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Transcript of A Seal We Can Trust
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1 Center or American Progress | A Seal We Can Trust
A Seal We Can Trust
How to Improve the College Accreditation System toGuarantee Quality for Students and Taxpayers
Julie Margetta Morgan June 2011
Introduction and summary
Wha makes a college a college? Tese days, anyone wih a decen compuer can designa ancy seal wih a phrase like “Ever o Excel” or “Te Way, he ruh, he Ligh” on i
in Greek or Lain and sar prining diplomas. And wih he adven o online educa-
ion, a college can ourish wihou an ivy-covered campus—or any campus a all. I
he radiional marks o legiimacy—a campus, a library, dozens o sudens wandering
around in “Universiy o” sweashirs—are no reliable, sudens need anoher symbol
o wheher an insiuion is providing a qualiy educaional experience. And he ederal
governmen needs a way o disinguish beween universiies ha will be good sewards
o nancial aid dollars and hose ha will no.
In he pas, sudens, policymakers, and insiuions relied on accrediaion o disin-guish good colleges rom bad ones. Accrediing agencies devise sandards or colleges
and employ a sysem o sel-sudy and peer review o deermine wheher educaional
insiuions are worhy o heir seal o approval. Te radiion o accrediaion was so
esablished as a measure o qualiy ha Congress adoped accrediaion as a precondi-
ion or insiuions seeking o paricipae in ederal suden aid programs.
oday, however, accrediaion is no so revered. Since he 1992 amendmens o he
Higher Educaion Ac here have been rumblings in he policy world ha accrediors are
no he cusodians o college qualiy hey were hough o be. And he recen atenion
o accredied or-pro colleges brings he weigh o evidence o ha asserion, wih
gures like a 9 percen graduaion rae or bachelor’s degree programs a Universiy o
Phoenix and a 69 percen wihdrawal rae a Kaplan colleges.1
I he accrediaion sysem is no broken hen how can such insiuions sill be
operaing wih accredied saus and he access o ederal dollars ha accompanies i?
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Accrediaion is a hugely imporan issue in ederal higher educaion policy. Firs, i is
a gaeway o ederal nancial assisance. Bu i ails o proec he ederal invesmen
hrough boh overinclusiveness and underinclusiveness. Accrediors allow insiuions
wih alarmingly low graduaion raes or high suden loan deaul raes o persis in
accessing nancial aid ye hey ac as a barrier o innovaive educaion providers who do
no he sandard model o “wha a college should look like.”
And second, accrediaion is one o he primary measures o consumer proecion in
higher educaion. Ye when accrediors give heir seal o colleges ha provide litle value,
sudens are unproeced, and hey are led o believe ha hese underperorming insiu-
ions are o equal qualiy o oher colleges and universiies.
Many organizaions weighed in on he accrediaion problem in he pas several years. In
ac, he U.S. Deparmen o Educaion’s Naional Advisory Commitee on Insiuional
Qualiy and Inegriy, or NACIQI—a group charged wih approving accrediing agen-
cies and suggesing changes o he ederal requiremens placed upon hem—convened a
group o expers in February and anoher in June o discuss he uure o accrediaion andhe role o he ederal governmen. Te expers oered some suggesions ha will grealy
improve accrediaion. Bu here are some addiional seps ha should be aken o su-
cienly assess college qualiy and o ensure ha accrediors mee he governmen’s needs.
Tis brie describes wha accrediaion is and he aws inheren in he sysem. I argues
ha he bes accrediaion sysem is one ha recognizes and mees he ederal govern-
men’s needs or boh qualiy assurance and coninuous qualiy improvemen. I is also
one ha borrows rom service qualiy heory by considering how sudens inerac wih
colleges—he processes, heir expecaions, and heir percepions o qualiy—when
evaluaing he overall qualiy o an insiuion.
In he las reauhorizaion o he Higher Educaion Ac, Congress responded o con-
cerns abou he qualiy o higher educaion by charging he Deparmen o Educaion’s
NACIQI commitee wih making recommendaions on how o change he accredia-
ion sysem. We recommend ha NACIQI sugges he ollowing changes o Congress’s
requiremens or accrediing agencies o promoe beter insiuional qualiy or su-
dens and proec axpayers’ invesmens in higher educaion:
• Congress should require ha accrediors clariy he sandards hey employ or
coninuous qualiy improvemen. I should also require ha hese sandards include
measures o increase colleges’ produciviy and decrease he price o educaion o
maximize is value.
