Conflicting Interests

The details of accreditation are so arcane and complex that the entire topic is confusing and controversial throughout all of education. When we're immersed in the details of accreditation, it's often exceedingly difficult to see the forest for all the trees. But at the core, accreditation is a very simple concept: Accreditation is a process of self-regulation that exists solely to serve the public interest.

When I say "public interest" I mean the interests of three overlapping but identifiably distinct groups:

• The interests of members of the general public in their own personal health, safety, and economic well-being.
• The interests of government and elected officials at all levels in assuring wise and effective use of taxpayer dollars.
• The consumer interests of students and their families in "getting what they pay for" -- certifications in their chosen fields that genuinely qualify them for employment and for practicing their professions competently and honestly.

Saying that a particular program or degree or institution is "accredited" should and must convey to these publics strong assurance that it meets acceptable minimum standards of quality and integrity.

Aside from the public interest, what other interests are there? Well, there are the interests of the accredited institutions, the interests of existing professional practitioners and their industry groups, and the interests of the accrediting organizations themselves. There is no automatic assurance that these latter interests are always and everywhere consistent with the public interest, so self-regulation (accreditation) necessarily involves consistent and vigilant management of this inherent conflict of interest. It is an inherent conflict because the general public, the government, and the students do not have the technical expertise to set curricular and other educational standards and monitor compliance.

I assume it is generally agreed that it is inconceivable to have anyone other than medical professionals defining the necessary elements and performance standards of medical education. Does the American Medical Association do a good job of protecting the public from fraud and incompetence? Yes, for the most part. But you don't need to talk to very many people to hear cynicism. It is the worst behaviors and the lowest standards of professional competence that create this cynicism, and that taints all doctors as well as the AMA. That is why our standards at the bottom or threshold level are so very important.
I submit to that the bedrock principle and the highest priority for everyone involved in higher education (the institutions, the professional groups, the accrediting organizations, and those who recognize or certify the accreditors) should be and must be to manage these conflicts of interest in ways that are transparent, and that place the public interest ahead of our own several self-interests.

If I could draw an analogy: Think about why the names Enron and WorldCom are so familiar. Publicly owned corporations must open their books to independent accounting firms that are expected to examine them and issue reports assuring the public that acceptable financial reporting and business practices are being followed, and warning the public when they are not. But there is an inherent conflict of interest in this process: The companies being audited are the customers of the accounting firms. This presents an apparent disincentive to look too closely or report too diligently lest the accounting firms lose clients to other firms who are more willing to apply loose standards. Obviously, this conflict was not well-managed by the accounting industry and, as a result, one of the world's largest and previously most respected accounting firms no longer exists, and all U.S. corporations (honest and otherwise) are saddled with an extraordinarily complex and expensive set of new government regulations.

If we don't manage our conflicts well, rest assured one or more of our publics -- the students, the government, or the public at large - will rise up and take care of it for us in ways that will be expensive, burdensome, poorly designed, and counterproductive. That would be in no one's best interest - ironically, not even in the public's best interest.

I must acknowledge that our current system of self-regulation is, by and large, working very well, just as most accounting firms and most companies are, and always have been, honest. Some of us, especially in the public sector of higher education, wonder how much more accountability we could possibly stand, and what, if any, value-added there could possibly be if more were imposed on us. At the University of Wisconsin at Madison, for example, we offer 409 differently named degrees -- 136 majors at the bachelor's level, 156 at the master's level, 109 at the Ph.D. level, and 8 professional degrees, 7 of which carry the term "doctor," a point I will return to later.

By Board of Regents policy, every one of our degree programs gets a thorough review at least every 10 years, so we are conducting about 40 program reviews every year, and one full cycle of reviews involves just about every academic official on campus. These internal reviews carry negligible out-of-pocket cost, but conservatively consume about 20 FTE of people's time annually. We are also required by the legislature to report annually on a long list of performance indicators that includes things like time-to-degree, access and affordability, and graduation rates, among many other things. In addition, about 100 of our degree programs are accredited by 32 different special accreditors and, of course, the entire university is accredited by the North Central Association. One complete cycle of these accreditations costs about $5,000,000 and the equivalent of 35 FTE of year-round effort. (Annualized, it is about $850,000 and 6 FTE).

