Accreditation

Accreditation: A Flawed Proposal

A recent report released by the Secretary of Education’s Commission on the Future of Higher Education recommends some major changes in the way accreditation operates in the United States. Perhaps the most significant of these is a proposal that a new accrediting framework “require institutions and programs to move toward world-class quality” using best practices and peer institution comparisons on a national and world basis. Lovely words, and utterly fatal to the proposal.

The principal difficulty with this lofty goal is that outside of a few rarefied contexts, most people do not want our educational standards to get higher. They want the standards to get lower. The difficulty faced by the commission is that public commissions are not allowed to say this out loud because we who make policy and serve in leadership roles are supposed to pretend that people want higher standards.

In fact, postsecondary education for most people is becoming a commodity. Degrees are all but generic, except for those people who want to become professors or enter high-income professions and who therefore need to get their degrees from a name-brand graduate school.

The brutal truth is that higher standards, applied without regard for politics or any kind of screeching in the hinterlands, would result in fewer colleges, fewer programs, and an enormous decrease in the number and size of the schools now accredited by national accreditors. The commission’s report pretends that the concept of regional accreditation is outmoded and that accreditors ought to in essence be lumped together in the new Great Big Accreditor, which is really Congress in drag.

This idea, when combined with the commitment to uniform high standards set at a national or international level, results in an educational cul-de-sac: It is not possible to put the Wharton School into the same category as a nationally accredited degree-granting business college and say “aspire to the same goals.”

The commission attempts to build a paper wall around this problem by paying nominal rhetorical attention to the notion of differing institutional missions. However, this is a classic question-begging situation: if the missions are so different, why should the accreditor be the same for the sake of sameness?  And if all business schools should aspire to the same high standards based on national and international norms, do we need the smaller and the nationally accredited business colleges at all?

The state of Oregon made a similar attempt to establish genuine, meaningful standards for all high school graduates starting in 1991 and ending, for most purposes, in 2006, with little but wasted money and damaged reputations to show for it. Why did it fail? Statements of educational quality goals issued by the central bureaucracy collided with the desire of communities to have every student get good grades and a diploma, whether or not they could read, write or meet minimal standards. Woe to any who challenge the Lake Wobegon Effect.

So let us watch the commission, and its Congressional handlers, as it posits a nation and world in which the desire for higher standards represents what Americans want. This amiable fiction follows in a long history of such romans a clef written by the elite, for the elite and of the elite while pretending to be what most people want. They have no choice but to declare victory, but the playing field will not change.

Author/s: 
Alan L. Contreras
Author's email: 
editor@insidehighered.com

Alan L. Contreras has been administrator of the Oregon Office of Degree Authorization, a unit of the Oregon Student Assistance Commission, since 1999. His views do not necessarily represent those of the commission.

Not All Change Is Improvement

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.

Author/s: 
Bernard Fryshman
Author's email: 
editor@insidehighered.com

Bernard Fryshman is executive vice president of the Association of Advanced Rabbinical and Talmudic Schools' Accreditation Commission.

Who Hypnotized Whom?

The world of genuine education awoke to a rude surprise on July 29, 2006, for on the previous day Mr. Justice Eady of the British High Court ruled that the Daily Mirror newspaper had libeled a celebrity hypnotist by saying (in articles in 1997 and again in 2003) that his Ph.D. from LaSalle University of Louisiana was bogus. The hypnotist, one Paul McKenna, who performs on television and works with many famous clients, had no other degrees at the time. The judge said that the newspaper had not shown that its statements about LaSalle were “substantially true.”

This is nonsense. Seek in vain for LaSalle of Louisiana, unless you seek among the records of the Federal Bureau of Investigation, U.S. Postal Inspection Service, the courts of Louisiana or the records of the federal prison in Beaumont, Tex., where LaSalle’s owner, who used various names, served time for running the fraudulent college from which McKenna acquired his degree.

Having read the entire opinion, I can say that Eady deserves an award for having listened to such a peculiar case filled with half-truths, quarter-truths and untruths and actually written an exceptionally clear, thoughtful opinion about it. That his conclusions are fundamentally mistaken on the question of whether LaSalle degrees are degrees in the usual sense of the term has as much to do with the exceptional obscurity of American education law as it does about Mr. McKenna’s actions.

It also sets a very bad precedent for the international use of degrees.

Anyone interested in the actual history of LaSalle can read about it in Allen Ezell and John Bear’s book Degree Mills (Prometheus, 2005). LaSalle, its history, its brethren and its spawn are all detailed there.  A similar account is available in the new, now ironically named publication “Guide to Bogus Institutions and Documents” (June, 2006) from the American Association of Collegiate Registrars and Admission Officers.

McKenna argued successfully that he did not know that LaSalle’s accreditation was baseless, and the judge agreed that it was unreasonable for him to have been expected to know.  That is doubtful but not outrageous, considering that Mr. McKenna is an uneducated person who had to go outside the U.K. to acquire any degree. But the judge went on to say, as quoted by Michael Herman in the Times of London:

“…whatever one may think of the academic quality of his work, or of the degree granted by LaSalle, it would not be accurate to describe it as “bogus.”

