Tussling Over Transfer of Credit

February 26, 2007

Given that a clear majority of traditional-age undergraduates attend at least two institutions at some point in their college careers, the issue of how smoothly (or not) academic credits or degrees earned at one college transfer to another has steadily climbed the ladder of public policy problems in higher education.

The issue, which matters because it costs students (and governments, if those students receive state or federal financial aid) money and time if they have to repeat coursework unnecessarily, was fought out, but not resolved, during 2005 discussions over renewing the Higher Education Act, and it earned a prominent place in last year's report of the Secretary of Education's Commission on the Future of Higher Education.

Yet there are really two related but distinct transfer of credit problems, a reality underscored during a fractious discussion Friday on the third and final day of the Education Department's opening negotiated rule making session on accreditation in a hotel ballroom just outside Washington. (Here you can find recaps of Day 1 and Day 2 of the meeting, which federal officials used to collect information and ideas about whether and how to propose new rules about accreditation.)
The problem that affects by far the most students, department officials and accreditors at Friday's session agreed, involves the growing swarms of students who start their educations at community colleges and find that four-year institutions in their own or especially other states decline to embrace the credits or associate degrees they've earned at the two-year institutions.

The solution to that problem, most policy makers and college leaders agree, is for more pairs of institutions to craft articulation agreements or for states to adopt accords that either set agreements involving specific institutions or develop common course numbering systems or statewide common cores for transfer. That's a painstaking process and one that is happening at too slow a pace, the experts generally concur, but community college officials strongly oppose any attempt (federal or otherwise) to force institutions to accept credits they're not comfortable with.

Most of Friday's discussion was about the other transfer of credit issue: the fact that some number of colleges routinely reject academic credits earned by students at "nationally" (as opposed to "regionally") accredited colleges, which are overwhelmingly for-profit rather than nonprofit. Those concerned about this problem characterize it as snobbery and bias against nontraditional institutions, while many traditional academics say they are merely safeguarding their institutions' academic integrity.

Although for-profit colleges enroll a small fraction of American college students (under 6 percent), the institutions' public visibility and political might are disproportionate, as evidenced by the fact that a full quarter of the slots at this week's federal negotiating session on accreditation were filled by representatives of for-profit colleges (the number climbs even higher when you factor in another nontraditional institution, the nonprofit but fully online Western Governors University, which is also susceptible to skepticism as a relatively new player in higher education).

Officials of for-profit colleges and national agencies that accredit career-oriented institutions argued forcefully at Friday's meeting that the Education Department should require accrediting agencies to ensure that the institutions they monitor have policies that do not, as a matter of course, reject students' transfer credits simply because they were earned at a nationally accredited college -- and that they follow those policies.

"Students are required too often to repeat coursework, pay for something twice, use the public's resources in terms of federal and state financial aid, and have impediments put in the way to advancing their career objectives," said Mark Pelesh, executive vice president for legislative and regulatory affairs at Corinthian Colleges, Inc. Yes, there have been lots of discussions and studies and statements about the problem, including a 2005 Government Accountability Office report, he said, but now, "it's high time we do something that has some regulatory teeth and impact."

"I've lost faith in the higher education community's ability to really solve this problem without some regulatory or legislative action," said Elise Scanlon, executive director of the Accrediting Commission of Career Schools and Colleges of Technology. "I'm not somebody who loses faith very easily. But when you talk to students every day, and yet no one seems to recognize that, it really does affect the way you see this issue."

Pelesh, Scanlon and others focused most of their comments on the effects of the transfer denials on students. But they also acknowledged, as has been clear in the for-profit sector's push for new rules or laws on transfer of credit, that part of the reason the issue is so important to commercial colleges is because of what the perceived discrimination says to students and others about their institutions.

"Students who may not even be interested in transferring credits nonetheless will ask us whether other institutions will accept their credits," Pelesh said. "What they're really asking is, is this a legitimate institution? Is it part of the legitimate postsecondary higher education world?" And policies that openly distinguish between credits earned at for-profit and nonprofit colleges -- turning down their nose at the former -- send a signal that answers that question No, he said.

