Accreditation Reform: Dull but Important!

Accreditation is one of those crucially important public-policy issues that suffers from being boring. Long ago, the federal government decided to outsource higher education quality control to private, voluntary accrediting associations, which means that organizations like the Middle States Commission on Higher Education are the only people standing between bad actors and tens of billions of dollars in federal student aid. Federal oversight over accreditors is exercised by the National Advisory Committee on Institutional Quality and Integrity, making NACIQI literally the only point of direct regulatory contact between the federal government and a crucial sector of the economy. But because accreditation is inherently regulatory, process-driven, opaque and obscure, policy discussions tend to be dominated by insiders with a large bias toward the status quo. To his credit, Secretary of Education Arne Duncan asked NACIQI to hold hearings and provide recommendations for improving accreditation in the next reauthorization of the Higher Education Act. I provided testimony to the committee yesterday afternoon. Here are my prepared remarks along with some additional commentary:

Thanks for the opportunity to speak today. I was asked to keep my comments brief  so I will confine my thoughts to two issues. The first is for-profit higher education and the second is student learning.

To be blunt, I believe the accreditors overseen by NACIQI should not be in the business of deciding whether for-profit colleges and universities should have access to the federal Title IV student-aid system. The heart of accreditation is peer review. And the power of peer review does not lie with the creation of or adherence to specific rules and guidelines. Instead, it lies with shared norms and values. That’s all that “peer” means, in the end—persons or organizations with whom one shares fundamental ideas about the nature of things. Peer approval is extremely important and influential, as we see in the scholarly communities that thrive in higher education. But it doesn’t work if those being reviewed are not actually peers.

When the accreditation system as we know it was established, nobody could have conceived of large, nationwide, publicly-traded higher education corporations using information technology to expand at a pace and a scale far beyond what has ever occurred before. I have no objection to people making a profit, or corporations per se. Nobody has any special claims to virtue here. But it’s abundantly clear that these new organizations are different organizations. Not inherently better or worse, but different, operating under a fundamentally different set of incentives.

The existing accreditation system was not designed to accommodate them and it would be a mistake to try to bend or warp its mission to do so. It can’t be done. If accreditors try, they will fail, and they will be blamed for the consequences of that failure. And, by extension, this body will be blamed as well.

So I would call on the accreditation community to relinquish this responsibility and work with for-profit colleges and policymakers to help design a new federal regulatory apparatus responsible for consumer protection and quality control in the for-profit sector. When the federal government provides or guarantees 9 out of every 10 dollars—or more—that flow into the coffers of large private sector corporations, the federal government must play a far stronger role in managing that process than it does today.

Second, student learning. You’re all aware of the dismaying findings reported by Richard Arum and his colleagues who testified this morning. Large numbers of college students are learning little or nothing. And all of the colleges studied were accredited.

I have to admit it’s hard to ignore recent history here, specifically that attempts by the prior administration to leverage federal oversight over accreditation into greater scrutiny of student learning resulted in the abolition of your predecessor body and the reformation of the organization meeting here today. Nonetheless, this new research demonstrates that the student-learning problem must be put squarely on the table. And while I and others have noted on many occasions the shortcomings of accreditation with respect to judging colleges based on learning, it’s important to recognize that arguably no organizations have done more than accreditors over the last decade to advance the cause of collegiate student assessment. This is very difficult work, particularly given institutional diversity and the historic unwillingness of colleges and universities to be subject to any kind of authentic external judgment of student academic progress.

That said, it’s still not good enough. We still have little or no meaningful public transparency of learning results, and by that I mean information that might conceivably be useful to students and parents making choices in the higher-education market or other stakeholders such as lawmakers and institutional trustees.

I belive the way forward here is to separate the student learning challenge from the work of accreditors in acting as gatekeepers to financial aid and enforcers of minimum standards. It would be absolutely impossible to create or enforce for all institutions any kind of common academic standards, either in absolute or growth terms, that accommodated the great diversity of post-secondary institutions while simultaneously adhering to legitimate standards of true higher learning.

Instead, accreditors should develop strong, aspirational standards of knowledge, skills, and progress that only the most successful institutions can claim. This would provide crucial differentiation in a market where monolithic accreditation status is currently serving to obscure differences in quality between institutions rather than distinguish them.

This would in many ways return accreditation to its core strengths in peer-driven standard setting and start to free it from the role as the federal government’s proxy guarantor of quality, a role for which it is increasingly ill-suited. Accreditation is an important part of our higher-learning system—but only when it does what it does best.

See The Chronicle’s coverage here.

Milton Greenberg, emeritus professor of government at American University, also testified on my panel and had many smart and wise observations, including the obvious fact that dividing responsibility for accreditation by geographic region makes far less sense that doing so by mission-defined sector. Barmak Nassirian of AACRAO opened with the incorrect but improved version of Eric Hoffer’s famous quote: “Every great cause begins as a movement, becomes a business, and eventually degenerates into a racket.” Barmak’s proposal to make accreditors financially liable for the cost to the taxpayer of poor accrediting decisions strikes me as very promising way to mitigate racket tendencies. Right now, the highest-profile institutions have very little skin in the accrediting game because their own approval is pro forma. If membership meant substantial financial risk, they’d invest more time and energy in the process.

Several committee members questioned whether for-profit companies should be given different treatment. The president of the University of Phoenix even said (the proceedings were being transcribed so somebody should probably check the exact wording) something along the lines of: My university isn’t focused on making profits. I don’t know what to make of that. Doesn’t he have a strong legal obligation to his shareholders? For-profits operate under incentives that create distinct risks that need to be regulated in distinct ways. That doesn’t mean accreditation oversight over nonprofits is all good—far from it. But the magnitude and character of the risk are not the same.

I also think that decoupling financial-aid gatekeeping and minimum standard setting from the student-learning challenge is key to making any headway there. One of the things that Academically Adrift makes plain is just how much distance there is between where students are when they enter and leave different colleges. Students enrolling as freshmen at elite school have higher CLA scores than students graduating with bachelor’s degrees from open-admissions schools. There is no way to impose one standard on a system that diverse. Value-added during college also varies significantly among institutions. That’s why accreditors should establish several higher levels of distinction above the minimum, levels that for-profits would also be free to shoot for. This is where the power of peer approval would really take hold. Traditional colleges are hyper-aware of their competitor institutions. If other nearby public universities or private colleges achieved the higher standard and your college didn’t, it would create a lot of pressure for self-examination and improvement, even if financial aid eligibility was off the table.