These words appear mild and even judicial in temperament, but consider what they mean in reality. A judge in one country has declared that an entity in another country is a legitimate doctoral institution, contrary to the universally understood status of the degree supplier in its home country.  The misunderstanding comes about because the judge does not realize that authority to issue degrees in the U.S. comes from states that may in fact have no meaningful standards for such programs.  This was the case in Louisiana in the 1990s, as it is in Mississippi today.  It can therefore be true, as the judge found, that LaSalle was issuing degrees legally under the laws of Louisiana, but also true, which the judge did not grasp, that the degrees issued did not represent academic learning.  

The term “bogus” as tossed around in this case did not refer to the legality of the institution; it referred to the nature of its product relative to the standard expectations of a college degree.

The McKenna case therefore sets a strange precedent for who decides the international use of degrees.Until now, we could generally assume that each country got to decide what is and is not a meaningful college degree within its own boundaries. The fact that LaSalle was briefly allowed to operate as a religious exempt institution in Louisiana (a status acquired by building a church on its lawn) became irrelevant on the day that its owner was convicted of degree fraud, and of course its Ph.D.s were risible from the beginning.

All degrees are by definition academic credentials. Doctoral degrees issued by LaSalle are invalid academic credentials. LaSalle never issued what anyone in American education would accept as genuine degrees. The fact that a few U.S. employers mistakenly allowed such degrees to be used speaks of shoddy screening practices at employers who hired LaSalle degree holders, not of degree acceptability. The fact that McKenna claimed to have sent course work to the owner of LaSalle does not make its  degrees genuine.

Eady’s opinion assumes that any entity claiming to be a college is capable of issuing genuine doctoral degrees, provided that it can produce the barest mist of a holographic image of pillars around itself. I readily concede that he has the right to do that within the norms of British law, provided that he is making that decision about a British degree grantor. In the McKenna case, he made that decision about a U.S. degree-grantor, which he should not have, and he got it wrong.

In paragraph 36 of the opinion, the judge wrote that whether a LaSalle degree is “scholarship worthy of academic recognition” is not the matter being litigated. The fact that the judge italicized the word “academic” only emphasizes the underlying problem: All Ph.D.s are academic, and must be so to be genuine. There is no such thing as a nonacademic Ph.D. In paragraph 60, Eady repeats this odd view when he mentions the distinction between the academic value of the Ph.D. and “its practical use.” It is not difficult to get some practical use out of a bogus Ph.D. -- for a while.  If that were the standard upon which issuance of Ph.D.s were to be based, we’d all be calling each other Doctor.

It is less important that Eady got it wrong than that he made a determination about a foreign college contrary to how the home nation treats that college. I hope that other British judges do not make the same error, and that this case remains, not an anomaly, but an utterly freakish result, as it is widely viewed in the education community.

Finally, it is important to consider the difference between this case and the recent cases involving fake schools in Liberia. In the St. Regis case, which involved the issuance of documents that appeared genuine, approving that entity to issue Liberian degrees a U.S. court was presented evidence that the college’s approval in Liberia had been obtained through fradulent means and bribery, and that the approval was therefore invalid, as were the degrees issued by the entities. Any nation should have the right to decide that degrees issued by a so-called college in a foreign country are substandard or fake, and therefore unusable in the receiving nation, based on evidence supporting that view, because degrees cannot be imported like coal: Degrees are not commodities and do not contain the same ingredients. All nations need the right to protect their citizens from fakes.  

No nation has the right to compel acceptance of degrees issued by a fake school in another country, simply because someone thought it was a real school. Mr. Justice Eady has done the academic community a favor by saying that the Mirror newspaper had not shown that LaSalle was sufficiently bogus. This should wake up the British ministry in charge of postsecondary education, which will, I hope, establish a meaningful screening system for grossly substandard degrees issued by fly-by-night suppliers in other countries.

Author/s: 
Alan L. Contreras
Author's email: 
newsroom@insidehighered.com

Alan L. Contreras has been administrator of the Oregon Office of Degree Authorization, a unit of the Oregon Student Assistance Commission, since 1999. His views do not necessarily represent those of the commission.

Don't Forget the Registrar

Now that Education Secretary Margaret Spellings is using the report of her Commission on the Future of Higher Education to stake out accreditation as the de rigueur battlefront/seed ground/hammer/hoe, we are seeing institutions and accrediting agencies and higher education associations alike scrambling to raise their hands high to the Department of Education in a show-and-tell fest, unprecedented since another commission’s report card, "A Nation at Risk: The Imperative for Educational Reform," was sent home nearly a quarter of a century ago.

While faculty, deans, and provosts are earnestly trying to address the accountability issue and to apply a wide range of instructional and enrollment patterns made possible through new uses of technology -- such as wholly online courses and degree programs, hybrid courses and programs with blends of face-/seat-time and online work alongside traditional campus-based learning; collaborative learning tools; and immersive simulation learning environments (see the EDUCAUSE Learning Intiative 7 Things You Should Know About… series) -- they face the challenges of decreasing resources, increasing enrollments, more demands for non-traditional courses, and a growing entry level population who arrive in class without the basic skills needed to succeed.