The other members of the accrediting panel were generally sympathetic to the notion that college policies on credit transfer should not discriminate against nationally accredited institutions, and noted that major college groups, including the American Council on Education, had embraced a 2000 statement by the Council for Higher Education Accreditation that specifically said that colleges should ensure that “transfer decisions are not made solely on the source of accreditation of a sending program or institution.” Ronald Blumenthal, senior vice president at Kaplan University, a major for-profit college provider, pointed out, though, that the statement “is a principle, which includes the word ‘please,’ “ which others acknowledged.

But in a recurring theme of the three-day meeting on accreditation, some members of the federal panel used a range of arguments to actively discourage the Education Department from turning to the federal regulatory process to try to solve problems, including this one.

Judith S. Eaton, president of the Council for Higher Education Accreditation, which coordinates accreditation nationally and recognizes 60 accrediting agencies, questioned whether the department had a legitimate legal basis for trying to change transfer of credit policies through accreditation regulations rather than a change in federal law (Pelesh, of Corinthian, insisted that legislative provisions giving the department latitude to monitor accreditors’ policies on admissions standards provided the legal authority).

Eaton and Steven D. Crow, executive director of the Higher Learning Commission of the North Central Association of Colleges and Schools, one of the six regional accrediting agencies, said that it would be a mistake for the Education Department to use federal regulation to require accreditors to oversee the transfer policies of the colleges they oversee. (That has been the stance of virtually all nonprofit colleges and their representatives, including the American Association of Community Colleges, which fought efforts in the 109th Congress to add to the Higher Education Act a transfer of credit requirement like the one the for-profit institutions are pushing the Education Department to impose through regulation now. The Association of Collegiate Registrars and Admissions Officers led the opposition to that effort.)

“I’m very skeptical that you can load this onto an accrediting agency … without turning us into a federal auditing agency,” Crow said. He also warned that imposing such a policy would result in any student whose credits are rejected by a college appealing to its accreditor for relief. “It would turn us into the largest complaint agency over this stuff,” he said.

Ralph S. Wolff, who heads the senior college commission of the Western Association of Schools and Colleges, also warned that imposing such a requirement would take away the right of institutions to set their own standards for what they see as equivalent in quality to their own courses and degrees. It would be a mistake to do this, he said, just like “it would be problematic to tell institutions which degrees are acceptable for admission to graduate school.”

That it was left to Wolff to make that argument reflected the fact that college and university leaders were largely excluded from the federal accreditation panel’s discussion last week. In addition to the multiple representatives of for-profit higher education on the rule making committee, several of the other negotiators included officials from state higher education departments, large public university system offices, and scattered experts on accreditation.

But the nation’s research universities and liberal arts colleges -- which would typically be expected to most view issues such as federal regulation of transfer of credit policies as an intrusion into their affairs -- have had no seat at the table. College lobbyists have viewed that imbalance as a purposeful effort by the Education Department to tailor the entire conversation around accreditation to achieve its desired results, which they see as trying to turn the accrediting process from one aimed primarily at ensuring that colleges are improving to becoming “agents of public accountability,” as Wolff described it Friday.

“One of the reasons I fight so much about regulation,” said Crow, in explaining his posture throughout last week’s rule making process, is that it’s important that accreditors not be seen as “having abdicated [their] control to a federal agency.... I don’t want it to appear that we are becoming more and more owned by and controlled by the department in how we’re doing our work.”

Exactly how far the department plans to push in trying to use its oversight of accrediting agencies to bring out transformation in higher education will become clearer in about three weeks, when department officials -- in advance of the next round of meetings by the rule making panel on March 26-28 – releases draft regulations on the wide range of issues discussed here: whether the agencies should set minimum standards for colleges’ outcomes on student learning, how much information about their reviews accreditors should make public, transfer of credit, and the like.

That’s when the real fun should begin.

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