I mention the costs, not to complain about these reviews as expensive burdens, but to emphasize that we put a great deal of real money and real effort into self-examination and accountability. Far from being a burden, accreditation and self-study reviews form the central core of our institutional strategic planning and quality improvement programs. The major two-year-long self-study we do for our North Central accreditation, in particular, forms the entire basis for the campus strategic plan, priorities, goals, and quality improvements we adopt for the next 10-year period. As such, it is the most important and valuable exercise we undertake in any 10-year period, and we honestly and sincerely attribute most of the improvements we've made in recent decades to things learned in these intensive self-studies. I think all public universities and established private universities could give similar testimony. Having said all this, let me turn, now, to some of the reasons for the growing public cries for better accountability, and some of the problems I think we need to address in our system of self-regulation:

1. Even in the best-performing universities, there is still considerable room for improvement. To mention one high-visibility area, I think it is nothing short of scandalous that, in 2006, the average six-year graduation rate is only around 50 percent nationwide. Either we are doing a disservice to under-prepared or unqualified students by admitting them in the first place, or we are failing perfectly capable students by not giving them the advising and other help they need to graduate. Either way, we are wasting money and human capital inexcusably. Even at universities like mine, where the graduation rate is now 80 percent, if there are peer institutions doing better (and there are), then 80 percent should be considered unacceptably low.

Now, if we were pressured to increase that number quickly to 85 percent or 90 percent and threatened with severe sanctions for failing to do so, we could meet any established goal by lowering our graduation standards, or by fudging our numbers in plausibly defensible ways, or by doing any number of other things that would satisfy our self-interest but fail the public-interest test. Who's to stop us? Well, I submit these are exactly the sorts of conflicts of interest the accrediting organizations should be expected to monitor and resolve in the public interest. The public interest is in a better-educated public, not in superficial compliance with some particular standard. The public relies on accreditors to keep their eye on the right ball. More generally, accrediting organizations are in an excellent -- maybe even unique -- position to identify best practices and transfer them from one colleges to another, improving our entire system of higher education.

2. A second set of problems involves accreditation of substandard or even fraudulent schools and programs. Newspapers have been full of reports of such institutions, many of them operating for years, without necessarily providing a good education to their students. For years, I have listened to the complaints of our deans of education, business, allied health, and some other areas, that "fly-by-night" schools or "motel schools" were competing unfairly with them or giving absurd amounts of credit for impossibly small amounts of work or academic content.

I must admit that I usually dismissed these complaints lightly, telling them they should pay more attention to the quality and value of their own programs, and let free enterprise and competition drive out the low value products. I felt they (our deans) had a conflict of interest, and they wanted someone to enforce a monopoly for them. More recently I have concluded that our deans were, in fact, the only ones paying attention to the public interest. Our schools of education (not the motel schools) are the ones being held responsible for the quality of our K-12 teachers, and they are tired of being told they are turning out an inferior product when shabby but accredited programs are an increasingly large part of the problem. The public school teachers, themselves, have a conflict of interest: They are required to earn continuing education credits from accredited programs, and it is in their interest to satisfy this requirement at the lowest possible cost to themselves. So the quality of the cheapest or quickest credit is of great importance in the public interest, and the only safeguard for that public interest is the vigilance of the accrediting organizations. I lay this problem squarely at the feet of the U.S. Department of Education, the state departments of public instruction, and the education accreditors. They all need to clean up their acts in the public interest.

3. Cost of education. There is currently lots of hand-wringing on the topic of the "cost of education." What is really meant by the hand-wringers is not the cost of education, but the price of education to the students and their families: the fact that tuition rates are inflating at a far faster rate than the CPI. I've made a very important distinction here: the distinction between cost and price. If education were a manufactured product sold to a homogeneous class of customers in a competitive market with multiple providers, then it would be reasonable to assume there is a simple cause-and-effect relationship between cost and price. But that is not the case.