To be successful, major academic redesign efforts often require the involvement of individuals with skills and knowledge not available at the department level where most of the discipline-specific work is done. While experts in technology, in assessment, in teaching methodology, and in course and program design are sometimes made available to faculty and academic offices, the registrar is, unfortunately, rarely involved in these discussions from the earliest stages.

Such an omission can be costly because the registrar can often be a critical component in academic transformation. No matter which of the many possible outcomes of the accountability movement we are talking about -- whether a national unit record system; new metrics for gauging academic progress and graduation rates; adaptable information systems for new forms of instructional design; discipline-specific measures of learning outcomes; mission-, demographic-, and Carnegie class-specific success standards or a more direct match between learning outcomes, assessment and grading criteria -- in each instance new support systems and policy changes will often be required, and in each instance the registrar is a key agent for any changes that may be required.

In the role of translator, arbiter, influencer, recorder, encoder, manipulator, and implementer of academic policy, grading protocols and keeper of official transcript records, privacy policies, enterprise information system architecture, real and virtual classroom usage rules, and academic calendar parameters, the registrar in involved in a wide array of campus activities below the radar of most faculty and many administrators. The registrar, however, can play a vital role in academic innovation by providing invaluable policy counsel and advice about the degree to which information systems can be customized, and, ultimately, can grease the tracks of academic innovation.

The role of the registrar in academic innovation

The registrar has, in fact, a major role to play in four of the most basic academic initiatives found on many campuses:

  • Redesigning and improving the quality of courses and curricula.
  • Enhancing the processes of course management and delivery to create more options and increased flexibility.
  • Translating academic policies into efficient and easily used procedures and refining campus-wide inter-departmental records management procedures accordingly.
  • Maintain official academic records and related processes in accord with state and federal privacy legislation while providing faculty and students with the information they require for quality advising and decision-making.

At far too many institutions, academic support, management, and information systems have simply been unable to keep up with the demands and requirements of faculty and academic units as they explore new applications of technology and new patterns of teaching and learning to improve the retention of students, to increase the involvement of students in the community, and to improve the quality and effectiveness of their academic programs.

The problem is a basic one. Many of the academic procedures and structures we now use were developed in a time when colleges and universities were far different than they are today. The challenges were fewer, the instructional capabilities of today’s technology not even dreamed of, the students far more homogenous and motivated, and interaction between the disciplines was the exception and not the rule, with most instruction taking place on campus in the classroom, the library, or the laboratory. It was a far less complex world for students, faculty, administrators, and staff.

Typical efforts to redesign courses and curricula involve faculty working alone or on a team with other faculty in the discipline. Experience has shown, however, that the most effective projects include, in addition to the stakeholder faculty members, others who bring to the table expertise in areas not found in most departments. Without this broader participation key questions will go often go unasked and unanswered, and important options will remain unexplored.

Serving on the core team should be the key faculty members, and an instructional designer or faculty member from another discipline who understands process of change and brings to the table the knowledge of the research on teaching and learning and the ability and willingness to ask hard questions and to test assumptions. Available to the team should be experts on assessment, on technology, and, while often overlooked, the registrar to anticipate and assist in making the necessary adjustments that will be required in academic regulations and system support.

The common issues

When comprehensive course or curriculum redesign efforts get underway at either the graduate or undergraduate level a number of fundamental questions need to be addressed. Among them:

  • What were the assumptions being made by faculty about the students entering their courses and degree programs, and how accurate were the assumptions?
  • What knowledge and skills did students actually bring to particular classes or programs? (If students entered an introductory course with a wide range of knowledge and competencies, why should they all start at the same place? If students had advanced skills or knowledge, could they be exempted from certain units within a course or curriculum?)
  • Must all students move through a course or program at the same pace? If some students required more time to complete a unit, how could we handle grades at the end of the semester when the work was not yet complete? When students move at different rates, have different requirements based on prior knowledge and experience, and if work might carry over from semester to semester, how can we handle credits, grades, student charges and faculty loads not to mention various student-aid issues?

(For a more detailed list of common questions and how one campus, Syracuse University, developed systems to successfully address these issues, please see a "Case Study: Flexible Credit and Continuous Registration.")

The Syracuse experience offers three key lessons that can guide other campuses.

First, without the registrar as a key player from the start, no easy synergy can be developed between instructional innovation, academic policy, records procedures, and system adaptation. If those directing the project, whether the focus be on on-campus, off-campus or a combination of both settings, are building on the latest research on teaching and learning and are “thinking outside of the box” new administrative systems will be required and these changes will be impossible to implement without the active participation of the registrars office. 

Second, new technology innovations such as e-portfolios and course/learning management systems are often implemented under accelerated pressure jeopardizing compliance with external privacy regulations that the registrar could have anticipated.

Third, unless an individual or a design organization (i.e., the registrar or a teaching and learning support unit) becomes a visible proponent of opportunity to adapt technology and policy, new visions will chafe against tradition and sputter at best. The registrar often brings to the project a knowledge of the institutional change culture, the political and technical history of the institution, and remembers what has worked and why.

Without the active involvement of the registrar, schools, colleges and academic departments attempting to significantly improve the quality of their academic program can anticipate inefficient or retarded progress.           

