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The tension between promoting innovation and new approaches on the one hand and protecting academic quality and federal financial aid funds on the other is at the core of many major issues in higher education -- not the least of which is the accreditation system. The system of peer-reviewed quality assurance is frequently attacked as a brake on progress and competition in American higher education, even as others criticize it for going too soft on institutions in ways that cost taxpayers money.

Sylvia Manning does not pretend to have all the answers to all of the issues, and she took her share of guff when caught in the vise between the two competing pressures. But as the former head of the nation's largest regional accrediting body, Manning believes she has a possible answer to one of the dilemmas: how to get new degree-granting institutions off the ground without undermining the accreditors' traditional "gatekeeping" role.

In a paper published last week by the American Enterprise Institute, Manning begins (in ways that some critics might find predictable) by challenging assertions that accreditation, in and of itself, is a barrier to innovation.

Yes, Manning writes, accreditors depend heavily on "inputs" (credentials of the faculty, services provided to students, etc.) as proxies to judge whether an institution is likely to "continue to offer an acceptable level of quality in the education it provides."

But ultimately, an accrediting agency can't accurately assess an institution based only on its plans, she argues. "Accreditation demands evidence, and evidence must be based in accomplishment, not plans," she writes. Since the evidence revolves around how students perform and "what the institution does with students," the evidence can be developed only after students are enrolled.

So yes, she concedes, "the barrier to innovative new institutions is accreditation." But that is not, she quickly adds, "because accreditation cannot deal with innovation, but because it wants and needs time to assess innovation, if the innovation is actually new." But the institution needs accreditation -- or at least one of the key benefits to accreditation -- the ability to enroll students who receive federal financial aid -- right away.

That creates what Manning calls the "chicken or egg problem": fledgling degree-granting institutions needing accreditation so they can enroll students with federal funding, and accreditors not wanting to approve institutions until they've enrolled students and proven their performance with them.

What Happens Now

Most of the ways that accreditors and institutions have worked around this problem in recent years have, in one way or another, "perverted" the process, Manning said in an interview.

Throughout much of the decade of the 2000s, entrepreneurs purchased already-accredited institutions and essentially turned them into a different institution altogether. The Higher Learning Commission was at the forefront of such an approach before Manning became its president, and under her the accreditor largely shut off that pathway. (That didn't stop her from getting raked over the coals at a 2011 Senate hearing that focused on the exploits of the poster child for that type of transformation, Bridgepoint Education's 2005 purchase of a struggling Iowa college that became Ashford University.)

More recently, those trying to create new institutions have turned to what Manning calls "accreditation by association," in which an existing institution teams up with a new entity (often a for-profit company) to create a joint venture. Manning and the Higher Learning Commission were in the middle of that trend, too, with the much-contested 2013 implosion of Tiffin University's partnership with Altius Education, known as Ivy Bridge College. (Supporters of Ivy Bridge criticized her and AEI for the limitations of Manning's proposal and for failing, they said, to fully acknowledge her role in its demise.)

Essentially, Manning argues, there have not yet been good ways for the accreditation system to "handle these kinds of [new] institutions while remaining true to itself."

That disconnect has many policy makers calling for major changes in how accreditation works, although those discussions have largely revealed how little agreement there seems to be on what those changes might be. Manning is skeptical that shortening the time before an institution is accredited, as some have suggested, would work: "[I]t is not possible to both preserve the time test of accreditation and hurry up accreditation for new institutions. To drop the time test would be to drop the elements of an accreditation review that add up to some sort of proof," she writes.

Her alternative is creating something else entirely: a provisional approval to award federal financial aid that would act something like a building permit in facilities construction. This process would involve close study of the would-be new institution's plans (with, yes, a focus on "inputs"), and then once a prospective institution is given permission to recruit students who are eligible for federal aid, annual reviews (not unlike inspections for construction of a new building) to keep that approval. The institution would then need to earn regular accreditation within a specific period of time, say seven years. Students who chose to attend these institutions in the meantime -- and the federal government, to the extent it backed them with financial aid -- would still take on risk, since the students' credits might not transfer.

Some key elements of Manning's vision remain less than fully sketched. She offers several possibilities, for instance, for who might grant this provisional approval -- the Education Department, recognized accreditors, or new nongovernmental agencies.

And she acknowledges the problems that her solution does not deal with at all, most notably whether and how the federal government might recognize the growing number of institutions that do not have any intention of granting degrees. (The Council for Higher Education Accreditation and the Presidents' Forum released a paper last month exploring potential ways to ensure the quality of "non-institutional" providers of higher education.)

But her proposal might satisfy at least some of the critics who say accreditation prevents experimentation, Manning said: "A provisionally approved status gives new institutions what they need to get started and earn accreditation. With this clear avenue to federal student support, innovators interested in starting an institution will not resort to various workarounds, prevarication, or subterfuge. It solves the chicken-or-egg problem simply, transparently, and honestly."

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