• Congress should also require ha accrediors ideniy benchmarks or qualiy
improvemen and measure heir progress a helping colleges improve based upon
hese benchmarks.
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• Congress should require ha accrediors creae more sringen sandards or qualiy
assurance by seting sandards or suden learning oucomes wih clear cuos below
which colleges lose heir accredied saus.
• Congress should require ha accrediors incorporae measures o service qualiy ha
evaluae how sudens respond o he services oered by colleges, including measures
o suden saisacion.
• Congress should require greaer ransparency rom accrediors in he ollowing ways: – Accrediors should make he repors rom heir sie visis available o he public
so ha policymakers can assess wheher oher changes are necessary in he
accrediaion process and so ha ineresed consumers can ake a deeper look a
how colleges measure up. – Accrediors should make available o he public he merics hey use o evaluae
colleges, including suden learning measures, employmen raes, and suden
saisacion raes. Tese should be available separae rom accredior’s repors, and
he Deparmen o Educaion should ensure ha he inormaion is available in aconsumer-riendly orma.
Determinations of quality matter
Deerminaions o qualiy can be enormously helpul o consumers, especially when
hey come rom a proessional amiliar wih a produc or service. Consumers rely on
hese deerminaions when hey do no have he experise or he access necessary o
judge qualiy or hemselves.
For insance, many rely on he American Denal Associaion’s seal o approval when
buying a ube o oohpase. oohpase companies proudly display his seal and eaure
i in heir adverisemens. Consumers do no really know wha i akes o be approved.
All ha maters is ha ADA approval signals a qualiy denal produc, and by relying on
he seal, consumers can res assured ha hey are choosing a oohpase or oohbrush
ha will help and no harm hem. Tey are hen ree o make choices among a variey o
opions based on preerences like avor, whiening power, and dispenser syle.
Now imagine here are many dieren seals o approval he nex ime you buy ooh-
pase. In addiion o he ADA, here’s a CDA, he Council o American Deniss; an
NDA, he Naional Deniss Associaion; and even a CED, he Commitee or Excellen
Denisry. As a consumer, you probably jus wan o buy a ube o oohpase relaively
quickly and eel good ha a proessional approves o i.
Bu do hese organizaions all adhere o he same sandards as he ADA? Or do some use
higher or lower sandards? And should you really be expeced o know he dierence?
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Le’s say you relied on he NDA seal only o nd your eeh riddled wih caviies. Bu he
NDA claims i’s no o blame because i’s no really ineresed in ceriying good ooh-
pases bu in helping he companies i works wih become beter oohpase providers.
Now, i may slightly miigae he circumsances i he NDA, CED, and ADA all le con-
sumers see he echnical repors hey wrie up when evaluaing each brand (assuming
you had he ime o read hem). Bu wha i hey won’ even do ha?
Well, hen hey’d be exacly like higher educaion accrediing agencies.
A leas 10 dieren bodies accredi higher educaion insiuions, and each uses a dier-
en se o sandards o do so. Tough he accrediors give each insiuion heir “seal o
approval,” hey claim o be mosly in he business o coninuous qualiy improvemen
raher han rubber-samping insiuions based upon heir qualiy a any given poin in
ime. And accrediors conduc largely condenial reviews o organizaions ha ocus
on he resources he insiuions possess raher han he learning is sudens achieve.2
Resources can give some indicaion o qualiy, bu hey do no ell he whole sory.
I he above example sounded like a silly sysem or approving oohpases, i’s even sil-
lier or higher educaion because consumers rely on ha sysem, and he ederal govern-
men uses i o deermine which colleges are deserving o is suden aid. Wih so much
riding on accrediaion, policymakers are wondering wheher he sysem can be xed so
ha i works beter or sudens and axpayers.
What is accreditation, anyway?
Accrediaion is a process o evaluaing possecondary insiuions based upon
dened sandards. Possecondary accrediaion’s purposes are qualiy assurance
and qualiy improvemen.