Author/s: 
Robert M. Diamond and Peter B. DeBlois
Author's email: 
newsroom@insidehighered.com

Robert M. Diamond is president of the National Academy for Academic Leadership and professor emeritus at Syracuse University, where he played a major role in the development of the flexible credit and continuous registration system. Peter B. DeBlois, currently director of communications and publishing at EDUCAUSE, served as university registrar at Syracuse University from 1985–2001. Before that, he served as director of registration and records and assistant director of freshman English. He helped design and implement Syracuse’s flexible credit and continuous registration system.

Time for a Shotgun Divorce

The irresistible force of the Cheneyist federal government has met the immovable object of colleges entrenched in their Eisenhower-era way of doing things, or so some commentators on the Department of Education’s recent attempt at negotiated rule making would have it. If that were true, it would be a fairly traditional conflict that could be resolved through standard political channels.

Under those conditions, the service of a critic such as Anne Neal on the National Advisory Committee on Institutional Quality and Integrity (NACIQI), the department panel that reviews accreditors, would excite little attention. Government and politics are joined at the hip, and Neal has been a visible and effective commentator on important policy issues, from a position roughly congruent with that of Republicans. Fair enough.

But that isn’t the situation. What is really happening is that accrediting bodies, which are not part of any government, are being jammed in between the principals like trapped sheep and beaten from both sides. The feds beat them for not thinking or acting like enforcers. Their collegiate membership beats them for listening to The Idiots In Washington. The Department of Education is using accreditors as a human shield to absorb incoming fire from schools, while simultaneously insisting that the accreditors, not the feds, fight back, with ammunition supplied by the feds themselves.

Sorry, that’s a foul. Can’t do it that way. It’s even inconsistent with the usual habits of the force-based Cheneyist government, which is usually quite willing to simply declare any opposition -- indeed, any discussion -- to be enemy action and begin stomping. Of course, arranging for a third party to be blamed for one’s actions is as old as politics.

Neal has argued that the formal linkage between the feds and accreditors needs to come to an end. She is right. This civil union of the 1950s, so convenient in another era under other conditions, no longer works. Eligibility for federal financial aid should be decoupled from accreditation as soon as possible and determination of eligibility brought inside the Department of Education. The department does it already for foreign schools, albeit badly. The establishment of an eligibility unit inside the department would simplify the situation immensely. If ever a Republican president were to support additional staff for the department, this is where they should go. Democrats could hardly object: adding this function where it belongs would allow government to work more efficiently and colleges to have a much clearer idea of what standards they must meet. A fine bipartisan plan.

The feds are trying in a very crude, clumsy way to transform accreditors into things that they were never intended to be and cannot be effectively: enforcement arms of the federal government. If the federal government wants to impose standards on schools that want federal aid, fine. Standards must be met for most federal aid, and that is as it should be. But the feds should not hide behind a third party in a shotgun wedding, when the bride would rather be anywhere else and the children think their new daddy is made by Frankenstein.

The standards for eligibility for financial aid should be set through a rational, governmental rule-making process that establishes the standards -- just like every other agency does it. Well, I make no claims of rationality for all governmental decisions, but neither can I do so for all policies established by accreditors -- assuming that anyone can figure out what they are.

Various critics of accreditation argue that the process is intrusive, ineffectual, does not help maintain quality and is not worth keeping. That’s a discussion that needs to happen between the colleges and their accreditors, separately from what standards the federal government expects colleges to meet for aid eligibility. I have seen good, bad and useless things emerge from accreditors during my years working in higher education, and the discussion needs to happen. Separately. It is not appropriate to try to answer those questions, which are not federal in nature, in the middle of a tug-of-war between colleges and the feds, by wrapping the rope around the necks of the accreditors in the middle.

There is no reason for accreditors to be attached to the federal government. Allowing this interspecific coitus to continue is simply a recipe for mutant policy offspring that can’t be effective. End it now. It’s time for a shotgun divorce.

Author/s: 
Alan Contreras
Author's email: 
newsroom@insidehighered.com

Alan L. Contreras has been administrator of the Oregon Office of Degree Authorization, a unit of the Oregon Student Assistance Commission, since 1999. His views do not necessarily represent those of the commission.

A Better Way on Transfer of Credit

The higher education community has been engaged in a vigorous contest with policy makers (both in Congress and in the U.S. Department of Education) over whether universities should use accreditation status to determine decisions about whether to accept the academic credits of transferring students. Arrayed on the side of restrictive regulations are individuals in the U.S. Department of Education, select members of Congress, and the Career College Association, which represents proprietary schools -- all favoring new legislation and/or regulations prohibiting individual credit transfer decisions being determined “solely on the basis of accreditation.”

The institutions targeted by these proposed restrictions are those that deny credit transfer from postsecondary institutions accredited by entities other than the six recognized regional accreditors (e.g., Middle States Association of Colleges and Schools, Western Association of Schools and Colleges).

Opponents of the proposed legislation and regulations argue that the federal government should have no role in determining credit transfer decisions that historically -- and appropriately -- have been the responsibility of the faculty and, in some instances, states and their governing systems. The debate is fueled by heated monologues, anecdotal testimonials and campaign contributions.

