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?
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.
Robert M. Diamond and Peter B. DeBlois
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.
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.
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.
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.
Constantine W. Curris
Constantine W. Curris is president of the American Association of State Colleges and Universities.
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 documentaryDeclining 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.
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.
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.
Constantine Curris’s Inside Higher Edessay 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.
Elise Scanlon and Roger Williams
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.
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.
Alan Contreras works for the State of Oregon; his views do not necessarily reflect those of the state. His blog is The Oregon Review.
I’m glad I missed the era that demanded Latin and sometimes Greek of those who sought a proper education. I did have to take music, one of whose requirements was the ability to identify the sounds of different musical instruments.
I flailed about helplessly in what sounded like a cacophony of sounds and I remember with particular pain my struggle to single out the Contrabassoon. My teacher brooked no excuses and warned that those who failed to acquire taste and culture inevitably ended up in the cesspools of iniquity. He was evidently right: I learned to identify the sound and I did not descend to the aforementioned cesspools, although I have sometimes wondered what they're like.
My efforts weren't in vain. I learned important lessons about perseverance and emerged from this high school class with an enhanced sense of confidence.
I now know that these qualities could have been honed in a much friendlier but equally demanding way. The same is true with all the many traits we identify with a postsecondary education. Critical thinking, discernment, appreciation of culture … all are characteristics that can be acquired in a variety of ways.
More precisely, there are no orthodoxies in higher education. The qualities of mind that the 1828 Yale Report describes as the “habits of thinking,” which “are to be formed by long continued and close application,” can emerge using content very different from what we consider to be the norm.
When Richard Brodhead (now the president of Duke University) was dean of Yale College in 2004, he put it this way in a commencement address: “By a conservative estimate, the things members of the class of 2004 collectively learned in Yale courses that you have already forgotten is probably equal to the sum of human knowledge gained since the early Renaissance.” He added: “Such inevitable forgetting is not a scandal in education, because the original act of learning taught something more deeply valuable and left a deeper trace: trained deep habits of mind that survived the specific content that was originally attached to them and can then be put to a different use”.
Actually, even content that is retained is increasingly irrelevant in a world where nothing sits still, least of all knowledge. This does not negate the effectiveness of the liberal arts; to the contrary, the liberal arts have proven their worth in creating the transformation of self which is for many, the ultimate goal of higher education. But the liberal arts are not necessarily alone.
Every school has a faculty that follows and fulfills a tradition of centuries of successful teaching and scholarship; this faculty should have the final say in determining the content of the school's offerings. Consistent, of course, with the requirements of each discipline and the standards of quality of the accreditor.
This should leave us with a sense of humility. We may know what we want to do in our own school, but we certainly cannot tell others what to do in theirs. Even if we agree we must provide the same kind of intensity, rigor, and intellectual demand, we cannot require the same educational experiences and the same content.
The actual words, on first glance, seem innocuous. While recognizing that educational goals vary, AACU and CHEA decided that these goals should include “the study of science, social science, the humanities, and the arts."
The flaws appear at once. Selecting the above content areas means ignoring mathematics, behavioral science, computer and information literacy, world religions, the environment, medicine and law, each of which could play a major role in enriching graduates’ lives.
The selection of content also ignores the fact that a package of 120 credits, which must also include the courses needed for the major, provides for a largely superficial understanding in each specified area of general education.
Has anyone looked at the courses that pass for an exposure to science in a general education sense? One prestigious publisher described a text for non-science majors as offering “an alternative route to science literacy for those with an interest in photography art and music." The table of contents is imaginative and well structured. But is the outcome “science literacy"? Seriously now! It is, for most, a dead end. Are we perhaps better off preparing students to aspire to read, to explore, to gather for the rest of their lives? I don't know, and suggest that AACU and CHEA may not know either.
It would seem that the education community should reject this attempt at specifying content with the same respectful vigor as was the case in rejecting the Department of Education's attempt to specify measures of learning outcomes. Content control is unwise, no matter who is proposing it.
