Quality Assurance, Rearranged

The Education Department's advisory committee on accreditation was given a nearly impossible task: proposing ways to "fix" the country's complex, multi-part system of ensuring financial integrity and academic quality in higher education.

A "discussion draft" of the report by the National Advisory Committee on Institutional Quality and Integrity, to be published later this week but obtained by Inside Higher Ed, in many ways concedes the difficulty of its assignment, purposefully avoiding putting forth clearcut, unwavering proposals that might suggest that there are easy answers to the knotty problems in the current system. (The panel's leaders take great pains to portray this document as a starting point for a broad and open-minded public discussion about a set of options, and say they hope to be more assertive in a later set of recommendations, depending on how that conversation unfolds.)

But despite its often noncommittal language filled with "might"s instead of "should"s -- and leaving an endless array of unanswered questions -- the document also provides a roadmap by which a very different system of college quality assurance could emerge. It does, for instance, make a strong (if equivocal) case for altering (but not ending) the role of accrediting agencies' role as the primary determiner of colleges' eligibility for federal student aid.

In one scenario laid out by the group, for instance, the federal government, in addition to its current focus on financial integrity, would take on the role of monitoring colleges' compliance with some baseline outcome measures of quality, aiming to ease the pressure on accrediting agencies to serve both as peer reviewers focused on institutional improvement and cops on the beat.

A New Charge

The accreditation panel's primary job is recommending (to the education secretary) whether accrediting agencies are following federal rules such that they continue to deserve federal recognition -- a status that allows them to confer on the colleges and universities they accredit the right to award federal financial aid to their students. But the committee also plays a broader advisory role to the secretary, and different leaders of the department have depended on the panel to varying degrees.

But last winter, Education Secretary Arne Duncan asked the newly constituted version of NACIQI to undertake a broad review of the increasingly beleaguered accreditation system (and, more broadly, the mechanisms by which the accreditors, states and the federal government seek to ensure the quality and integrity of postsecondary education. (The secretary specifically asked the group to suggest changes that might be made when the Higher Education Act is next renewed in 2013, or some time thereafter). Since then, the panel, which is made up of college administrators, government officials, outside experts, and others, has held a series of meetings aimed at soliciting ideas.

The discussions made clear, to anyone who still wondered, just how complicated, convoluted, and conflicting the quality assurance system in the United States is. They also left many observers believing that it would be impossible for the panel (whose members see the world very differently) to draft anything that would unite them and begin to untie the knotty problems in the system -- accreditation's inscrutability and mystery, the reality that the agencies are being asked to take on a policing role to which they're not well-suited, the fact that states, the federal government and accreditors have roles that both overlap and leave major gaps, to name a few.

Recognizing the potential divides among the panel’s members, a subcommittee charged with drafting the report – which itself included a wide range of viewpoints – opted to produce a document that included lots of “options” and “considerations” rather than firm “proposals” and “recommendations,” and to publish it on a short enough timetable so that educators, policy makers and others – in what the panel’s chairwoman, Jamienne Studley, called a “virtual roundtable” -- can weigh in with their views on which ideas might or might not be sound, and what the consequences of different possible solutions might be.

“We chose to do it in terms of ‘mights’ and ‘what ifs’ intentionally, because this is a complex system and we didn’t want to do something that suggested we had all the answers,” said Studley, president of Public Advocates, and a former college president (of Skidmore College) and Education Department lawyer. “We’re eager for the field, defined broadly, to help us really think about whether these could work, and based on what we hear, we plan to move from this to something that is more directional in terms of recommendations to the secretary.”

That framing, as a contained list of possibilities rather than a set of recommendations, helped the report earn unanimous approval from the full committee, in part, Studley said, because “we chose to include many ideas that somebody or another [on the committee] didn’t favor.”

“We chose to do it in terms of ‘mights’ and ‘what ifs’ intentionally, because this is a complex system and we didn’t want to do something that suggested we had all the answers.”

That doesn’t mean the report reads like a laundry list; plenty of ideas ended up on the cutting room floor (at least for now), such as proposals to create an entirely separate agency to assess the financial integrity of for-profit colleges, and the outright end of regional accreditation.

