With all the extensive consultation about the Postsecondary Institutions Ratings System during the past 18 months, all the meetings and the many conversations, we know almost nothing about its likely impact on accreditation, our all-important effort by colleges, universities and accrediting organizations working together to define, judge and improve academic quality.
All that the U.S. Department of Education has officially said to date is that the system will “help inform” accreditation -- and we do not know what this means.
This is worrisome. Ratings create, in essence, a federal system of quality review of higher education, with the potential to upend the longstanding tradition of nongovernmental accreditation that has carried out this role for more than 100 years. And establishing the system may mean the end of more than 60 years of accreditation as a partner with government, the reliable authority on educational quality to which Congress and the Education Department have turned.
Accreditation is about judgment of academic quality in the hands of faculty members and academic administrators. It is about the commitment to peer review -- academics reviewing academics yet accountable to the public -- as the preferred, most effective mode of determining quality. It is about leadership for academic judgment when it comes to such factors as curriculum, programs, standards and strategic direction remaining in the hands of the academic community.
In contrast, a ratings system is a path to a government model of quality review in place of the current model of academics as the primary judges of quality.
First introduced by President Obama in August 2013 and turned over to the Education Department for development, the ratings system is on track for implementation in 2015-16. Based on the still incomplete information the department has released to the public, the system is intended to rate (read: judge) colleges and universities based on three indicators: access, affordability and student outcomes. Institutions will be considered either “high performing,” “low performing” or “those in the middle.” Ultimately, the amount of federal student aid funding a college or university receives is intended to be linked to its rating.
A federal ratings system is both an existential and political challenge to accreditation.
First, there is the challenge of a potential shift of ownership of quality. Second, new key actors in judging quality may be emerging. Finally, the relationship between accreditation and the federal government when it comes to quality may be shifting, raising questions about both the gatekeeping role of accreditation in eligibility for federal funds and the agreement about distribution of responsibilities among the parties in the triad -- the federal government, the states and accreditation.
A ratings system means that government owns quality through its indicators and its decisions about what counts as success in meeting the indicators. The indicators replace peer review.
It means that government officials are key actors in judging quality. Officials replace academics. With all respect to the talent and commitment of these officials, they are not hired for their expertise in teaching and learning, developing higher education curriculum, setting academic standards, or conducting academic research. Yet using a ratings system calls for just these skills.
A ratings system means that the relationship between accreditors and the federal government, with the accreditors as dominant with regard to quality judgments, may give way to a lesser role for accreditation, perhaps using performance on the ratings system as a key determinant of eligibility for federal funds -- in addition to accreditation. Or, it is not difficult to envision a scenario in which ratings replace accreditation entirely with regard to institutional eligibility for access to federal financial aid.
We need to know more about what we do not know about the ratings system. Going forward, we will benefit from keeping the following questions in mind as the system -- and its impact on accreditation -- continues to develop.
First, there are questions about the big picture of the ratings system:
Has a decision been made that the United States, with the single most distinctive system of a government-private sector partnership that maximizes the responsible independence of higher education, is now shifting to the model of government dominance of higher education that typifies most of the rest of the world?
What reliable information will be available to students and the public through the ratings system that they do not currently have? Will this information be about academic quality, including effective teaching and learning? What is the added value?
Second, there are questions about the impact of the ratings on accredited institutions:
Are the indicators to serve as the future quality profile of a college or university? Will the three indicators that the system uses -- access, affordability and outcomes -- become the baseline for judging academic quality in the future?
Will it be up to government to decide what counts as success with regard to the outcomes indicators for a college or university -- graduation, transfer of credit, entry to graduate school and earnings?
To claim quality, will colleges and universities have to not only provide information about their accredited status, but also their ratings, whether “high performing,” “low performing” or “in the middle”?
Will institutions be pushed to diminish their investment in accreditation if, ultimately, it is the ratings that matter -- in place of accreditation?
Finally, there are questions about how ratings will affect the day-to-day operation of accrediting organizations and their relationship to the federal government:
Will accreditors be required to collect/use/take into account the information generated by the ratings system? If so, how is this to influence their decisions about institutions and programs that are currently based on peer review, not ratings?
Will performance on the ratings system be joined with formal actions of accrediting organizations, with both required for accredited status and thus eligibility of institutions for federal funds -- in contrast to the current system of reliance on the formal actions of accrediting organizations?
How, if at all, will the ratings system affect the periodic federal review of the 52 accrediting organizations that are currently federally recognized? Will the government review now include the ratings of institutions as part of examination and judgment of an accreditor’s effectiveness?
While we cannot answer many of these questions at this time, we can use them to anticipate what may take place in the approaching reauthorization of the Higher Education Act, with bills expected in spring or summer.
We can use them to identify key developments in the ratings that have the potential to interfere with our efforts to retain peer review and nongovernmental quality review in preference to the ratings system.
Judith S. Eaton is president of the Council for Higher Education Accreditation.