In the same sense, we must learn to ignore content mandates by handwringers. There are many good reasons to study foreign languages, but globalism isn't one of them. Unless we are prepared to require college graduates to master six or seven tongues, including two dialects of Chinese.
Nor should global competition serve as an engine of content change. The world is competitive, because American business leaders shipped abroad the technology and industries that our graduates created. There is something very special and unique about American higher education and even after a decade of other countries’ producing more scientists and engineers then we, it is they who copy our ideas and discoveries, not the other way around.
Finally, we should stop reading our own press releases. A recent report breathlessly warned that people who lack a basic understanding of science cannot function in modern society. I am happy to relate that people without any idea of science live happy, fulfilling and satisfied lives. Impressive and numerous are the fortunes made by people who never learned to appreciate Maxwell’s Equations or the Krebs Cycle.
We must recognize and celebrate the immense diversity that defines American higher education. Our colleges are part of a fermenting vat of ideas, and the content, strategy, outcomes, and resource wars that take place in any Faculty Senate would do the Middle East proud. But the key here is that the probing and experimentation, the trial, monitoring and error all take place within the walls of independent institutions.
We have the best system of higher education and a smoothly functioning system of accreditation capable of keeping it that way. Our graduates -- our products -- prove this unequivocally. And until someone proposes a change that is established through scientific standards as safe and effective, we must stand fast in the face of efforts to dictate change, particularly insofar as content is involved.
Bernard Fryshman is an accreditor and a professor of physics.
(Editor’s note: When Congress renewed the Higher Education Act last summer, lawmakers scuttled the National Advisory Committee on Institutional Quality and Integrity. which advises the U.S. secretary of education on accreditation issues. The panel is soon to be reconstituted with new members appointed by the secretary and by leaders in the House and Senate. The column below offers advice to those making the selections, and to their eventual selections.)
Accreditation long preceded the establishment of the U.S. Department of Education, and it is only within the past 50 years that a nexus was established between accreditation and the ability of a postsecondary institution to award federal student financial aid. Congress, in helping needy students attend college, needed to determine which schools are of sufficient quality to participate in programs under Title IV of the Higher Education Act.
Since we do not have a Ministry of Education, this determination required that the Department of Education frequently look over the shoulder of accrediting agencies to read their lists of quality institutions. Accrediting agencies receive no federal support and therefore are, in a very real sense, simply doing the department a favor in sharing these privately determined and privately supported lists.
There is another side to the story, of course. Accrediting agencies are supported by the schools and colleges they accredit, and are anxious to have the department consult their lists, keeping their accredited institutions eligible to participate.
One further element. Since anyone can create an accrediting agency, there must be standards whereby an accrediting agency is determined to be a “reliable authority” -- i.e., accrediting agencies must be recognized by the Secretary of Education. This has spawned a series of regulations surrounding accreditation; every recognized agency must meet a number of requirements, submit appropriate reports, and petition for renewal of recognition every five years.
The Department of Education has developed a great deal of expertise in executing this process, staffed by policy analysts who examine petitions, participate in site visits, draw conclusions, and prepare a report.
All of this plays itself out before the National Advisory Committee on Institutional Quality and Integrity, known as NACIQI. Although this is nominally an advisory committee, the Secretary of Education has usually followed the recommendations of this body, so the individuals sitting on NACIQI have a great deal of influence on the process, and therefore, on all of American higher education.
Suffice it to say that the precarious balance between a government needing to consult the lists of recognized accrediting agencies, and the desire of accrediting agencies to be so recognized, can be greatly nuanced by the nature, knowledge and personal outlooks of the members of NACIQI.
Against this background one must admire the businessmen, legislators, lawyers and financial aid officers who will serve on NACIQI, often armed with little more than their own personal exposure to college, as background to the task of recognizing accrediting agencies.
If past experience is prelude, these will be intelligent, involved, alert and sensitive people. By the time their three year term of office is over, many, perhaps most, will have begun to understand the complexities of accreditation. They will have sensed the nuances of difference between agencies and between fields, understood the nature of peer review, and appreciated the manner in which accreditation enhances quality and leads to change -- and sometimes to improvement.