O course, here are many dieren ways o dene qualiy. According o he Council or
Higher Educaion Accrediaion, accrediing agencies base heir judgmens o qualiy
on he insiuion’s mission. For insance, he New England Associaion o Schools and
Colleges’ Commission on Insiuions o Higher Educaion saes ha successul insiu-
ions have clearly dened purposes, he resources o achieve hose purposes, and are in
ac achieving heir saed purposes.3
Tere are echnically wo disinc ypes o accrediaion: program accrediaion and
insiuional accrediaion. Insiuional accrediaion is a general seal o approval or
he enire insiuion, while program-level accrediaion is a more horough review o
he qualiy o a paricular educaional program (e.g., nursing).
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A commitee aliaed wih he leading proessional organizaion in a paricular eld
ypically perorms program-level accrediaion. Mos colleges pursue insiuional
accrediaion and only seek program-level accrediaion when sudens in ha program
mus atend an accredied program as a prerequisie o pracice wihin a eld. For
insance, mos law schools pursue accrediaion by he American Bar Associaion’s
Accrediaion Commitee because atendance a an accredied school is necessary or
admission o he bar in many saes.
Insiuional accrediaion is he precursor or paricipaion in ederal suden loan and
gran programs (more deail on his below). Tis paper ocuses on insiuional accredia-
ion since i is primarily concerned wih he ederal policy implicaions o accrediaion.
How it works
Insiuional accrediing organizaions generally have boh a permanen sa and a
commission or oher decision-making board ha consiss o persons eleced by memberinsiuions. Te decision-making bodies are comprised primarily o academics and
adminisraors rom member insiuions, along wih a ew public represenaives. Te
organizaions se heir own sandards or accrediaion and evaluae insiuions accord-
ing o hese sandards.
Each insiuion mus undergo an iniial evaluaion and subsequen ollow-ups over he
years (ypically every 10 years). Evaluaions consis o a sel-sudy in which an insiu-
ion examines how is programs and operaions measure up o he accredior’s sandards
and a eam visi in which a group o aculy members and adminisraors designaed by
he accrediing agency perorms is own evaluaion o he insiuion hrough inerviewsand documen review.
Why do institutions pursue accreditation?
Accrediaion is a volunary process. So why do colleges and universiies voluneer or
such scruiny? Tere are a ew possible reasons.
Te accrediaion process ceries he qualiy o insiuions or academic programs
and provides guidance o hem on coninuous qualiy improvemen, according o he
Council on Higher Educaion Accrediaion, an organizaion ha promoes he use o
volunary accrediaion in he Unied Saes. Some insiuions may ge accredied o
receive echnical assisance in heir pursui o qualiy. Bu i’s likely ha mos colleges
and universiies pursue accrediaion or he accredior’s seal o approval.
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Ta’s because his rubber samp o qualiy helps insiuions atrac sudens and signals
he legiimacy o an academic degree o poenial employers. A suden’s atendance a
an accredied insiuion also ofen serves as a precursor o urher graduae educaion
or enry ino cerain proessionalized elds. In addiion, accrediaion encourages he
ranser o credi rom one insiuion o anoher. In ac, he original purpose o accredi-
aion was o help colleges deermine he qualiy o he educaion received by sudens
who migraed rom oher colleges or schools.
Finally, accrediaion’s mos angible bene is likely he access i provides o ederal
unding. Accrediors ha are recognized by he U.S. Deparmen o Educaion serve
as gaekeepers o ederal nancial aid programs. Colleges and universiies who seek o
oer ederal suden loans, Pell Grans, or oher aid programs o heir sudens mus be
approved as qualiy insiuions by an accrediing agency.
Standards of accreditation
Tere are many similariies among he sandards employed or accrediaion even
hough each accrediing agency may deermine is own. As menioned earlier, accredi-
ors base heir qualiy decisions on he insiuion’s mission. o be recognized by he
Deparmen o Educaion, however, accrediing agencies mus also mainain sandards
peraining o he ollowing aspecs o possecondary insiuions:
• Success wih suden achievemen• Curricula• Faculy •
Faciliies and equipmen• Fiscal and adminisraive capaciy • Suden suppor services• Recruimen and admissions pracices, academic calendars, caalogs, publicaions,
grading, and adverising• Measures o program lengh and objecives o he degrees or credenials oered• Record o suden complains• Record o compliance wih ile IV responsibiliies4
Accrediing agencies comply wih he ederal requiremens bu say rue o he cenraliy
o he insiuional mission by evaluaing each o hese areas based upon how well he
insiuion’s progress in ha area compors wih is mission.