At the core of this policy debate is the assumption that the type of accreditation held by the institution where a student was enrolled should not be the controlling influence on the decision to award credit by the receiving institution. I believe that assumption needs to be revisited.

It must be remembered that one of the reasons for the establishment of accreditation by geographical regions was precisely to provide assurance to accepting institutions that the credits earned at the “sending” institution were in fact “earned and comparable.” Within regions virtually all institutions offering academic coursework were known and a network of college officials worked together to make practical and usually fair transfer decisions.

The higher education world has changed dramatically in the past few decades. There has been a massive growth in student enrollments, with an increasing number transferring credits from several institutions. Whereas a quarter of a century ago a typical institution might have 200 credit transfer decisions in a given year, today that same institution, particularly if located where the population is growing, may have 2,000 such decisions. One Midwestern public university with over 12,000 students annually makes nearly 4,000 credit transfer decisions. The staff in admission and registrar offices have experienced only modest growth during this same period. As a result there are far fewer resources available to address credit transfer decisions.

This explosion in student numbers is but part of the problem. Equally problematic is the growth in the number of institutions offering higher education credits. The latest figures (2006) indicate there are 2,713 proprietary institutions eligible for federal Title IV Funds, most marketing themselves as “accredited” with their accrediting agency recognized by the United States Department of Education. Just over half of these are less than two-year institutions, many offering freshmen “equivalent” courses.

Federal student aid policies, particularly those grossly expanding “guaranteed student loan” programs, have significantly contributed to growth in the proprietary sector. Recent changes in educational benefit programs for active duty military personnel have likewise contributed to the creation of institutions seeking to serve military personnel. From 2000 to 2006 the number of proprietary institutions offering baccalaureate degrees increased over 50 percent, from 274 to 429. Our sympathies should flow to registrars and admission offices flooded with transfer requests and at times confronted with transcripts from distant institutions whose names are hardly recognizable.

I would argue the opposite of the position now being made by policy makers and their patrons: Accreditation status, especially that conferred by established regional accrediting groups, should be a key part of the decision-making process by which institutional officials make credit transfer decisions.

Where institutions not regionally accredited are known to registrars it makes eminently good sense that they would make credit decisions based on what they know: articulation agreements, the experience of earlier transfer students, and the Transfer Credit Practices database used by the American Association of Collegiate Registrars and Admissions Officers. But for distant, recently created and even suspect institutions not well known to registrars and admission officers, credit transfer decisions based solely on the absence of regional accreditation status are reasonable and justified. Institutional accreditation by the six regional associations remains the most thorough and reliable of all accrediting efforts. It is also a process historically resistant to political and financial influence.

Does such a position unfairly discriminate against proprietary institutions? Not necessarily. The most recent data available (2004) indicate that 165 of the then 375 four-year proprietary institutions (or 44 percent) had earned regional accreditation. In short, a large number of those proprietary institutions meet the same standards as do independent and public colleges and universities and for them credit transfer would be handled on comparable bases. The remaining proprietary institutions would better serve their students by likewise pursuing and achieving accreditation from one of the six regional accrediting entities, rather than marketing a narrow peer accrediting status (often called “national accreditation”) and seeking governmental intrusion in the accrediting process.

The public interest would be better served if policy makers, rather than berating credit transfer decisions or proposing “federalizing” transcript evaluations, would, instead, support the work of regional accrediting agencies. Moreover, policy makers should question complaining institutions about why they have not earned regional accreditation as have a significant proportion of their proprietary counterparts.

Author/s: 
Constantine W. Curris
Author's email: 
newsroom@insidehighered.com

Constantine W. Curris is president of the American Association of State Colleges and Universities.

Time to Step Back

The last thing I want to do is defend the system of college and university accreditation that we have now, which I believe is seriously flawed. But I do want to argue that bringing in more government control will make it worse.

The secretary of education wants to mold accreditation to the current fashions of higher education criticism, to incorporate “student learning outcomes” such as graduation rates and other quantifiable measures that can be used to compare one school with another. But embedding these concepts into regulations is a recipe for stagnation. It means that graduation rates will be measured for years after they become meaningless in a world of lifelong learning, and today’s imprecise measurements of learning will become a series of inappropriate tests enshrined in law. And they’ll be costly, too.

Indeed, in my view the chief problem of accreditation is that the federal government already has too much control.

Consider the history of accreditation. Decades ago, regional accreditors were private organizations composed of schools that wanted to show that they met quality standards. Accreditation was like the Underwriter’s Laboratory seal for electrical appliances -- a voluntary way to signal that minimum standards (for safety, in the UL case) were met.

That changed, beginning with the G.I. Bill, as the federal go vernment began to provide aid to colleges by supporting students through grants and then low-interest loans. Unwilling to back up the expanding federal aid with direct monitoring of institutions -- and nudged by a few scandals -- government officials eyed the regional accreditors as gatekeepers. The accreditors received, in turn, an enormous increase in prestige and power.

This support from the federal government has enabled the six regional agencies to function in a way that economists would call a cartel. They divide up the country and operate without competition -- while holding life-or-death power over the institutions that they “represent.” This arrangement stifles innovation and slows to a crawl the creation of new institutions (such as independent online universities).