Very few students pay tuition that covers the actual cost of their education. Most students pay far less than the true cost, and some pay far more. In aggregate, the difference is made up by donors (endowment income) at private colleges, and by state taxpayers at public institutions. Since public colleges enroll more than 75 percent of all students, the overall picture -- the price of higher education to students and their parents -- is heavily influenced by what's going on in the public sector, and the picture is not pretty.

In virtually every state in the country, governors and legislators are providing a smaller share of operating funds for higher education than they used to, and partially offsetting the decrease by super-inflationary increases in tuition. They tell themselves this is not hurting higher education because, after all, the resulting tuitions are still much lower than the advertised tuitions at comparable private colleges, so their public institutions are still a "bargain."
This view represents a fundamental misunderstanding of the nature of the "private model." Private institutions do not substitute high tuition for state support. They substitute gifts and endowment income for state support, and discount their tuitions to the tune of nearly 50 percent on the average.

There is a very good reason why there are so few large private universities: It is because very few schools can amass the endowments required to make the private model work. Of the 100 largest postsecondary schools in the country, 92 are public, and ALL of the 25 largest institutions are public. There is no way the private model can be scaled up to educate a significant fraction of all the high school graduates in the country. Substituting privately financed endowments for public taxpayer support nationwide would require aggregate endowments totaling $1.3 trillion, or about six times more than the total of all current endowments of public and private colleges and universities in the country. This simply is not going to happen.

So, to the extent that states are pursuing an impossible dream, they are endangering the health and future of our entire system of higher education. Whose responsibility is it to red-flag this situation? Who is responsible for looking out for the overall health of a large, decentralized, diverse public/private system of higher education? When public (or, for that matter, private) colleges point out the hazards of our current trends, they are vulnerable to charges of self-interest. We are accused of waste and inefficiency, and told that we simply need to tighten our belts and become more businesslike.

I don't know of a single university president who wouldn't welcome additional suggestions for genuinely useful efficiencies that have not already been implemented. Is there a legitimate role here for the U.S. Department of Education and the accrediting organizations? To the extent that accrediting organizations take this seriously and use their vast databases of practices and indicators to disseminate best practices nationwide, we would all be better off. Accreditors should be applauding institutions that are on the leading edge of efficiency, and helping, warning, and eventually penalizing waste and inefficiency, all in the spirit of protecting the public interest. Instead, I'm afraid many accreditors are pushing us in entirely different directions.

4. Another category of problem area is what I will call "protectionism." I have already said there is an inherent conflict of interest in that professional experts must be relied upon to define and control access to the professions. This means that the special accreditors have a special burden to demonstrate that their accreditation standards serve the best interests of the public, and not just the interests of the accredited programs or the profession. Chancellors and provosts get more complaints and see more abuses in this area of accreditation than any other. I will start with a hypothetical and then mention only a small sampling of examples.

In Wisconsin, we are under public and legislative pressure to produce more college-educated citizens -- more bachelor's, master's, and doctoral degrees. Suppose the University of Wisconsin announced next week that any students who completed our 60 credits, or two years, of general education would be awarded a bachelor's degree; that completing two more years in a major would result in a master's degree; and that one year of graduate school would produce a degree entitling the graduate to be called "doctor."

I hope and assume this would be met with outrage. I hope and assume it would result in an uproar among alumni who felt their degrees had been cheapened. I hope and assume it would result in legislative intervention. I even hope and assume it would result in loss of all our accreditations.

That's an extreme example, and most of what I hope and assume would probably happen. But we are already seeing this very phenomenon of degree inflation, and it is being caused by the professions themselves! This is particularly problematic in the health professions, where, it seems, everyone wants to be called "doctor." I have no problem whatsoever with the professional societies and their accreditors telling us what a graduate must know to practice safely and professionally. I have a big problem, though, when they hand us what amounts to a master's-level curriculum and tell us the resulting degree must be called a "doctor of X." This is a transparently self-interested ploy by the profession, and I see no conceivable argument that it is in the public interest. All it does is further confuse an already confusing array of degree names and titles, to no useful purpose.

