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Whether on student loan policy or oversight of for-profit colleges, federal higher education policy over the past decade has resembled a ping-pong match, with rules adopted by one administration reversed or revised by the next. With college accreditation now on the Biden administration’s agenda with rule-making meetings starting this month, are we in for a wholesale reversal of the Trump administration’s 2020 rule changes?
While noisy fights over free speech and other issues on campuses may get the headlines, much of the important work on higher education policy and quality is, fortunately, more amenable to constructive discussion and solution. We should know, because in our roles as two of the 18 members of the National Advisory Committee on Institutional Quality and Integrity, which advises the secretary of education on accreditation, we led a subcommittee tasked with identifying ways to improve federal oversight of the accrediting agencies that open the door to federal grants and loans.
NACIQI is designed to cut across ideological lines. The committee includes Trump and Biden appointees; officials from a religious college, a public university, for-profit colleges, a historically Black college and a community college; and a range of independent experts. One of us is among the appointees of congressional Republicans, the other, Democrats.
Despite our diversity, our subcommittee was able to work through the details of a number of issues relating to the policies and processes around accreditor recognition, culminating in recommendations that were accepted unanimously by the full NACIQI membership last summer. These recommendations provide the U.S. Department of Education with a constructive starting point for the upcoming rule making. Here are some of the topics we raised.
Groups that lean both left and right have complained that while the public may provide input on accreditors’ applications for recognition, or on reviews of their adherence to federal rules, under current regulations the public can only do so without access to the relevant documents and under time frames that don’t make sense. Reporters, too, have been frustrated, forced to file Freedom of Information Act requests that take years to bear fruit, long after the issue has been decided. The subcommittee recommended changes to the timeline and public record policies so that the public—and NACIQI members—would have both the information and opportunity to weigh in on specific accrediting agencies.
How accreditors handle complaints was also a key topic. Our review and experience found that some accreditors have processes that make it too difficult for students and others to voice concerns or complaints about a college. The subcommittee recommended changes that would require accreditors to be more open to input, even if the person did not submit the complaint in precisely the manner requested by the agency. An agency should not be able to ignore the substance of a complaint just because it was not written in legalese, came in the wrong envelope, lacked a phone number or was anonymously made.
While college accreditation is a peer-review process, federal law requires that boards of recognized accrediting agencies include at least one member for every six who represents the public or student interests rather than those of the accredited colleges. Because some accreditors have treated that requirement somewhat half-heartedly, the subcommittee drafted rule changes to make those positions more independent.
Perhaps the weediest topic discussed by the subcommittee related to the requirements surrounding “substantive change” and written arrangements between institutions and third parties. Given the amount of work colleges and universities are doing with third parties to offer online certificates and programs, the subcommittee’s recommendations focused on the need for specific changes to current regulations to ensure accrediting agencies are consistently and appropriately reviewing changes in program offerings and growth in new areas at an institution.
News coverage of the subcommittee report focused largely on the thorny issue of student achievement. Should the federal government require accreditors to be more aggressive in requiring evidence that students are learning? Committee members were divided, but all accepted the subcommittee’s modest approach of requiring accreditors to have some standards they set to assess student achievement rather than no standards at all, and expecting them to be able to tell NACIQI what those standards are and how they monitor them.
In an effort to find consensus, we are encouraged that some ideas referenced in the subcommittee’s report appear are included in the Education Department’s initial issue papers as starting point for the upcoming rule making. We agree about the importance of ensuring the billions of dollars that consumers and taxpayers spend on higher education are getting the value we all deserve.