But the overweening power that the government bestows on accreditors may be less harmful than what seems to be coming down the pike -- or was, until Congress rapped the secretary’s knuckles, forcing her to back off from promulgating new federal rules on accreditation and, in legislation that has now passed the Senate, restricting her power to do so in the future.

I agree that it’s important to measure student outcomes. But the federal government is not the one to do it, or even to insist on it.

Yes, there's a dilemma. The federal government gives many billions of dollars, via students, to the nation’s universities and colleges, and, yes, it has a fiduciary responsibility to use those billions wisely. I’ve noticed, however, that fiduciary responsibility for taxpayer money rarely comes up when we talk about defense expenditures or farm subsidies.

Frankly, I do not expect fiduciary responsibility from government. We have just gone through a painful episode of malfeasance with respect to student loans. Inappropriate lending practices were no secret, but they went on for years with little oversight by the Department of Education or anyone else.

In the case of accreditation, the federal government uses the agencies to keep money from going to “diploma mills.” The government should leave it at that. It’s simply not capable of assessing the intricacies of measuring outcomes.

And if the idea of measuring student outcomes is a good one, why does anyone need to force it on our schools, anyway?

Higher education is clearly undergoing a period of self-examination, as evidenced by books like Derek Bok's Our Underachieving Colleges and the PBS book and documentary Declining by Degrees. Efforts are being made to identify student outcomes. These include keeping records of graduation rates (which, in spite of Secretary Spellings’ concerns, seem to be widely published), the National Survey of Student Engagement, and the 2006 civic literacy study of the Intercollegiate Studies Institute.

And then there are the U.S. News and World Report rankings. Although U.S. News is rightly criticized for its "input" and "reputational" measures, I understand that the editors are open to new measures of outcomes, and there are other rankings, such as the Princeton Review, the Fiske Guide, and Kiplinger's.

Secretary Spellings' own Commission on the Future of Higher Education issued a report that has spurred a national dialogue about how to improve our schools. The secretary's legacy should be the national conversation to which she has contributed, not more government meddling.

Unfortunately, the best resolution of the accreditation conflict is politically impossible: drastically reduce federal scholarship aid. Let Congress appropriate an amount of aid that the government can intelligently monitor and provide it as grants to poor but qualified students.

But if aid continues to burgeon and the department must continue to rely on accreditors, it should at least open up accreditation to more players. Last spring it did just the opposite by retracting its recognition of the American Academy of Liberal Education. By removing AALE, it tightened the
grip of the cartel.

This is not a good prognosis, in my view, for positive results from future government tampering. My recommendation is: Hands off, Secretary Spellings.

Author/s: 
Jane S. Shaw
Author's email: 
doug.lederman@insidehighered.com

Jane S. Shaw is the executive vice president of the John William Pope Center for Higher Education Policy in Raleigh, N.C.

Score One for the Secretary

It’s strange to be looking back while we’re still in the middle of the process of reauthorizing the Higher Education Act, but the hiatus since the Senate passed its version of the legislation is the first chance those of us interested in higher education policy and quality assurance have had to catch our breath in almost two years.

Certainly the almost unending stream of initiatives from Secretary of Education Margaret Spellings, beginning with the Commission on the Future of Higher Education, and then, in quick succession, the commission summits, the big changes at the National Advisory Committee on Institutional Quality and Integrity, negotiated rulemaking on accreditation and the HEA have kept us alert, attentive -- and scared.

The secretary wanted quantitative measures of learning and performance metrics, and we in higher education were hard pressed to establish that currently available learning measures were not reliable, valid or comprehensive. It took all we had to explain that her goal of ensuring comparability on learning measures among the many differing types of institutions would create a ‘one size fits all’ model for higher education, and lead to tragically misleading results. We faced, and faced down, pressure for a level of transparency that would compromise accreditation.

These last few months have not been a happy time: purgatory never is. But things look a lot better when it’s over. For the first time in decades, the ferment, the scrutiny and criticism of higher education made headlines. The debate, the close examination of ideas and the resulting clarification turned out to be immensely helpful. Suddenly, the negative implications of the new proposals became clear, and college and university presidents in unprecedented numbers came to the defense of a diverse and independent American higher education.

The learning outcomes language that emerged from the Senate, substantially unchanged from current law, could never have come about were it not for the fact that everyone understood the stakes. The debate, the controversy, the proposals and even the intrusion all played their part.

In essence, Secretary Spellings did what education secretaries are supposed to do: she pushed higher education higher on the nation’s agenda, she stimulated a cauldron of healthy controversy, and she energized our college and university leadership in a way I haven’t seen before.

I was one of those who disagreed most vigorously (but respectfully, I hope) with some of the secretary’s initiatives. And if circumstances warrant, I will not hesitate to venture an opposing view in the future.

For the time being, retrospect has its own prerogative. Surveying the temporarily empty playing field, I would empathetically score one for the secretary.

Author/s: 
Bernard Fryshman
Author's email: 
newsroom@insidehighered.com

Bernard Fryshman is executive vice president of the Association of Advanced Rabbinical and Talmudic Schools’ Accreditation Commission and a professor of physics at New York Institute of Technology.

Counterpoint: What About the Students?

