‘Obstacle Course of Bureaucracy’

The complaint processes at seven of the agencies charged with monitoring the quality of higher education institutions and holding them accountable are burdensome and seem designed to protect colleges, a new brief from the think tank New America argues.

None of the policies reviewed in the brief meet New America’s criteria for an effective complaint process, the brief concluded. Accreditors, in turn, say they take complaints seriously and that the report doesn’t fully reflect their processes. Complaints typically come from students or employees who think their institution has violated an accreditation standard or policy.

Edward Conroy, a senior adviser with New America’s education policy team, reviewed the policies for the seven formerly regional accreditors, such as the Midwest’s Higher Learning Commission and the Middle States Commission on Higher Education. Among the seven, he ranked the policy for Southern Association of College and Schools Commission on Colleges (SACSCOC) as the most burdensome. SACSCOC requires complaints in writing, professional transcripts that have been notarized for audio recordings and two copies of all supporting documents, per the brief. The Western Association of Schools and Colleges Senior College and University Commission had the easiest-to-navigate process, according to the brief.

“None of them are great, and all seem to have put processes in place to make it very difficult for the average person to easily submit a complaint about their institution, and that seems less than ideal for agencies that are meant to be ensuring the quality of higher education,” Conroy said.

A member of the National Advisory Committee on Institutional Quality and Integrity (NACIQI), which makes recommendations to the Education Department about accrediting agencies, questioned SACSCOC president Belle Wheelan last year about the agency’s policy. Department officials required SACSCOC to review its complaint process as a condition of the agency’s renewal of federal recognition.

Wheelan said that the agency’s policy, in place since 1999, has been revised several times since and has not been an issue for the department or NACIQI until this most recent recognition process. Colleges and universities have to be accredited by an Education Department–recognized accreditor in order to disburse federal student aid.

The accreditors reviewed for the report oversee about 85 percent of the country’s colleges and universities, according to the brief.

Some of the accreditors highlighted in the report took issue with the document, including its title—“Higher Education Accreditors Don’t Want to Hear Your Complaints.”

“I think it’s the headline and some of the ways that the report presents things as something where we’re trying to suppress complaints or hide problems, and that for us really couldn’t be further from the truth,” said Tracey Schneider, senior vice president for legal affairs and general counsel for the Middle States Commission on Higher Education.

Middle States is one of four regional accreditors whose recognition status is up for renewal and who are set to appear before NACIQI next week at the committee’s winter meeting. The commission, which received 275 complaints from 2018 to 2022—half of which were from students—is currently reviewing its complaint policy as part of its normal policy-review process. That review will include several of the issues raised in the New America report.

Other accreditors said that they appreciated the report’s suggestions, which could serve as a starting point for reviewing complaint processes.

‘Not Sufficient’

Conroy judged the policies by a set of principles adapted from the Institute for College Access and Success for designing processes that serve students. The criteria included that processes should be easy to understand, with simple tools to submit complaints; agencies should monitor complaints for problematic patterns; and processes should operate independently of the institutions overseen.

He looked specifically at whether complaints could be submitted online, whether the agency required the complainant to identify a specific accreditation standard that might have been violated and whether anonymous complaints were allowed, among other questions.

Most did have an online system for complaints, but none allowed complainants to be anonymous.

“Differing standards, combined with the removal of regional boundaries for accreditors, sets up the perfect conditions for a race to the bottom in higher education oversight,” Conroy wrote in the report. “A review of the complaints processes used by the seven regional accreditors reveals no common standard in how they handle complaints.”

Conroy called for agencies to release more data about the number of complaints they receive and how they are resolved. Currently, the accreditors are not required to release details on the complaints they receive, he said.

The Education Department requires accrediting agencies to review any complaint it receives related to the agency’s standards or procedures.

“It’s not sufficient to just say, ‘We have a complaint process,’” Conroy said. “It needs to be an accessible, easy-to-understand and easy-to-navigate process in order to be considered effective.”

Complaints, Conroy said in an interview, are a way for accreditors to get information about what’s happening at an institution in between reviews, which are typically every 10 years.

“If you’ve created a system that makes it very difficult to complain, so that only the most determined people get through this obstacle course of bureaucracy, then you’re going to artificially reduce the number of complaints that get to you,” he said. “As a result, you might be, as an accreditor, missing really important information that can help you do your job better to make sure that institutions are providing students with a quality education.”

Accreditors said in interviews and statements that complaints are just one way that they hear about potential issues at institutions and they have other avenues to raise issues with an institution if a person wants to remain anonymous. Representatives also said they don’t only interact with institutions when it comes time to reaffirm their accreditation status—institutions have to file annual or interim reports. Accreditors also can initiate an inquiry whenever they receive information, whether that’s through an anonymous tip or a news article.

Conroy said that the requirement for individuals to cite an accreditation standard in the complaint was “very unreasonable,” given the complexity of the standards.

Lawrence Schall, president of the New England Commission of Higher Education, said he’s found that the standard requirement is not a difficult one for complainants to fulfill.

“We don’t ask people to go deep into the issue, which means they don’t have to pore through our booklet,” he said. “Is it a finance issue? Is it a governance issue? Is it a student issue? It’s just sort of high level, and they just check a box and that’s pretty easy to do.”

He added that the commission doesn’t reject complaints if they list the wrong standard.

“We think it’s an important part of what we do,” he said.

Schall said his agency has received about 100 complaints since 2020, when he took over as president. The agency oversees about 200 institutions.

“We have a very strong complaint policy,” he said. “It works. We get lots of complaints.”