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For almost two years, accrediting organizations and higher-education institutions have been confronted with a most serious challenge from the federal government, one that goes to the heart of the role and purposes of colleges and universities. The government has been taking action that could result in its assuming unprecedented direct control over standards of quality and the academic offerings of higher education.
The central aim of this effort is enhanced accountability, and the key target has been accreditation. Why accreditation? Because it is the primary means by which higher education ensures and improves its quality—and, crucially, accreditation is also subject to federal control.
The challenge is fundamental: Who, going forward, will have the primary authority and responsibility for academic quality?
This is emphatically not just another of those periodic dust-ups between higher education and the government in Washington. At stake is the longstanding “appropriate relationship” that has prevailed among government, accreditors, and institutions. Institutions and accreditors have historically had primary responsibility for academic quality, and the federal government has long relied on their judgment when making policy determinations regarding the use of federal funds. But if the current governmental challenge is successful, the authority for defining and judging academic quality would shift from institutions and accreditors to the federal government. This would amount to a “federalizing” of accreditation and affect all accredited colleges and universities, subjecting them to considerable additional federal control.
The challenge goes beyond a shifting relationship to include substantive matters as well, with the government focused on four accountability issues. Institutions and accreditors are to be accountable to the federal government:
• To provide more evidence of student achievement and institutional performance;
• To make this information easily accessible to the public;
• To develop means to compare institutions or groups of institutions;
• To establish threshold standards for collegiate learning.
What follows is an examination of how the federal accountability challenge is putting pressure on the relationship among institutions, accreditors, and the government. It concludes with five suggestions, designed to preclude the federalizing of accreditation by creating a new relationship based upon (1) federal reaffirmation that institutions and accreditors have primary responsibility for academic quality; (2) a federal commitment to eliminate or overhaul the federal recognition function; (3) a significant ratcheting up of action from institutions on the four accountability issues; (4) a significant strengthening of accreditation practice to address these issues; and (5) the creation of a new and compelling symbol of the responsibility institutions and accreditors have for leadership regarding academic quality, such as a searchable national database designed to help answer questions about academic quality.
A new relationship among the three parties would mean that they would all increase their investment in accountability, but the shift of responsibility to monitor and evaluate academic quality away from institutions and accreditors to the federal government would not occur. Instead, institutions and accreditors would acknowledge and act on the federal demand for enhanced accountability, provided that the government defer to institutional leadership for oversight of academic quality, with accreditors confirming that this oversight has in fact been exercised.
How Did We Get Here?
Throughout much of their history, U.S. colleges and universities and accrediting organizations have enjoyed the benefits of independent—yet accountable—operations, based on their success with both self-governance and self-regulation. Elected or appointed governing boards of colleges and universities, rather than government, were entrusted with ensuring that institutions provided a high-quality education, maintained fiscal integrity, and served the public interest. Colleges and universities have long relied not on government but rather on accreditation’s collegial, yet rigorous, system of self study and peer review to examine and enhance their teaching and learning, research, and service roles.
Accountability and the Role of the Federal Government
At the same time, the federal government has had a significant stake in higher education, driven by many years of financial investment. The Veterans Readjustment Assistance Act (GI Bill) of 1952 launched the current federal investment, providing extensive tuition assistance to returning veterans of World War II. Later in the 1950s, the federal government again turned to higher education for a major expansion of the research needed for scientific and defense purposes. Some 50 years later, this federal funding now amounts to some $100 billion annually—a significant sum to be sure, although not the majority of funding for higher education.
Despite its major expansion of investment, the federal government deliberately chose not to directly regulate collegiate quality. Instead, it turned to higher education’s private, self-regulatory accreditation bodies as “reliable authorities” to assure that federal funds were spent appropriately. In 1952 the U.S. Commissioner of Education began to publish a list of “nationally recognized accrediting agencies” to affirm the quality of the institutions at which veterans used their grant aid.