For insance, he New England Associaion o Schools and Colleges’ sandards or higher
educaion accrediaion include requiremens or organizaion and governance ha begin
wih: “Te insiuion has a sysem o governance ha aciliaes he accomplishmen o
is mission and purposes and suppors insiuional eeciveness and inegriy.”
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And he Wesern Associaion o Schools and Colleges’ sandard on achieving educa-
ional objecives sars wih: “Te insiuion achieves is insiuional purposes and
atains is educaional objecives hrough he core uncions o eaching and learning,
scholarship and creaive aciviy, and suppor or suden learning and success.”5
wo observaions abou he sandards accrediors use are relevan o his paper. Firs,
hough he agencies’ sandards or accrediaion do no dicae any paricular orm or acollege—aside rom he idea ha i should have a aculy and a curriculum—hey leave
much o he discreion o he sie visiors and he accrediaion commission or board.
Te wide discreion means ha accrediing agencies can have inconsisen resuls. Some
colleges nd accrediaion o be an excellen experience ha pushes hem oward
improvemen while ohers recoun sories like NACIQI commitee member Wilred
McClay’s experience in which an accredior inexplicably required his insiuion o
change is mission saemen because i was oo old.6 And colleges ha oer unique or
innovaive educaional programs ha do no look like wha we generally hink o as “col-
lege”—or example, insiuions ha oer courses based upon compeencies, no credihours, or hose ha do no have a physical campus—have diculies wih he accredia-
ion process, possibly because accrediors are more suspicious o educaional delivery
orms ha look so dieren rom he norm.
Te second observaion is ha he sandards accrediors use do no lend hemselves o
brigh-line cuos or a yes/no choice on wheher o accredi a college.
Te mehod accrediors use or deermining qualiy o an insiuion, or wheher ha
insiuion meris he gold seal o accredied saus, is more like he way proessors grade
papers han i is he way a car manuacurer deermines wheher an auomobile is sae odrive. Proessors have crieria or judging erm papers, bu sudens ofen don’ have any
indicaion o wha separaes a D rom an F. And hey may even ge he sneaking suspi-
cion ha acors like randomness or avoriism inuence he oucome. In auomobile
qualiy conrol, however, here are specic sandards a car mus mee, and ailure on a
given sandard amouns o an overall ailure o qualiy. In oher words, here are brigh-
line sandards o wha is accepable and wha is no.
Wih accrediors, we don’ have such brigh lines even when i comes o suden ou-
comes such as graduaion raes or suden learning measures. So, or example, accred-
iing sandards on suden learning say hings such as “Te organizaion provides
evidence o suden learning…ha demonsraes i is ullling is educaional mission”
no “he organizaion ensures ha a leas 60 percen o is sudens achieve prociency
on a widely recognized insrumen ha measures learning.”
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Federal role and funding model
I’s worh elaboraing urher on he connecion beween accrediing agencies and he
ederal governmen because i provides insigh ino how ha connecion migh need o
change. When he ederal governmen began using public money o help low-income
sudens gain access o college, i made he decision o allow sudens o choose where
hey would use his money. Since sudens would be deciding how ederal dollars were
spen, he governmen needed a mechanism or ensuring ha hese axpayer dollars were being handled properly and ha he insiuions o which sudens brough he
money were o sucien qualiy.7
Raher han engaging in is own qualiy review—an arduous, expensive process ha
would pu he governmen in a posiion o commening on curricula—he ederal
governmen urned o accrediing agencies. Accredied saus became a precondiion o
paricipaing in he nancial aid programs conained in ile IV o he Higher Educaion
Ac, including he Pell Gran program and he ederal suden loan program.8
Congress was able o co-op his qualiy assurance sysem essenially or ree since heaccrediaion process exised beore he ederal role in higher educaion. Colleges pay
accrediors an iniial ee o become accredied as well as an annual membership ee
based on insiuional size and ofen pay inermiten ees or services such as special sie
visis.9 Te ederal governmen’s role in his nancing scheme, arguably, is o ensure a
coninual sream o cusomers or he accrediing agencies.
Tis migh sound like a win-win arrangemen. Bu here are a ew aws. Firs, since
he governmen does no conrac direcly wih he accrediors i does no have a clear
mechanism or conrolling wha accrediors do. Insead, Congress insiued a process in
which accrediors mus be approved by he Deparmen o Educaion in order o serveas gaekeepers o suden aid.