They will also have begun to appreciate the conditions leading to successful student outcomes and the role of faculty, students and facilities (inputs!) in a college’s successfully completing its mission.
Until these revelations happen, members will know little more than what they were told in Department of Education training sessions. They will know to watch for conflicts of interest, they will be introduced to the government lawyer who will be present to help them navigate the regulations, and they will hear about the conduct and impact of their sessions.
But they won’t get to meet accreditors first hand, and will not have an opportunity to participate in an actual, on site accreditation visit. They will possibly be addressed by people who will cast doubt on peer review, and who claim that expert judgment is not sufficient to establish the quality of programs and institutions. Numbers, they will be told, are needed instead. No matter how irrelevant, incomplete, inconsequential, or purposeless the numbers happen to be.
NACIQI members, at least in the early years, may not be in a position to challenge those assumptions, with questions like: Why were these particular measurements chosen? What have such numbers shown in the past? What improvements to teaching, learning, and policy resulted from their use? Where is evidence of the validity, reliability, and relevance of these measurements?
They probably will not have participated in conversations that questioned the cost/benefit of all this measurement. Nor will they realize that ”accountability” has not been defined, operationally or otherwise, and that the theories that govern public education policy, have rarely, if ever, been subjected to experimentation and test to scientific standards.
Polite, attentive NACIQI members will hear presentations from persuasive speakers who work at the peripheries of higher education, but not in it. They will not hear from the people who teach philosophy and English, art and accounting and engineering to ever increasing numbers of indifferently prepared students.
The Department of Education staff is not at fault: It’s simply that the accreditation agenda has been taken over by those who bring a regulatory mindset to the process. Hence, NACIQI rarely hears words such as “scholarly,” ”deep study,” ”well read,” and “erudite.” They do hear about measures, templates, benchmarks and graduation rates.
As in the past, NACIQI stands to be diverted, unless new members are prepared to defend the academy, to preserve accreditation, and, from the very outset, to challenge, to question, and to examine.
Transparency, in certain frameworks, is a blessing. In accreditation it can convert the site visitor (who benefits from open, frank and revealing interactions) to a regulator (who is reduced to checking off boxes in a rigid grid). “Does transparency have a chilling effect on the site visitor’s report?” is a question that might be appropriate for a NACIQI member.
When hearing about graduation rates, NACIQI might profitably ask whether human interactions (a legislator’s effectiveness, marriage, religious experience), and enterprises (hospitals, jails, retirement communities, colleges and universities) can, indeed, be reduced to numbers.
In a phrase, NACIQI must have people at the ready, from day one, to push back. When they hear talk about student engagement, for example, they must be able to ask questions like: “Does engagement create successful students or are successful students engaged?” And to ask about the experiments, to scientific standard, that support the answers.
NACIQI members must not hesitate to go beyond the surface to seek out the ideas and complexities of accreditation. They should not be intimidated by words like “regulations” and “statutes.” Law as applied to education is a guide, not a barrier or a set of blinders. The Higher Education Act expects that NACIQI members will be people of a variety of backgrounds who are fair and perceptive, with good judgment. NACIQI was not intended to be made up entirely of lawyers.
Education is an analog process that cannot be properly understood or described in terms of discrete digital elements. Even if a qualitative question can be posed, NACIQI members should be prepared for a quantitative response.
At one particularly painful period, accrediting agencies were being asked about the number of applicant schools they rejected. Some members of NACIQI seemed impatient with anything other than a simple numeric answer. Actually, rejection often takes place before a formal application is submitted. The head of the school makes contact, gets to spend a long time with an accreditor, learns enough about the process to know what may be missing, and how to get ready for the future. By the time most schools apply, they’re ready to succeed. A number tells a distorted story, if that!