In agreeing to rely on colleges and universities for high-quality teaching, learning, and research while not regulating them directly, the federal government effectively defined what would come to be considered “the appropriate relationship” among itself, higher education, and accreditors. Institutions and accrediting organizations, working together, assured accountability for academic quality. In extending deference to them, the government was endorsing the value and effectiveness of the U.S. higher-education enterprise, including its traditions of self-governance and self-regulation, with accreditation as a reliable and respected means to assure students and society of its worth.
The relationship was characterized by mutual respect and acknowledgment of mutual gain among equals. The top-down, government-based regulatory or “ministry-of-education” approach to higher education that characterized much of the rest of the world was thought not to be needed in the United States. Subsequently, the United States has been lauded for its absence of a national “system” of higher education and for its restraint with regard to government control, with many observers pointing to the independence of U.S. higher education as a key factor in its national and international preeminence with regard to access and quality.
In 1965, the system of self-governance and self-regulation by institutions and accrediting organizations, accompanied by federal investment in higher education, was codified in the Higher Education Act (HEA). Although there have been a number of changes in the law over time, the fundamental features of the relationship have remained pretty much intact.
Accountability and the Commission on the Future of Higher Education
But recently, a series of forces have been in play that could radically alter that relationship. Of greatest significance, in September 2005, the U.S. Secretary of Education established a Commission on the Future of Higher Education, a body composed of business, policy, and higher-education leaders that scrutinized the accessibility, affordability, and accountability of higher education. The work of the commission has constituted the most significant federal attention to higher education in the past 25 years.
The commission’s final report was issued in September 2006, and its most dramatic impact to date has been on accreditation. It criticized accreditation severely, maintaining that it lacks rigor, fails to adequately address student achievement, does not encourage innovation, fails to provide a basis for comparisons among institutions, and does not effectively inform students and the general public about academic quality.
To remedy these perceived deficiencies, the commission offered several recommendations regarding accreditation. If enacted, the recommendations would call for institutions and accreditors to:
(1) Provide more evidence of student achievement and institutional performance and make this evidence primary when judging academic quality;
(2) Make this information easily understandable and readily accessible to the public;
(3) Develop various means to compare institutions or groups of institutions regarding their success in student achievement and institutional performance.
The commission’s report did not address how the recommendations related to accreditation would be implemented. But the U.S. Department of Education was not content either with issuing the commission’s report and then allowing it to suffer the sit-on-the-shelf fate common to similar documents, or with leaving action on its various recommendations to the higher-education community. Instead, the department chose to force the accountability issue. It is this decision, more than the substance of the commission’s recommendations, that could upend the historic institution-accreditor-government relationship.
The Education Department turned to two readily available federal vehicles or levers for action. The first was the National Advisory Committee on Institutional Quality and Integrity (NACIQI, pronounced NaSEEkee), a body of individuals from outside government established in law to advise the Secretary of Education on the quality and effectiveness of accrediting organizations and recommend which organizations should be federally “recognized.” Over the years, NACIQI members have included business leaders and state officials, as well as college and university presidents and students. Second, the department proposed changes in the regulations that it uses to implement the Higher Education Act’s provisions that focus on federal recognition of accreditors. Because only institutions that are accredited by federally recognized accrediting organizations are eligible for the $100 billion in federal funds dispensed annually to colleges and universities, NACIQI and the accreditation regulations are indeed powerful levers through which the federal government can pressure higher education.
Strengthening the Government’s Role: NACIQI
Until recently, NACIQI’s scrutiny of accrediting organizations proceeded within the framework of the relationship I described above. This included acceptance of the basic values on which accreditation operates: primary emphasis on mission when judging quality, the value of self study and peer review, and respect for institutional autonomy and academic freedom. Accrediting organizations themselves were free to meet the federal standards in various ways. In short, NACIQI accepted the collegial, peer-based features that had been part of accreditation since its inception.
