of time.

College administration is one. Different courses require different talents, unequal effort ("I fill up two blackboards each period while he plays movies."), dissimilar exam grading burdens.... None of these factors plays a role in determining faculty salaries -- nor should they. The system works, with every faculty member teaching the same number of credit hours.

Government is the other. Student financial aid takes no notice of differences in subject area, level, course title, rigor, challenge, or school reputation. The Department of Education has avoided interfering with the internal workings of postsecondary schools and should continue to do so.

But herein lies a danger, because there is a disconnect between the Department's usage of the CU and the manner in which it is understood and used in higher education. This is the reason we are being asked to define the credit hour as a simple measure, when as noted above, its use and understandings are quite comprehensive and quite complex.

Defining the credit hour will undo the easy exchange, the ready conversations, and the fuzziness which sometime enables us to coexist. It will generate considerations of other indicators which will similarly have to be precisely defined. Will we accelerate students according to their grade point averages? Will a 4.0 student in physics trump a 4.0 in sociology (or vice versa)?

Will teachers be paid according to the number of students they teach? According to their brightness? Their preparation for the course? Will students pay more for a 45 hour program in a philosophy seminar than a survey course?

In our litigious society, we have to keep an eye on the inevitable aggrieved student. Did he fail the course because the teacher did not provide a full 50 minutes of teaching? Does humor constitute a part of the teaching hour? Does the time spent by some other student talking constitute "teaching"? How about the time spent by the teachers walking up and down the aisles watching as students work a computer assignment? And how do we determine that the student has devoted two hours of out-of-class student work? Will we have cameras, beepers, monitors? What constitutes two hours of out-of-class student work?

Defining a credit hour has implications that could conceivably cause great dislocation and misunderstanding in higher education.

If there are concerns, they are rare. And these unusual episodes should not be allowed to drive higher education, just like the rare high school "diploma mill" student should not be permitted to impose on all of higher education another costly, time consuming, and unnecessary burden.

Author/s: 
Bernard Fryshman
Author's email: 
newsroom@insidehighered.com

Bernard Fryshman is an accreditor and a professor of physics.

Reconsider the Credit Hour

The agenda for change before U.S. higher education is already very long. But with its recent reports on three regional accrediting agencies, the Office of the Inspector General of the Department of Education has moved the definition of the credit hour closer to the top than I had ever imagined.

If the community procrastinates and the out-of-date Carnegie Unit becomes the default definition applied by the department, accrediting agencies and the institutions and programs they accredit will experience greater upset and confusion than they expect or want.

Based on my experience in higher education, I know that for decades faculties assigned credit hours according to a fairly complex although unwritten matrix. But perhaps I received the wrong introduction to the collegiate credit hour as long ago as 1962.

That year Lewis & Clark College, my alma mater, ran a breathtaking experiment. With several other freshman colleagues, I spent my first collegiate semester in Japan. I took four three-credit courses, two of which were completely independent study and two of which involved about six weeks of face-to-face instruction. I took exams in the latter two and turned in lengthy papers in all except Japanese language.

I could not discern any mathematical formula based on seat time and/or study time that made these each three-credit courses. Nor did it bother me that the actual workload for each three-credit course seemed different. I assumed the faculties of record, as well as the L&C faculty as a whole, must have agreed to the assignment of credit hours. Looking back on that experience, I can also testify that had time on task alone been the measure of learning, I probably deserved four credits each in a couple of those courses.

The “flexibility” of the credit hour continued throughout my collegiate career. In finishing my undergraduate studies, I had a three-credit honor’s thesis course that had no structured time commitments. It prepared me for graduate school where, after finishing a sequence of courses, I registered faithfully each semester for credit-bearing “independent” courses for my doctoral research. I assumed that everyone in the academy understood that the use of credit hours to measure student learning often was not tied to seat time or study time.

My decade as a classroom instructor essentially confirmed that understanding. During it I experienced my share of faculty squabbles over losses of a class day -- and the contact hours it represented -- to such things as post-Thanksgiving Fridays and campus-wide days devoted to the discussions of the issue of the moment. Differences among faculty opinions most often were ironed out in curriculum committees and faculty senates. Sometimes contact hours figured into those debates; sometimes other faculty expectations of student activity counted more heavily. But most faculties seemed to have a basic understanding of how to assign credits.