There are many other such pitfalls; fortunately transcripts of previous NACIQI meetings are readily available, so that anyone can relive some of the highlights (or lowlights) of the past. Attending a conference of the Council for Higher Education Accreditation and/or spending time with accreditors will be invaluable as well.
In the end, the success of NACIQI will depend upon the selection of people who are independent thinkers, knowledgeable, confident, and able to clash in the world of ideas – knowing that every word they utter will be recorded, transcribed, and made available to everyone, everywhere.
Oh yes, by the way, welcome.
Bernard Fryshman is an accreditor and a professor of physics.
Skipping lightly over 350 years of history, we will take the bachelor's degree as the true given of American higher education. Since we do not have a ministry of education, the definition of this degree is imprecise, variable and sometimes even fluid, as independent and autonomous institutions experiment, compete, modify, and adapt.
There are bounds, of course. States and accreditors ensure that level and scope remain consistent with commonly understood and accepted standards. Not fixed, but clearly recognizable.
Lest we be diverted, we will also have to disregard the 100 year chronology of the Carnegie Unit (CU) and focus on its present role.
In the life of a student and in the career of a teacher, four years is a very long time. The term is a more tractable unit, and at a time when colleges all offered similar programs of limited variety, it probably sufficed. Students moved through college in lock step and there was less of a need for a measure of accomplishment on a course by course basis.
That's not true anymore, and the Carnegie Unit has emerged as a means of identifying accomplishment and progress towards a degree. But it is not a mute measure of elapsed time!
Again, the fundamental given of higher education is the totality of the degree. This involves a content path, a variety of teachers, courses building on one another, and it involves strategies developed over 100 or 150 years of experience. The degree structure encourages a slow but steady change in topics and emphasis to enable courses to remain relevant, fresh, and comprehensive. This in turn enables a students to leave college and enter a job, a career, graduate program, or the professions.
The degree encompasses a generally agreed upon quantity of material delivered over four years, and the CU provides an orderly means of breaking down this totality. The degree presents a coherent track, an organized program, and a series of accomplishments, and so too must the CU.
But the Carnegie Unit is intended to be used only in conjunction with other information. Along with curriculum, catalog description, prerequisites, grades, grade point average, and distribution requirements, credit hours can help describe effort, content, and accomplishment.
A credit hour makes sense only when there is a background of distribution requirements, junior or senior level course work, a degree map, and a topic under discussion. Making progress toward a degree depends on all of these characteristics. The three credits earned in Chem I cannot be offered to replace three credits in Accounting. Indeed, poor planning could leave a student with 150 or more credits and no degree!
Everyone within higher education understands the limits of the Carnegie Unit as well as its usefulness as a medium of exchange, or a lingua franca.
The CU enables useful and easy conversations to take place between departments and among schools. Without this shorthand, every interaction would have to encompass consideration of content, rigor, and intellectual challenge. With it, a course map can be agreed upon that lists 40 courses across 10 departments in an easily comprehensible manner, without the details and minutiae of each course.
The allocation of credit hours is neither mindless nor haphazard. Credit hours are determined by the quantity of material a student is expected to acquire, by the rigor, and by the intellectual challenge he or she will face. So too, the time and effort. History, experience and professional judgment all influence the decision to assign a certain number of credit hours to a certain quantity and intensity of material.
There is within each field and each subject area a commonly understood level of prerequisites, skills, and competencies that students must bring to bear in addressing a conventional college course. A norm is established, and vigorously protected. Experts in any given field can usually look at a curriculum, a textbook, or an examination and deduce whether or not the credits being offered for the course are consistent with common usage.
There are variations of course, but within reason. A student presenting three credits in Calculus 101 will find acceptance of these credits virtually everywhere.
There is a cross-fertilization enhancing the norm that occurs as students become faculty members elsewhere, as faculty members change campuses, as students transfer, as textbooks become widely available, as graduates enter professional programs, and as accrediting team visitors travel to different campuses. Comparisons and conversations, as well as experience, all help create a common credit hour currency which speaks volumes in academe, but only haltingly everywhere else.