But NACIQI’s scrutiny is quickly becoming a key means by which to implement the commission’s recommendations. Accreditation’s emphasis on institutional mission as the appropriate driver of expectations regarding student achievement is being diminished by insistence that institutions are to be held accountable for at least a core group of “outcome indicators” for purposes of comparisons. These indicators are to be developed by accreditors but must be approved by NACIQI. In addition, and going beyond the commission’s recommendations, deference to the academic judgment of institutions with regard to student achievement is being replaced by a demand that accreditors establish—and that NACIQI approve—minimum standards for student achievement that apply to all institutions reviewed by any accreditor. NACIQI has thus become the primary arena for a discussion of what counts as threshold quality.
Moreover, NACIQI is questioning the adequacy of the information given the public about accreditation reviews. The customary zone of discretion in which accrediting organizations work confidentially with their institutions is giving way, under NACIQI pressure, to demands that institutions and accreditors make public all information generated in the course of a review. There is discussion of accrediting organizations’ providing more information about the reasons for decisions about accredited status, including both the strengths and weaknesses of an institution under review. While NAICIQI has been emphasizing these issues for some time, there is—coincident with the commission’s deliberations, papers, and report—a significant escalation in the pervasiveness and the intensity of NACIQI’s focus on them.
Congress has taken exception to NACIQI's role in implementing the commission’s recommendations in a way that bypasses the reauthorization of the Higher Education Act. At this writing, the Senate Health, Education, Labor, and Pensions Committee has just proposed a Higher Education Act measure that would replace NAICQI with a new body called the Accreditation and Institutional Quality and Integrity Advisory Committee. Its members would be appointed not by the Secretary of Education alone but rather jointly by the department, the Senate, and the House of Representatives.
Strengthening Government Oversight: Negotiated Rulemaking
In addition to ratcheting up accountability expectations through the work of NACIQI, the Education Department also launched a process known as “negotiated rulemaking,” to further expand the regulations to which federally recognized accreditors are subject. “Negotiated rulemaking” convenes individuals from the department and the higher-education community to address changes that the government would like to see in current regulations, in this case those used to implement the federal recognition standards and to review accrediting organizations.
A rulemaking panel was convened in February, approximately five months after the release of the commission’s report in September 2006, and it concluded in June. It was, from the start, a means to reinforce the shift in NACIQI scrutiny and provide the department with stronger and additional tools by which to control accreditation, propelling the conversion of a collegial system answerable to the higher-education community into a regulatory system answerable to the federal government. If the department succeeds in establishing these new rules, the federalizing of accreditation will have advanced dramatically.
The department proposed rule changes that would position accreditors to replace quality indicators developed by colleges and universities with ones developed by accreditors and, most important, subject to federal control through NACIQI. The department also sought changes to enable the federal government to become directly involved in setting academic policy through rules that address, for example, how institutions deal with transfer of credit. Additionally, the rule changes would reaffirm NACIQI’s broad scope of authority vis-à-vis the accrediting organizations that it reviews.
An accrediting organization coming before NACIQI in the future must be prepared for an extensive range of potential recommendations on subjects lying within the committee’s purview—anything from instant renewal of recognition for the maximum of five years to instant removal of recognition. In a shot across the bow, NACIQI has already recommended the removal of recognition for one accrediting agency, the New England Association of Schools and Colleges’ Commission on Technical and Career Institutions. At a prior meeting, the committee also recommended that the American Academy of Liberal Education be constrained from accrediting any additional institutions—a recommendation adopted by the Secretary of Education.
The use of NACIQI and the negotiated-rulemaking process are positioning the department to hold institutions and accreditors directly accountable to the government for academic quality, bypassing the accountability of institutions through their governing boards and accrediting organizations.
The rules of negotiated rulemaking stipulate that a failure to come to consensus on any proposed changes in the regulations means that the department can do what it likes with those regulations. No consensus having been reached in the negotiated-rulemaking process this year for accreditation and despite Congressional warnings that it was overstepping its authority in issuing rules that should be negotiated during the reauthorization of the Higher Education Act, the department at first seemed inclined to proceed with the rule changes. But at this writing, Education Secretary Margaret Spellings has just assured Sen. Lamar Alexander (R-TN) that she will not, at this time, issue rules that put in place department proposals on student learning, transparency, and other issues considered in negotiated rulemaking.