As I moved from campus to campus in the 1970s, I saw that this understanding apparently carried across institutional boundaries. I moved from institutions with 15-week semesters to others with 10-week semesters. I created courses for the four- to six-week courses in a “4-1-4” or a “4-4-1” academic calendar, and once I taught summer school sessions on a six-week calendar. Calendars shifted, but allocation of credit hours, at least to me, appeared to follow some well-understood “industry standards” related to mastery of course content and only loosely tied to the contact hours of a Carnegie Unit.

The fact is that professional judgment by the faculty long ago supplanted seat and study time in the determination of award of credit hours. Faculties, drawing on education and experience, determine what knowledge and skills a student should master; faculties determine how to break into courses and modules the learning processes necessary for that mastery; and faculties determine the rigor, content, and examination strategies appropriate the award of a specified number of credit hours. Individual members of the faculty might propose the course and the credit it should bear, but most often it is their faculty colleagues who make the final determination through curriculum approval processes. It has proven to be a decent system that provides a way to tally up learning while allowing for considerable flexibility in delivering education and evaluating learning.

Colleges and universities that serve adult learners by recognizing achieved learning through portfolio evaluations or ACE credit equivalency determinations or CLEP testing have for decades unbundled credit hours from a rigid formula of seat time and study time. Colleges and universities that have integrated work-study and community service into their credit-bearing courses have as well. In making these important educational pathways work, expert judgments by faculties determine the award of credit hours, either by assigning those hours directly or accepting them in transfer.

I think back on the times that credit hours influenced accreditation actions when I was with the Higher Learning Commission. To be sure, truncation of a standard academic calendar most often triggered concern. Frequently, however, the key issues had less to do with time on task than rigor of expected learning. Inevitably, expert judgment of faculty rather than contact/study hours informed the decision about the appropriateness of the challenged credit award. Those evaluation team members pored over course syllabuses, evaluated the rigor of the assigned work and study, talked with teaching faculty and students, and sometimes reviewed samples of student work. In some cases they concluded that the award of credit was pretty much in line with industry standards; sometimes they proposed that the accrediting agency require that an institution rework its internal systems for determining the award of credit; and sometimes they found the disconnect between achieved learning and assigned credit to be so out of whack that they recommended denial or withdrawal of accreditation.

The Office of the Inspector General prefers auditable measures for performance. It reads the Higher Education Act with its multiple references to credit hours to demand such measures. It appears to propose that the Carnegie Unit is a pretty good place to start. It has little patience with the difficulty of translating professional judgment into some readily auditable matrix. Considering how little that OIG really understands about higher education, I was only a little surprised by how much weight that office placed on such a weak reed.

I was surprised by how quickly voices from the academy and the department proposed that educational quality should, indeed, probably be linked to the Carnegie Unit. A yardstick based on seat time and supposedly related study time to measure collegiate learning is just the wrong tool.

Years ago others wiser than I said it was time to find a new way to measure achieved learning. That advice was prompted not by the time-on-task mentality of the OIG but instead by growing discontent over the lack of dependable transfer of credits from one college to another. Credit hours in too many transfer debates become separated from the actual learning achieved by the student. Faculties in receiving institutions are more likely to question the fit of the curriculum represented by the credits than they are to question the award of the credit hours themselves. Frequently when credits transfer, they just don’t count toward the degree. But the transfer issue has not gained enough traction to bring about a community-wide review of the credit hour.

The current OIG challenge ought to be sand under the spinning wheels of the higher education community on this matter. If the inspector general decides that when it comes to credit hours the law requires something more measurable than professional judgment and if the department agrees, then instead of retreating to the old time-on-task formulas, the higher education community must hold up for review and major revision the credit hour system of measuring learning. The community has too much experience in assigning credit hours to very different learning experiences to try to return to artificial formulas based on contact and study hours.

Clearly no one is particularly interested in having the Department of Education lead this important exercise. Thanks to the much-vaunted decentralization of higher education in the United States, leadership for the endeavor is difficult to identify easily. But a dozen leaders from higher education associations, accrediting agencies, SHEEOs, faculty organizations, and interested foundations must find a way to create a process as important to higher education in this century as the National Education Association and Carnegie Foundation efforts were to the last century. After all, the Carnegie Unit and the credit hour resulted from that seminal work.

With the Carnegie Unit hanging around as the weighty fallback in these resurrected discussions of the credit hour, we must move with dispatch to recast this academic measurement to fit contemporary higher education and the learning achieved by students in it.

Author/s: 
Steven D. Crow
Author's email: 
newsroom@insidehighered.com

Steven D. Crow is CEO of S.D.Crow & Co., which consults on accreditation and other issues, and former president of the Higher Learning Commission of the North Central Association of Colleges and Schools.