The report focuses on the current and appropriate roles of the three main actors in higher education quality assurance, the U.S. government, the states, and accreditors (the so-called triad); the extent to which those roles align or leave gaps, and whether the overlap creates an excessive data and regulatory burden that might be eased without any reduction in effectiveness.

The core question, though – in many recent years’ policy discussions about accreditation, and in the panel’s report -- revolves around whether colleges should continue to be required to gain accreditation to participate in federal financial aid programs.

Sections of the report argue all sides. Taking accreditors out of the process of determining institutional eligibility for financial aid, as some critics have advocated, would eliminate from the process “the most experienced source of information about academic quality” in the system, the report states. It would also make that assessment of institutional quality a governmental decision (or much more of one, since some critics assert that the federal government is already putting so much pressure on accreditors that it is already driving the decisions, if not making them).

Keeping accreditors involved also helps ensure that the quality assurance system “does not subject institutions of higher education to rapid changes in how they will be judged for purposes of accreditation (and therefore federal financial aid),” the report says. “This can be contrasted with experiences of universities in several European countries when the government changes the rules precipitously and there is no independent ‘buffer body’ to help absorb the shock and help ensure that changes are both real and appropriately incremental.”

But the report also cites that entanglement between the federal government and the accreditors as an argument for separating accreditation from the process for gauging eligibility for financial aid programs under Title IV of the Higher Education Act. The fact that institutional quality and self-improvement has historically been determined by a peer-review process conducted by colleges themselves (rather than the government) has long been seen as a great strength of American higher education; but the linkage to federal financial aid (and the ballooning in recent decades of federal spending on higher education) have introduced an “array of consequences that are neither appropriate nor desirable.”

Among them: “undesired intrusion of the federal government into matters more appropriately assigned to institutions,” and “an assignment to an academic peer review enterprise [of] a policing function that it may be neither willing, nor fully competent, to undertake.”

Ending the linkage between accreditation and federal aid eligibility would free the accreditors of the uncomfortable job of policing financial integrity and keep the government out of questions of quality, the report suggests. But the panel cites arguments that financial integrity alone “is insufficient to serve the federal interest” in higher education quality, which leads it to a third option that would modify, rather than end, the link between accreditation and financial aid eligibility.

Under such a system, the panel suggests, the federal government might review colleges’ compliance with “baseline federal financial responsibility and performance measures,” which it leaves undefined for now. “Once institutions passed this review, eligibility to participate in the Title IV programs could be attained by either satisfying specified heightened federal quantitative performance criteria or securing accreditation from an approved accrediting entity.”

Such an approach would, by creating a federal process that assessed colleges based on “quantitative performance criteria” that are not financial in nature, give the government a bigger role in judging institutional quality than it has now.

So many questions would remain, the report acknowledges: What would those “heightened” criteria be? Would all institutions get to make that choice, or only institutions that perform well for a period of time? And “[h]ow would the federal government set the performance measures that would establish sufficient indicia of educational success that an institution or program would not be required to secure accreditation?”

The NACIQI report addresses a slew of other issues and tensions, including the great variation in the degree and quality of state regulation of higher education (sometimes overlapping with the demands and roles of accreditors and the U.S. government), the prospect of allowing colleges to choose among accreditors (perhaps based on their institutional missions rather than their location), and the possibility of better coordinating what kinds of data accreditors, states and the federal government collect from institutions, to ease concerns that “the quality assurance enterprise collects too much data and data of the wrong type.”

While the panel’s report offers some options to deal with those and other problems, its authors hope to spur a period of intense comment and discussion that will allow them to sharpen the committee’s work. But that will happen only if the feedback takes a certain form, said Studley, the chairwoman.

“We don’t want people to just re-date what they sent us before, arguing for the same approaches they did then,” she said. “We were hoping to focus in on a set of opportunities, concerns and consequences, and put out some options that might make enough difference in addressing those problems to be worth considering. We hope people will concentrate their feedback on those.”