Constantine Curris’s Inside Higher Ed essay about transfer of credit this week confirms in print what many of us in the national accreditation sector already know: that many institutions base their decisions on credit transfers arbitrarily on the accreditation status of the “sending” college, with complete disregard for the students’ capabilities or the course equivalency of the credits the student seeks to transfer.

What is particularly alarming about the article’s portrayal of the transfer of credit issue is its reliance on history, its almost exclusive emphasis on the burdens imposed on the registrars, and, most importantly, the article’s absolute disregard of the effect that current arbitrary transfer of credit decisions have on the millions of students who attempt to change institutions in order to complete or advance their educations. Should not this national debate focus first on the students and the national education policy goals of helping them complete their educations in the most timely and cost efficient manner, while also ensuring the quality of their educations? If so, then resolving the transfer crisis by prohibiting the arbitrary denial based solely on accreditation makes eminent sense.

While Curris acknowledges the increase in student mobility and in enrollments generally, he seems content to justify current transfer policies on the historical basis for such determinations and on a time in particular when accreditation by “region” served a specific purpose. However, the increasing number of “contemporary” students enrolled -- students who are older, sometimes employed, part-time, and mobile -- is undeniable, and federal education policy and institutions must adapt to and accommodate these students.

Indeed, this fact should not be viewed as a burden, but rather as a responsibility and benefit to this country’s citizens, their educational aspirations and achievements, and to the U.S. economy’s increasing need for continuous educational upgrades. Curris’s article, however, confirms the entrenched and fundamental unwillingness of many institutions to voluntarily adapt their policies and practices on transfer of credit.

Here are the facts: Denial of credits results in the denial of access, as well as in increased education costs when students are forced to pay twice for the same course. These obstacles to completing or improving academic credentials come at a cost not only to those individuals, but also to the taxpayers who often foot the bill for the repeated coursework, and to our economy in the form of the affected students’ delayed entry to our nation’s workforce.

Indeed, in a 2005 report prepared by the Government Accountability Office on the transfer of credit issue confirms the national agencies’ own experiences. The GAO found that “84 percent of postsecondary institutions had policies to consider the accreditation of the sending institution when assessing transfer credits.” An official at the Department of Education recently indicated that the single largest number of complaints the Office of Postsecondary Education receives are from students wondering why their credits were denied by receiving institutions.

Accreditation and the accrediting agencies should play an important role in facilitating, not denying, credit approvals as Curris suggests. All recognized accrediting agencies -- whether regional, national or specialized -- are subject to the same criteria and approval processes by the Department of Education. The Council on Higher Education Accreditation (CHEA) and other organizations, like the American Association of Collegiate Registrars and Admissions Officers, have jointly and formally adopted a policy confirming that institutions should evaluate credits for transfer without discriminating based on the sending institution’s accreditation.

And, yet, the credits of students who attend nationally accredited schools continue to be denied on the basis of accreditation. Curris says that this denial is not necessarily about discrimination against proprietary schools. He is right -- this debate is not about the proprietary institutions. It is about the students who choose to attend institutions that have met Title IV eligibility and are accredited by agencies that meet the same criteria for U.S. Department of Education approval as the regional accrediting agencies. Curris seems skeptical of the types of schools the national accrediting agencies accredit -- in fact, many of these schools and their students look very much like the two year programs and students found at regionally accredited community colleges.

Instead of making arbitrary transfer decisions based on accreditation, the focus by institutions in these decisions should instead be on the students and the quality of credits they received. Even if institutional resources are tight, receiving institutions should be examining the course equivalency of the sending institution and student competency; students deserve this level of basic attention to objective measures. There is no legislation or regulatory solution proposed that would deny or affect the very important autonomy of an institution to make an independent judgment on the merits of the transfer request. The legislation that had been proposed merely asked institutions to give a student’s record a fair review.

This is a national problem requiring a national solution. Articulation, policy statements and other private sector arrangements, while helpful, do little to ensure that students nationwide will be fairly and consistently treated when considering a transfer. To support legislation in this in this area would provide affirmation to students, institutions, and accreditors that Congress intends to support student achievement, mobility, and access to an affordable education, as a matter of national education policy.

That Curris, as the head of one of the country’s major associations of public colleges, would argue otherwise is dismaying.

Author/s: 
Elise Scanlon and Roger Williams
Author's email: 
info@insidehighered.com

Elise Scanlon is executive director of the Accrediting Commission of Career Schools & Colleges of Technology, and Roger Williams is executive director of the Accrediting Council for Continuing Education & Training.

Untangling Quality Assurance in Higher Education

On September 24, a perceptive federal judge in California pointed out the obvious and cleared a lot of thick overgrowth from the landscape of postsecondary oversight in the United States. In brief, Judge Margaret Morrow concluded that a state cannot treat regional accreditors differently from each other in order to favor colleges based in the state over those based elsewhere.

Judge Morrow’s preliminary opinion in Daghlian v. DeVry, with which I agree for the most part, concludes that differences among regional accreditors are insufficient to sustain California’s contention that the state can in effect exempt locally based colleges from state oversight because they are accredited by the Western Association of Schools and Colleges (WASC), while requiring colleges based elsewhere to get state approval to operate because they are accredited by a different regional accreditor.