Going Public

As the Council for Higher Education Accreditation gathers for its 2010 Annual Conference this week in Washington, I want to urge a change in the way we do accreditation in the United States to strengthen how it supports public accountability.

Let’s require that every institution of higher education prepare a "public learning audit" as part its accreditation materials. This would be a stand-alone statement disclosing the evidence that the institution has regarding student learning, and commenting on why the institution takes the approach to assessing learning that it does. The college or university would itself prepare the statement. The statement would be reviewed by the visiting team during periodic accreditation cycles, and approved by the relevant accrediting body. The learning audit would be publicly available to anyone, placed on the Web sites of the institution in question and of the accrediting body.

Earlham College’s public learning audit would highlight some aspects of our results from the National Survey of Student Engagement and the Collegiate Learning Assessment, and it would provide a link to our full scores on these instruments. It would also discuss the quite varied program by program assessments we do in each of our majors. It might discuss our growing interest in and experimentation with electronic portfolios of student work. And finally it would say something about what we have learned from assessment that is leading us to make changes to improve the education we offer. These elements are an honest reflection of what we are doing about assessment at Earlham, an approach we believe works well for our liberal arts mission. Another institution, one with a different mission or even a different perspective on how to carry through good assessment, would include other elements in their public learning audit.

Why do we need such public learning audits? An exchange between Peter Ewell (vice president of the National Center for Higher Education Management Systems) and the members of the Spellings Commission in the spring of 2006 was one of the more interesting but less constructive moments in the hearings that preceded the commission’s report. Ewell patiently reminded commission members that virtually every step toward better and more widely-conducted assessment of learning in higher education over the previous quarter century had happened because of accreditation. He showed that a good deal of progress had been made. Both at that session and in their final report, commission members, on the other hand, made it clear they had lost patience with accreditation.

“Accreditation, the large and complex public-private system of federal, state, and private regulators, has significant shortcomings,” (p. 14) concluded the Spellings Commission in its final report. No, not everyone would agree that the parenthetical phrase is an accurate, brief description of accreditation. Nevertheless, “significant shortcomings” is a blunt, clear conclusion. The report goes on to say “Accreditation reviews are typically kept private, and those that are made public still focus on process reviews more than bottom-line results for learning and costs” (p. 14). And later in the report, “Higher education institutions should make aggregate summary results of all postsecondary learning measures, e.g., test scores, certification and licensure attainment, time to degree, graduation rates, and other relevant measures, publicly available in a consumer-friendly form as a condition of accreditation” (p. 23).

There has been steadily rising agreement from all sides that we need to put more focus on learning outcomes in accreditation, but on the question of making accreditation more public we have been in a stalemate for years. Critics (such as those on the commission) have insisted that accreditation self-studies and visit reports be made public. Defenders of the current system argue that making these documents public would undermine the candor needed to make these documents useful for institutional improvement. Besides, note defenders, accreditation self-studies and visit reports are lengthy, complex documents; no one in the public would really want to read them.

Public learning audits would provide a middle ground and break the stalemate. Accrediting agencies would provide a rubric for preparing these statements. Colleges and universities would have considerable latitude within these rubrics about how to assess student learning. That latitude would allow an institution to shape its report around its mission(s), and to make its own choices regarding instruments or approaches for assessing learning. These statements would be prepared as stand-alone documents, with institutions knowing that these statements would become public.

Ten years (the normal length of time before an accreditation needs to be renewed) would be too long a shelf life for these learning audits, so the public learning audits would be revised every two years. At the time of re-accreditation, visiting teams would look back over the sequence of statements to assure that these were forthcoming and adequate.

We do not need to require that all the materials prepared for accreditation be made public. But we need to recognize, all of us, that the effectiveness of an institution of higher education with regard to student learning is a legitimate focus of public accountability. Any college or university enrolling students who receive federal financial aid should be subject to such accountability. Public learning audits would be a useful vehicle for providing such accountability. We do not need Congress or the Department of Education to act. Accrediting bodies could make the change themselves.

Author/s: 
Douglas C. Bennett
Author's email: 
info@insidehighered.com

Douglas C. Bennett is president of Earlham College.

Edward Waters College Regains Accreditation

Smart Title: 

Southern accrediting group, after loss in court, reinstates the Florida college.

Report Criticizes Lack of Data on For-Profit Students

Smart Title: 

Agencies should push for more and better information on completion and job placement rates, consumer group says.

Pages

Subscribe to RSS - Accreditation
Back to Top