Today, leaders of colleges and universities across the board, regardless of size or focus, are struggling to meaningfully demonstrate the true value of their institution for students, educators and the greater community because they can't really prove that students are learning.
Most are utilizing some type of evaluation or assessment mechanism to keep “the powers that be” happy through earnest narratives about goals and findings, interspersed with high-level data tables and colorful bar charts. However, this is not scientific, campuswide assessment of student learning outcomes aimed at the valid measure of competency.
The "Grim March" & the Meaning of Assessment
Campuswide assessment efforts rarely involve the rigorous, scientific inquiry about actual student learning that is aligned from program to program and across general education. Instead, year after year, the accreditation march has trudged grimly on, its participants working hard to produce a plausible picture of high “satisfaction” for the whole, very expensive endeavor.
For the past 20-plus years, the primary source of evidence for a positive impact of instruction has come from tools like course evaluation surveys. Institutional research personnel have diligently combined, crunched and correlated this data with other mostly indirect measures such as retention, enrollment and grade point averages.
Attempts are made to produce triangulation with samplings of alumni and employer opinions about the success of first-time hires. All of this is called “institutional assessment,” but this doesn’t produce statistical evidence from direct measurement that empirically demonstrates that the university is directly responsible for the students’ skill sets based on instruction at the institution. Research measurement methods like Chi-Square or Inter-rater reliability combined with a willingness to assess across the institution can demonstrably prove that a change in student learning is statistically significant over time and is the result of soundly delivered curriculum. This is the kind of “assessment” the world at large wants to know about.
The public is not satisfied with inferentially derived evidence. Given the cost, they yearn to know if their sons and daughters are getting better at things that matter to their long-term success. Employers routinely stoke this fire by expressing doubt about the out-of-the-box skills of graduates.
Who Owns Change Management
Whose responsibility is it to redirect the march to provide irrefutable reports that higher education is meeting the needs of all its stakeholders? Accreditors now wring their hands and pronounce that reliance on indirect measures will no longer suffice. They punish schools with orders to fix the shortfalls in the assessment of outcomes and dole out paltry five-year passes until the next audit. They will not, however, provide sound, directive steps for the marchers about how to systematically address learning outcomes.
How about the government? The specter of more third-party testing is this group’s usual response. They did it to K-12 and it has not worked there either. Few would be happy with that center of responsibility.
Back to the campus. To be fair, IR or offices of institutional effectiveness have been reluctant to get involved with direct measures of student performance for good reasons. Culture dictates that such measures belong to program leaders and faculty. The traditions and rules of “academic freedom” somehow demand this. The problem is that faculty and program leaders are indeed content experts, but they are no more versed in effective assessment of student outcomes than anyone else on campus.
This leaves us with campus leaders who have long suspected something is very wrong or at least misdirected. To paraphrase one highly placed academic officer, “We survey our students and a lot of other people and I’m told that our students are ‘happy.’ I just can’t find anyone who can tell me for sure if they’re ‘happy-smarter’ or not!” Their immersion in the compliance march does not give them much clue about what to do about the dissonance they are feeling.
The Assessment Renaissance
Still, the intelligent money is on higher ed presidents first and foremost, supported by their provosts and other chief academic officers. If there is to be deep change in the current culture they are the only ones with the proximal power to make it happen. The majority of their number has declared that “disruption” in higher education is now essential.
Leaders looking to eradicate the walking dead assessment march in a systematic way need to:
Disrupt. This requires a college or university leader to see beyond the horizon and ultimately have an understanding of the long-term objective. It doesn’t mean they need to have all the ideas or proper procedures, but they must have the vision to be a leader and a disrupter. They must demand change on a realistic, but short timetable.
Get Expertise. Outcomes/competency-based assessment has been a busy field of study over the past half-decade. Staff development and helping hands from outside the campus are needed.
Rally the Movers and Shakers. In almost every industry, there are other leaders without ascribed power but whose drive is undeniable. They are the innovators and the early adopters. Enlist them as co-disruptors. On campuses there are faculty/staff that will be willing to take risks for the greater good of assessment and challenge the very fabric of institutional assessment. Gather them together and give them the resources, the authority and the latitude to get the job done. Defend them. Cheerlead at every opportunity.
Change the Equation. Change the conversation from GPAs and satisfaction surveys to one essential unified goal: are students really learning and how can a permanent change in behavior be measurably demonstrated?
Rethink your accreditation assessment software. Most accreditation software systems rely on processes that are narrative, not a systematic inquiry via data. Universities are full of people who research for a living. Give them tools (yes, like Chalk & Wire, which my company provides) to investigate learning and thereby rebuild a systematic approach to improve competency.
Find the Carrots. Assume a faculty member in engineering is going to publish. Would a research-based study about teaching and learning in their field stand for lead rank and tenure? If disruption is the goal, then the correct answer is yes.
Assessment is complex, but it’s not complicated. Stop the grim march. Stand still for a time. Think about learning and what assessment really means and then pick a new proactive direction to travel with colleagues.
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