Where Are Higher Education and Accreditation Going?
The Accountability Climate Has Changed
The commission’s report, however troublesome to some institutions and accreditors, does capture a public sentiment that goes well beyond the views of some commission members and the Education Department. It reflects the essentially utilitarian approach to the value of a higher-education degree that is now common in public discourse. Higher education is viewed as an increasingly and unreasonably costly investment in time and money, and earning a credential is seen as a necessary return on this investment, given the growing importance of at least some higher-education degrees for economic success and safety in contemporary society.
The report has also tapped into the strongly held beliefs of at least some government officials and others that higher education, long respected and even revered in this society, must be more accountable to the public. Indeed, our society is in the midst of a substantial escalation of expectations with regard to the accountability of many social institutions, including government itself, charities, churches, and corporations, as well as elementary and secondary education. It is becoming more and more difficult for colleges and universities, which spend hundreds of billions of public and private dollars annually, to argue persuasively that they should not be more accountable for what they produce with those dollars.
Finally, that many of the calls for accountability, as well as proposed solutions, are coming from the federal level is consistent with a growing perception that accountability requires federal intervention.
To the extent that we ignore anxiety over access and price, the escalation of accountability, and growing emphasis on federal solutions, we may imperil our future.
Higher Education’s Response
A great deal has been done by institutions and accreditors in recent years that is innovative, far-sighted, creative, and effective in responding to the call for enhanced accountability. These efforts, while various, share important features: They are voluntary, emphasize institutional mission as the basis for determining quality, engage faculty, and preserve institutional responsibility for academic quality.
Many colleges and universities have been focusing on greater accountability for a number of years. At the same time, all accreditors have embraced standards that call for institutions to report on student-learning outcomes and institutional performance. The accreditors’ approach to learning outcomes varies, from holding institutions responsible both for identifying and collecting evidence of outcomes based on their missions, to accreditors making their own judgments about effectiveness of institutions, to accreditors and institutions voluntarily establishing shared student-achievement expectations. In response to these demands from accreditors and sometimes states, institutional activities have clustered around developing outcomes-based approaches to judging institutional effectiveness, including student achievement in general education and in the majors.
Currently, a number of institutions are working through their national associations to identify indicators about which they will all collect evidence and make comparisons. (See George Kuh’s article in this issue mentioning the Voluntary System of Accountability being fashioned by the National Association of State Universities and Land-Grant Colleges and the American Association of State Colleges and Universities.) Other institutions are using national testing vehicles such as the Collegiate Learning Assessment or the Measure of Academic Proficiency and Progress, or measures of student engagement such as the National Survey of Student Engagement. Still others have created institutional profiles that contain information about performance and other dimensions of institutional operation, which are often shared with the public via Web sites and electronic portfolios.
Accreditors provide extensive information about how accreditation operates and are explicit about their standards, policies, and practices. A number offer aggregated information about the major characteristics of the institutions they accredit (e.g., degree levels, mission, and enrollment). A small number of accreditors require institutions to provide outcomes information to the public, although most do not provide this information themselves, and most do not make the reasons for their accreditation decisions public.
The fourth accountability issue, the establishment of threshold learning standards, has not yet been addressed by institutions or accreditors. Much work remains to be done in this area to sustain, on one hand, the primacy of institutional mission and, on the other, to establish some common expectations of when claims of quality based on mission are less than acceptable.
Strengthening the Community Response to Accountability
However valuable, the current good work by institutions and accreditors concerning accountability is not enough. A significant escalation of effort by institutions and accrediting organizations is essential to address the current accountability challenges—a response that is more robust, immediate, and self-reflective. And more institutions and accreditors need to engage in this work.