I asked some of my fellow presidents and chancellors to send me their favorite examples, and I got far too many to include here. Interestingly, and tellingly, most people begged me to hide their institutional identity if I used their examples. I'll let you decide why they might fear being identified. Here are a few:

• A business accreditor insisting that no other business-related courses may be offered by any other school or college on campus.
• An allied health program at the bachelor's level (offered at a branch campus of an integrated system) that had to be discontinued because the accreditors decreed they could only offer programs at the bachelor's level if they also offered programs at the master's level at the same campus.
• An architecture program that was praised for the strength and quality of its curriculum, its graduates, and its placements, and then had its accreditation period halved for a number of trivial resource items such as the sizes of their brand-new drafting tables that had been selected by their star faculty;

Some years ago, the American Bar Association was sanctioned by the U.S. Department of Justice for using accreditation in repeated attempts to drive up faculty salaries in law schools.

The Committee on Institutional Cooperation (the Big Ten universities plus the University of Chicago) publishes a brochure suggesting reasonable standards for special accreditation. The suggested standards are common-sense things that any reasonable person would agree protect the public interest while not unreasonably constraining the institution or holding accredited status hostage for increased resources or status when the existing resources and status are clearly adequate. They focus on results rather than inputs or pathways to those results. Similar guidelines have been adopted by other associations of universities.

So, when I was provost, I routinely handed copies of that brochure to site-visit teams when they started their reviews, saying "Please don't tell me this program needs more faculty, more space, higher salaries, or a different reporting line. Just tell me whether or not they are doing a good job and producing exemplary graduates." Inevitably, or at least more often than not, at the exit interview, I heard "This program has a decades-long record of outstanding performance and exemplary graduates, but their continued accreditation is endangered unless they get (some combination of) more faculty, higher salaries, a higher S&E budget, larger offices, more space in general, greater independence, a different reporting line, their own library, a very specific degree for the chair or director, tenure for (whomever), ... etc." Often, the program was put on some form of notice such as interim review with a return visit to check for such improvements.

Aside: It is perfectly natural for the faculty members of site-visit teams to feel a special bond with the colleagues whose program they are evaluating. It is natural for the evaluators to want to "help" these colleagues in what they perceive as the zero-sum resource struggles that occur everywhere. It is also natural for them to want to enhance the status of programs associated with their field. But, resource considerations should be irrelevant to accreditation status unless the resources being provided are demonstrably below the minimum needed to deliver high-quality education and outcomes. Similarly, "status" considerations are out of place unless the current status or reporting line demonstrably harms the students or the public interest. It is the responsibility of the professional staffs of accrediting organizations to provide faculty evaluators with warnings about conflict of interest and guidelines on ethical conduct of the evaluation.

Let me end with one of the most egregious examples I have yet encountered, and a current one from the University of Wisconsin. Our medical school spent more than a year in serious introspection and strategic planning, with special attention on its role in addressing the national crisis in health care costs. What topic could be more front-and-center in the public interest? The medical school faculty and administration concluded (among other things) that it is in the public interest for medical schools to pay more attention to public health and prevention, and try to reduce the need for acute and expensive interventions after preventable illnesses have occurred. To signal this changed emphasis, they voted to change the name of the school from "The School of Medicine" to "The School of Medicine and Public Health." They simultaneously developed a formal public health track for their M.D. curriculum.

I am told that we cannot have this school accredited as a school of public health because the accreditation organization insists that schools of public health must be headed by deans who are distinct from, and at the same organizational level as, deans of medicine. In particular, deans of public health may not be subordinate to, nor the same as, deans of medicine. This, despite the fact that the whole future of medicine may evolve in the direction of public health emphasis, and this may well be in the best interests of the country. Ironically, to the best of my knowledge, our current dean of medicine is the only M.D. on our faculty who holds a commission as an officer in the Public Health Service.

I have used some extreme examples and maybe some extreme characterizations intentionally. Often, important points of principle are best illuminated by extreme cases and examples. If there are any readers who are not offended by anything here, then I have failed.  I hope everyone was offended by at least one thing. I also hope I am provably wrong about some things I've said. But, most of all, I hope to stimulate a vigorous debate on this vitally important topic.