This decision may cut part of the knot that has plagued proposed revisions of California postsecondary approval laws. WASC has been actively opposing some of the changes, even though they don’t affect WASC schools, apparently on a camel’s nose theory: any hint of state interference in collegiate self-governance must be sprayed with hot and cold running lobbyists. Ultimately, WASC is lobbying the tide not to come in.

The DeVry case may therefore serve to drag into the open one of the less-well-understood aspects of education law and policy. One of the commonest fallacies in higher education, and one which is amazingly ill-understood even by professional educators, is that colleges get to offer degrees because their accreditor allows them to. Not so. Colleges, including private ones, get to offer degrees because state governments give them the authority to do so.

Let me say that again for maximum clarity: Private colleges in the United States have no inherent right to issue degrees. That right comes to them through a grant of authority from a state government. With the exception of Congress and Indian tribes, I know of no other source for degree authority in the United States. The authority may come as a charter, a constitutional provision or a statute, but it must have an origin in state law. No accreditor can give that authority and no accreditor can take it away. Nor can the federal government do either, except for its own colleges.

The federal government recognizes this area of state supremacy in its regulations governing accreditors. A federally recognized accreditor is prohibited by federal rules from accrediting a college unless that college has appropriate state authority to issue degrees prior to accreditation. That is why one current California proposal to allow schools accredited by the Western Association to operate without a separate grant of state authority cannot work. This chicken chasing its own egg is a turkey. Judge Morrow’s preliminary decision serves to add top-quality stuffing to this defunct bureaucratic poultry.

California (and every other state) must formally give authority to issue degrees to every college based in the state that wants to grant degrees. Instead, it seems simpler for states to just punt the function of postsecondary approval to the local accreditor. Sorry, it can’t be done that way. Likewise, accreditors have no ability to grant degree authority to a foreign school -- only the government of the nation, or its properly designated authority, can do that.

In theory, every state diligently determines which colleges can issue degrees and, ideally, exercises at least some baseline quality control. In practice, this does not always happen, and in California today, it can’t happen, for there is no state agency in existence to issue the approval. The consequences are significant.

Right now as I write, it is impossible to start a new degree-granting institution in California, because any such institution requires state approval. It requires state approval not only to get accredited, but to have any legal authority to issue degrees. And it can’t get this approval. On these grounds alone, California is flirting with a Commerce Clause problem: The legislature has de facto protected all existing California colleges from competition. Florida tried this a few years ago and was squashed in federal court.

Also, any California institution that comes up for renewal by its current accreditor has to show that it has current state approval to issue degrees. Some won’t be able to. Even if all parties accepted the convenient but illegal fiction that WASC can stand in for the state, Judge Morrow has killed any attempt by the state to claim that WASC accreditation works as a stopgap but that accreditation by the North Central Association’s Higher Learning Commission doesn’t.

With luck, one side effect of the DeVry case will be to hose out once and for all some of the fictions that states, colleges and accreditors have erected around the curiously opaque process of college and program approval. When the false fronts have collapsed -- the collegial slurry panned for its limited nuggets and the agencies of various states (e.g., loopholed Alabama, grandfathered New Mexico, AWOL Hawaii and disinterested Idaho) subjected to the need to perform -- we can hope for useful changes.

What should emerge from this helpful legal reality check on the role of states and accreditors? First, absolute clarity that each state is legally responsible for the private colleges based there. That includes program quality. No more hibernating under the accreditorial dust storm. Accreditors are owned by their dues-paying member schools and should never be expected to serve as enforcement arms of state or federal governments. They are arms of the colleges, dedicated to advancing the interests of their member schools. There is nothing wrong with that, but let’s give it the right name: a club of schools with similar interests and approaches, not an enforcement body (certainly not of federal standards), and not remotely capable of handling student complaints.

States that have perched primly in the back pews, hands clasped and eyes downcast while the U.S. Department of Education brutalizes accreditors into doing oversight work for which they are unsuited, unfunded and unprepared, need to stop shirking their duties and hoping that the feds will do it for them. Who on earth, looking with unclouded eyes at the federal government, would entrust it with quality control?

I have argued for some time that the Department of Education should make its own decisions about financial aid eligibility based on its own standards, properly enforced by itself. That is a different and appropriate role: You want our money? Here are our rules.

Right now, the Department of Education is incompetent, in the technical sense, to perform college oversight. They can deal, sort of, with the most obvious cases, but they have no real structure in place for meaningful Title IV eligibility oversight. Regional accreditors need not fear losing their recognition, since the feds have no replacement process in place. Therefore regional accreditors and the larger national and specialized accreditors can ignore most federal noises.

Finally, the federal government has no business assuming a duty that constitutionally belongs to the states. The federal government would love to move in on territory that has belonged to the states for over 200 years. It is trying to persuade accreditors to do the dirty work. The states should not let this happen. If Judge Morrow’s case is nominally about the comparability of accreditors, its real impact may be on states that have taken their responsibilities lightly for too long.

Author/s: 
Alan Contreras
Author's email: 
newsroom@insidehighered.com

Alan Contreras works for the State of Oregon; his views do not necessarily reflect those of the state. His blog is The Oregon Review.

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