With all the extensive consultation about the Postsecondary Institutions Ratings System during the past 18 months, all the meetings and the many conversations, we know almost nothing about its likely impact on accreditation, our all-important effort by colleges, universities and accrediting organizations working together to define, judge and improve academic quality.
All that the U.S. Department of Education has officially said to date is that the system will “help inform” accreditation -- and we do not know what this means.
This is worrisome. Ratings create, in essence, a federal system of quality review of higher education, with the potential to upend the longstanding tradition of nongovernmental accreditation that has carried out this role for more than 100 years. And establishing the system may mean the end of more than 60 years of accreditation as a partner with government, the reliable authority on educational quality to which Congress and the Education Department have turned.
Accreditation is about judgment of academic quality in the hands of faculty members and academic administrators. It is about the commitment to peer review -- academics reviewing academics yet accountable to the public -- as the preferred, most effective mode of determining quality. It is about leadership for academic judgment when it comes to such factors as curriculum, programs, standards and strategic direction remaining in the hands of the academic community.
In contrast, a ratings system is a path to a government model of quality review in place of the current model of academics as the primary judges of quality.
First introduced by President Obama in August 2013 and turned over to the Education Department for development, the ratings system is on track for implementation in 2015-16. Based on the still incomplete information the department has released to the public, the system is intended to rate (read: judge) colleges and universities based on three indicators: access, affordability and student outcomes. Institutions will be considered either “high performing,” “low performing” or “those in the middle.” Ultimately, the amount of federal student aid funding a college or university receives is intended to be linked to its rating.
A federal ratings system is both an existential and political challenge to accreditation.
First, there is the challenge of a potential shift of ownership of quality. Second, new key actors in judging quality may be emerging. Finally, the relationship between accreditation and the federal government when it comes to quality may be shifting, raising questions about both the gatekeeping role of accreditation in eligibility for federal funds and the agreement about distribution of responsibilities among the parties in the triad -- the federal government, the states and accreditation.
A ratings system means that government owns quality through its indicators and its decisions about what counts as success in meeting the indicators. The indicators replace peer review.
It means that government officials are key actors in judging quality. Officials replace academics. With all respect to the talent and commitment of these officials, they are not hired for their expertise in teaching and learning, developing higher education curriculum, setting academic standards, or conducting academic research. Yet using a ratings system calls for just these skills.
A ratings system means that the relationship between accreditors and the federal government, with the accreditors as dominant with regard to quality judgments, may give way to a lesser role for accreditation, perhaps using performance on the ratings system as a key determinant of eligibility for federal funds -- in addition to accreditation. Or, it is not difficult to envision a scenario in which ratings replace accreditation entirely with regard to institutional eligibility for access to federal financial aid.
We need to know more about what we do not know about the ratings system. Going forward, we will benefit from keeping the following questions in mind as the system -- and its impact on accreditation -- continues to develop.
First, there are questions about the big picture of the ratings system:
- Has a decision been made that the United States, with the single most distinctive system of a government-private sector partnership that maximizes the responsible independence of higher education, is now shifting to the model of government dominance of higher education that typifies most of the rest of the world?
- What reliable information will be available to students and the public through the ratings system that they do not currently have? Will this information be about academic quality, including effective teaching and learning? What is the added value?
Second, there are questions about the impact of the ratings on accredited institutions:
- Are the indicators to serve as the future quality profile of a college or university? Will the three indicators that the system uses -- access, affordability and outcomes -- become the baseline for judging academic quality in the future?
- Will it be up to government to decide what counts as success with regard to the outcomes indicators for a college or university -- graduation, transfer of credit, entry to graduate school and earnings?
- To claim quality, will colleges and universities have to not only provide information about their accredited status, but also their ratings, whether “high performing,” “low performing” or “in the middle”?
- Will institutions be pushed to diminish their investment in accreditation if, ultimately, it is the ratings that matter -- in place of accreditation?
Finally, there are questions about how ratings will affect the day-to-day operation of accrediting organizations and their relationship to the federal government:
- Will accreditors be required to collect/use/take into account the information generated by the ratings system? If so, how is this to influence their decisions about institutions and programs that are currently based on peer review, not ratings?
- Will performance on the ratings system be joined with formal actions of accrediting organizations, with both required for accredited status and thus eligibility of institutions for federal funds -- in contrast to the current system of reliance on the formal actions of accrediting organizations?
- How, if at all, will the ratings system affect the periodic federal review of the 52 accrediting organizations that are currently federally recognized? Will the government review now include the ratings of institutions as part of examination and judgment of an accreditor’s effectiveness?
While we cannot answer many of these questions at this time, we can use them to anticipate what may take place in the approaching reauthorization of the Higher Education Act, with bills expected in spring or summer.
We can use them to identify key developments in the ratings that have the potential to interfere with our efforts to retain peer review and nongovernmental quality review in preference to the ratings system.
Judith S. Eaton is president of the Council for Higher Education Accreditation.
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