For the most part, it is a tenured (and largely jaundiced) faculty that jealously protects the integrity of the courses they teach and the degree that they stand for. While there may be grade inflation in some schools, there is rarely credit hour inflation.
A teacher who does not complete his/her course's goals will at one point or another hear from a colleague teaching a more advanced course to students who do not have all the necessary prerequisites. A school whose students do poorly on the bar examination will examine all aspects of the program leading to graduation. This is all part of a vast self-correcting mechanism that protects students and protects the enterprise.
Also important is the textbook marketplace, in which a handful of texts have gained widespread acceptability at least partially because there is an excellent fit with commonly agreed-upon course descriptions and the number of credits assigned.
Difficulty with allocating credit hour appears at the peripheries. Programs that are unusual in their content or structure, weekend programs, accelerated programs, study abroad, experimental and innovative programs all have a common burden: assigning a certain number of credit hours which signifies accomplishment and progress towards a degree, and which are consistent with the norms of higher education.
Courses offered in conventional format are usually associated with a certain quantity of seat time. This, in turn, provides a template against which courses delivered in unfamiliar or unconventional format can be measured. Teachers who have offered the same course on campus and online know what to expect of students at the end of a course and will also be an excellent source of information for assigning a reasonable number of credit hour to the online (or weekend, or study abroad) course.
We do not live in a wild west environment. While there are innovative and nontraditional programs of all kinds, accomplishment is almost invariably measured against existing bricks and mortar classroom time. There are glitches -- but that's all they are. With several million different courses (and assigned Carnegie Units) offered each year, a handful of extravagant claims do not a national emergency make!
In this connection it's worth noting that it is not the role of the accreditor to "give guidance" in matters relating to credit hours. The assignment of credit hours is a faculty's prerogative and responsibility. It is the accreditor's role to ensure that this was done in a reasonable manner consistent with the field and with broad norms. This, of course, is why site visitors are comprised of experts capable of making such judgments.
For completeness, it's important to mention two parties which, by design, use the credit hour as a simple measure of time.
College administration is one. Different courses require different talents, unequal effort ("I fill up two blackboards each period while he plays movies."), dissimilar exam grading burdens.... None of these factors plays a role in determining faculty salaries -- nor should they. The system works, with every faculty member teaching the same number of credit hours.
Government is the other. Student financial aid takes no notice of differences in subject area, level, course title, rigor, challenge, or school reputation. The Department of Education has avoided interfering with the internal workings of postsecondary schools and should continue to do so.
But herein lies a danger, because there is a disconnect between the Department's usage of the CU and the manner in which it is understood and used in higher education. This is the reason we are being asked to define the credit hour as a simple measure, when as noted above, its use and understandings are quite comprehensive and quite complex.
Defining the credit hour will undo the easy exchange, the ready conversations, and the fuzziness which sometime enables us to coexist. It will generate considerations of other indicators which will similarly have to be precisely defined. Will we accelerate students according to their grade point averages? Will a 4.0 student in physics trump a 4.0 in sociology (or vice versa)?
Will teachers be paid according to the number of students they teach? According to their brightness? Their preparation for the course? Will students pay more for a 45 hour program in a philosophy seminar than a survey course?
In our litigious society, we have to keep an eye on the inevitable aggrieved student. Did he fail the course because the teacher did not provide a full 50 minutes of teaching? Does humor constitute a part of the teaching hour? Does the time spent by some other student talking constitute "teaching"? How about the time spent by the teachers walking up and down the aisles watching as students work a computer assignment? And how do we determine that the student has devoted two hours of out-of-class student work? Will we have cameras, beepers, monitors? What constitutes two hours of out-of-class student work?
Defining a credit hour has implications that could conceivably cause great dislocation and misunderstanding in higher education.
If there are concerns, they are rare. And these unusual episodes should not be allowed to drive higher education, just like the rare high school "diploma mill" student should not be permitted to impose on all of higher education another costly, time consuming, and unnecessary burden.
Bernard Fryshman is an accreditor and a professor of physics.