In more than 30 years of involvement in accreditation and postsecondary education, I have rarely seen a body of any kind stimulate so much debate, discussion and review as the Secretary of Education's Commission on the Future of Higher Education. 
This is probably to be expected, given the seriousness with which the Secretary is following the deliberations of the commission, the quality of its members, and the sometimes provocative proposals that have emerged, particularly with respect to accreditation.
Judith S. Eaton, president of the Council of Higher Education Accreditation, suggested in these pages an aggressive response, noting that "actors in the private sector [could] step in and develop new mechanisms to gather information about higher education quality in a more transparent and evidence-based way, sidelining accreditation."
Eaton makes a strong case for change in the "conduct of the business of our enterprise," but I believe a great deal of calm and dispassionate debate is in order before recommending change.
First some context. The relationship between government and accrediting agencies is that of partners -- wary partners, but partners. (For those who want a little more background on why this is so, please follow this link. ) There is a dynamic equilibrium in effect, ensuring that if change is to take place, it will be done responsibly, with careful review, and with the input of the entire postsecondary community.
Viewing the commission’s proposals through that prism, a federal accrediting system that is not of the academy itself, that does not enjoy the confidence of the schools being visited, would quickly reduce to a regulatory system, and a regulatory system will simply not work. Schools are open and frank when talking to colleagues; regulators never learn about limitations and deficiencies that are regularly discussed with accreditors. Federally operated accreditation would be adversarial in nature and would not allow the professional judgment that is so central to higher education. When we take into account the possibility of political input, it is clear that federal accreditation will fail.
A national accrediting system could conceivably work but without the outcomes that have made American higher education the envy of the world and without the successes that bring other nations to study accreditation and to emulate it. Accreditation is not just a paper process. On the one hand, the institutions and programs being accredited play a key role in determining the standards and policies under which they are recognized. At the same time, accreditation agency staff knows much more about schools and programs than appears on reports. There are personal relationships that add immeasurably to an agency's ability to assess a school and its function. These reasons call for smaller agencies rather than a single national body.
In addition, the multiplicity of accrediting bodies helps create intellectual ferment, diverse approaches, experimentation and the sharing of strategies and techniques and the cross fertilization of ideas that lead to improvement in accreditation. Conferences and papers sponsored by the Council on Higher Education Accreditation are often both stimulus and venue for this healthy interaction which in turn leads to responsible, carefully monitored, and targeted change.
Our thoughtful and reasoned response to the commission should point out that for over two decades, states, accreditors and scholars alike have sought valid indicators of institutional quality, without success. Similarly, those seeking measures of student learning have failed to identify strategies that accomplish this accurately and comprehensively. Suffice it to add that should such valid measures surface, accreditors and schools will enthusiastically adopt them. Note the emphasis on the word valid.
We might also explain that calls for transparency will result in a reluctance of schools to be open and straightforward to accreditors, and influence site visitors to write defensively. We would emphasize the importance of accreditation in establishing a threshold for quality, and in fostering a culture where institutions and programs seek to improve beyond that threshold.
And we would make it clear that in accreditation, improvement does not require structural change, and not all change is improvement.
Bernard Fryshman is executive vice president of the Association of Advanced Rabbinical and Talmudic Schools' Accreditation Commission.