And o make maters more complicaed, i incorporaed a commitee ha advises he
deparmen on recogniion o accrediing agencies: he Naional Advisory Commitee
on Insiuional Qualiy and Inegriy. Mos members o he NACIQI commitee are
senior adminisraors a colleges or sae higher educaion sysems. So he mechanism o
conrol over qualiy is asking a group o higher educaion leaders o monior how oher
groups o higher educaion leaders monior he behavior o heir peers’ insiuions.
Anoher problem wih using accrediors o ensure he inegriy o he ederal nancial
aid program is ha he incenives ha guide accrediors’ acions do no align wih
having black-and-whie, high sandards or qualiy. Tere are 17 accrediing agencies
recognized by he Deparmen o Educaion o accredi insiuions.10 Since colleges
have heir choice among agencies—as well as he choice o orm a new agency—here
is litle incenive o be he accredior wih he mos sringen sandards. And accrediing
agencies have heir own ideas abou wha hey should be doing since hey predae heir
adopion as ederal qualiy insurers.
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As he ederal invesmen in nancial aid or higher educaion grew, however, so did he
ederal governmen’s concern ha he accrediaion process did no guaranee qualiy. I
began o place more requiremens on accrediors o ensure ha hey ullled he qualiy
assurance role ha Congress imposed on hem.
For insance, he Deparmen o Educaion requires recognized accrediing agencies o
have a cerain number o public represenaives on heir boards and o submi copies o heir annual repors o he deparmen. Congress and he Deparmen o Educaion also
began pursuing measures o promoe qualiy in higher educaion ouside o accredia-
ion, including gran programs o boos college perormance and innovaion, as well as
more direc regulaion like he new gainul employmen measure ha promoes beter
resuls a career educaion programs.
Is accreditation broken?
I is very common hese days o poin o accrediaion as he source o—and solu-ion o—he ailings o he higher educaion sysem.11 Kevin Carey, policy direcor a
Educaion Secor, poins ou ha he Senae’s recen invesigaion ino raud and abuse a
or-pro colleges amouns o an implici criique o he accrediaion sysem. And many
problems ha arise in higher educaion can be seen as a ailure o qualiy assurance.
Te low graduaion raes a many communiy colleges and or-pro colleges, as well as
some our-year insiuions, are a signal ha he qualiy o he services oered a hose
insiuions may no be up o par. Likewise, he rising suden loan deaul rae a many
or-pro insiuions may be a sign ha sudens are no geting a sucien educaion o
pay heir deb upon graduaion. And Richard Arum and Josipa Roksa’s book Academically Adrif ha analyzes he resuls o he Collegiae Learning Assessmen suggess ha su-
dens are no learning very much a many o our naion’s our-year colleges.12
Aside rom hese indicaors, here are oher reasons o quesion he inegriy o he accred-
iing process. In recen years, i became common or or-pro companies o circumven
he long process o acquiring accrediaion and qualiying or ederal nancial aid by buy-
ing colleges ha already have accrediaion. Accrediors allowed his process o go on rela-
ively unchecked, wih companies buying colleges and increasing heir enrollmen rom
2,000 o 30,000 in a mater o years.13 And some accrediing agencies have been allowing
colleges o award credi ha is inconsisen wih he amoun o ime sudens spen on
learning, resuling in a ederal crackdown on how colleges can dene college credi.14
I’s dicul or ousiders o pinpoin where he aws lie in he accrediaion process
because i occurs largely in secrecy. Agencies believe ha he condenialiy o accredia-
ion is essenial because i encourages colleges o share inormaion abou heir qualiy
ha hey would no oherwise divulge. As a resul, colleges may make heir sel-sudy and
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peer review repors available o he public, bu hey need no do so. Mos publish heir
sel-sudy repors bu do no divulge he peer review sie visi repors compleed by he
accrediing bodies, likely because he peer repors are more criical o he insiuions.
Te sandards accrediors apply when reviewing insiuions are available even hough
heir repors are no public. And hese sandards reveal wo key aws ha policymakers
and academics increasingly poin ou. Firs, he sandards o accrediaion are almosenirely based on inpus, no oucomes. Ta is, accrediaion emphasizes he resources
a college mainains or educaing is sudens wih a lesser ocus on wheher sudens
acually learn anyhing.