More of them could, for instance, develop templates of student achievement and institutional performance. Additional programs that emphasize outcomes, public information, comparability, and threshold quality could be launched. More institutional funds could be invested in special accountability initiatives. Action-based research into student achievement could be ramped up. Search engines could be designed that assist students and the public in obtaining information about institutional performance. More work could be done to share effective practices across the higher-education community.
A more robust response to accountability demands also requires that institutions no longer assert that academic quality is solely a faculty issue and not under the purview of institutional leadership. Faculty engagement and judgment are vital, but the institution’s leaders need to ensure swift action to improve any lackluster results, as well as participate in the development of quality indicators and the determination of what counts as success at, and for, their institutions.
Finally, a more robust response means that institutions and accreditors need to accept that any future claim to leadership regarding academic quality requires more investment in accountability.
A New Relationship
Based on events of the last 20 or so months, what has been considered the appropriate relationship of institutions, accreditors, and the federal government is unlikely to continue. Concerns about access, demands that all social institutions be more accountable, and the growing societal investment in federal solutions to social concerns all require that the relationship be redefined.
Acknowledging that the federal government will continue to place greater emphasis on evidence of student learning and institutional performance, improved information for the public, comparability among institutions, and learning standards, I offer five suggestions as the basis for a new relationship to help preclude the federalizing of accreditation and the ensuing harm to institutions.
• The federal government needs to publicly reaffirm, whether through a resolution or in law, the leadership role of higher education in defining and judging academic quality and to acknowledge the importance and value of self-governance and the self-regulatory system of accreditation.
• The federal government needs to reconsider its oversight role in accreditation, either eliminating that role entirely or overhauling the recognition function. That overhaul would include rethinking how NACIQI members are selected and the extent to which its membership is representative of both higher education and the public, as well as auditing NACIQI’s policies, procedures, and scope of operation. (As mentioned earlier, a Congressional panel has already proposed an alternative to NACIQI that may be included in the reauthorization legislation.)
• Institutions need to accelerate and enrich current efforts to produce evidence of performance, make this evidence available to the public, and accelerate efforts to address comparability among institutions and threshold expectations of quality.
• Accrediting organizations also need to quickly address these accountability issues and strengthen practices needed to ensure that accreditation standards addressing them are rigorously enforced.
• Institutions and accrediting organizations need to join forces to launch a compelling new symbol of their leadership in defining and judging quality in order to demonstrate their commitment to public accountability.
This last might be achieved through institutions and accreditors developing a national, voluntary, searchable database containing the performance profiles of accredited institutions across the country. This database should enable users to obtain immediate and reliable information about the quality of individual colleges or universities, as well as of groups of similar colleges and universities.
These suggestions for a new relationship assume that the federal government will continue to strengthen its expectations concerning accountability. However, these expectations would be met through institutions and accreditors that strengthen their investment in accountability as the warrant for their academic leadership. The federal government would not usurp higher education’s primary responsibility for defining and judging academic quality, but rather would hold institutions and accreditors accountable for doing this work.
Conclusion
For almost two years, a major effort has been under way to redistribute responsibility and authority for ensuring academic quality in higher education among the federal government, accreditors, and institutions. The primary target for these efforts has been the community of federally recognized accrediting organizations, and the primary goal has been to establish federal standards for defining and judging academic quality, a task heretofore left to institutions working with accrediting organizations. If successful, this effort will fundamentally undermine key features of higher education, especially its long history of self-governance and self-regulation.
A newly calibrated relationship is needed, and the five suggestions offered above provide a foundation on which to establish it. It will take courage and creativity on the part of institutions, accreditors, and the federal government, but it will be worth it. If the suggestions are adopted, the strength of American higher education will be sustained, even as its accountability is enriched.
Judith Eaton is president of the Council for Higher Education Accreditation (CHEA). She previously served as chancellor of the Minnesota State Colleges and Universities and president of the Council for Aid to Education, the Community College of Philadelphia, and the Community College of Southern Nevada.