One oher aw in accrediaion is very clear: Accrediors do no employ minimum qual-
iy sandards. Tere are no cuos in erms o universiy perormance below which an
insiuion may no access ederal nancial assisance. Many have argued ha o mee
he qualiy assurance ha he ederal governmen requires, accrediors mus deermine
minimum perormance sandards ha a college or universiy mus mee. Tese peror-
mance measures should be sandard across all insiuions in a given secor.
Te nal problem wih accrediaion—a leas rom he ederal perspecive—is is
dual mission o qualiy assurance and coninuous qualiy improvemen. o secure he
invesmen in ederal nancial aid, he governmen needs accrediors o make absolue
decisions abou qualiy and cu o accredied saus when an insiuion alls below
minimum levels. Bu because accrediors avor he qualiy improvemen uncion, hey
end o allow insiuions o mainain heir accredied saus while rying o improve.
Can it be fixed?
I he las NACIQI meeing is any indicaion, he general senimen in he higher
educaion communiy hese days is no wheher accrediaion can be xed, bu how.15
Raher han arguing or a oal overhaul o ederal qualiy assurance, he speakers sug-
gesed ha changes could be made o he accrediaion sysem o help i beter serve
ederal purposes.16 Te major proposals on he able mirror he aws idenied in he
previous secion.
Firs, many argue ha accrediors mus impose oucome-based sandards wih cuos
ha resul in rescinding accredied saus.
Nex, hey asser ha ransparency is key o improving accrediaion. I accrediors make
heir judgmens available o he public, hen boh policymakers and sudens will gain a
beter undersanding o college qualiy.
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Finally, some higher educaion leaders argue ha accrediors need o separae ou he
qualiy assurance uncion rom he coninuous qualiy improvemen uncion. I is no
really clear how his would work. Bu he senimen behind i seems o be ha creaing
a clear division beween he wo uncions would help ensure ha accrediors acually
perorm he qualiy assurance ha he ederal governmen requires o hem.
Each o hese suggesions has he poenial o improve he accrediaion sysem. Buhey require elaboraion. In paricular, any suggesions o x accrediaion should ake
ino accoun wha he ederal governmen wans ou o accrediaion and wha i akes
o evaluae he qualiy o a service.
Te ollowing secions consider hese recommendaions and build upon hem
based on he governmen’s need or a balance beween qualiy assurance and qualiy
improvemen, and proven mehods o service qualiy evaluaion ha can enhance he
accrediaion process.
Protecting the federal investment requires both quality assurance and
quality improvement
I is increasingly imporan o ensure ha ederal dollars or higher educaion are well
spen wih more han $30 billion invesed in he Pell Gran program and over $100 bil-
lion in new ederal suden lending in 2010.17 Proecing he ederal invesmen includes
direcing he money oward colleges and universiies ha provide a leas a minimum
level o qualiy. And he argumen ha accrediors need o emphasize heir role as assur-
ers o minimum qualiy is aking hold.
One migh assume ha here is no need o worry abou how he accrediors are a
qualiy improvemen, as accrediors seem so conden in heir esablished role in his
space. Bu he ederal invesmen is bes proeced i accrediors are good a boh qualiy
assurance and qualiy improvemen.
Te hing is, seting minimum cuos or suden oucomes will help wih qualiy assur-
ance, bu i will no bring abou greaer produciviy or beter value in higher educaion.
In ac, i accrediors rescind accrediaion abruply—even wih some phase-ou pro-
gram—based upon ailure o mee oucomes sandards, hose colleges will lose access
o ederal nancial aid—a virual deah senence or many insiuions ha rely on aid
programs o make college aordable or heir sudens. And since he ederal govern-
men is rying o ge more people hrough college, no ewer, closing colleges is he very
opposie o produciviy.
Insead, he governmen needs accrediors o mainain minimum sandards bu also
ensure ha colleges do no all below hem. In oher words, hey should balance qualiy
assurance wih coninuous qualiy improvemen.
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Accrediors sae ha qualiy improvemen is a undamenal par o heir business model
oday. Bu he sae o American higher educaion indicaes oherwise. I accrediors
were coninuously improving he qualiy o colleges and universiies hen hose insiu-
ions ha have exised or more han a ew years would be o ver y good qualiy—and
many o hem are no.18
So while he accrediaion process should coninue o emphasize qualiy improvemen,ha uncion needs o be beter dened and measured.
Te NACIQI commitee should require ha accrediors se sandards and goals or
coninuous qualiy improvemen ha emphasize increased produciviy and value.
Tey should require ha accrediors se benchmarks or produciviy and value such as
reenion raes, graduaion raes, and cos per degree and develop a plan or helping col-
leges mee hem. Te mechanism or qualiy improvemen should be more han ad hoc
judgmens by an accrediing commitee. Raher, accrediors should ideniy promising
pracices a colleges who measure up o is benchmarks and advise oher insiuions as
o how hese pracices migh be adaped.
Beter inormaion or he public can also be seen as a measure o coninuous qual-
iy improvemen. By providing public inormaion abou how colleges measure up
on suden learning oucomes, cos, suden saisacion, and employmen oucomes,
accrediors can conribue o a higher educaion marke where colleges compee on real
atribues o he services hey oer raher han on repuaion alone.
o ha end, NACIQI should sugges ha Congress require accrediors o make such
measures available o he public on he Deparmen o Educaion’s websie.
Service quality is more than output measures
Te suggesion ha accrediors begin ocusing more on oupu measures is a good sep
in moving away rom viewing higher educaion as a good o be produced and oward
hinking o i as a service.
In manuacuring goods, he resources and processes ha go ino producion can be a
good indicaion o he qualiy o he nal produc. Bu in service indusries, he service
providers’ inpus canno be he primary measure o qualiy. Services are co-consruced
by he provider and he cusomer. Ta is, he cusomer’s inpu ino he process also
deermines he overall qualiy o he oupu. Te cusomer’s (suden’s) inpus include
his or her capabiliies and moivaions as well as his or her expecaions or wha he
nal resul o he service will be.
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Measuring he qualiy o services has always been a ricky business. Bu here are some
general principles. Since boh he cusomer and he service provider co-creae he service,
boh o heir expecaions and percepions o he experience are relevan when measuring
service qualiy. Sel-sudy by he insiuions helps accrediors undersand he college’s
expecaions and is evaluaion o how i measures up. Bu here is no similar expression
o how sudens perceive he qualiy o a college. Accrediors can make more circumspec
judgmens abou he qualiy o he services he college provides by incorporaing bohhe sudens’ and he colleges’ percepions ino he accrediaion evaluaion.
Incorporaing conceps rom he measuremen o service qualiy ino he accredia-
ion process recognizes he ac ha he producion and consumpion o a service are
inseparable. One canno evaluae he services colleges provide wihou considering he
conac beween he college and he suden.
Harvard, or example, is only a high-qualiy educaional insiuion because he services
i oers work well or he majoriy o he sudens i admis. I he suden body o he
local communiy college suddenly supplaned he suden body a Harvard we mighhave very dieren judgmens abou is qualiy because he services i oers would no
work well or is new suden body.
Conclusion and recommendations
Tis paper idenies some undamenal aws in using he accrediing process as a
gaekeeper o ederal nancial aid, including he lack o ransparency, he ocus on
inpus bu no oucomes, and he emphasis on coninuous qualiy improvemen
raher han qualiy assurance.
Te simple xes or hese problems are o increase ransparency, ocus on oucomes, and
emphasize qualiy assurance. Bu simply doing so would no mee he ederal govern-
men’s undamenal need o assure ha i is invesing is nancial aid dollars in qualiy
educaional programs while also producing an increasing number o possecondary
compleers a relaively low cos.
Insead, he paper argues ha accrediaion should be xed by nding a balance beween
qualiy improvemen and qualiy assurance and by incorporaing conceps o service
qualiy ino he assessmen o college qualiy.
Congress asked he Deparmen o Educaion’s NACIQI commitee wih making
recommendaions on how o improve he higher educaion accrediaion process. We
sugges ha NACIQI recommend he ollowing based on our analysis in his brie:
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• Congress should require ha accrediors clariy he sandards hey employ or
coninuous qualiy improvemen. I should also require ha hese sandards include
measures o increase colleges’ produciviy and decrease he price o educaion o
maximize is value.
• Congress should also require ha accrediors ideniy benchmarks or qualiy
improvemen and measure heir progress a helping colleges improve based uponhese benchmarks.
• Congress should require ha accrediors creae more sringen sandards or qualiy
assurance by seting sandards or suden learning oucomes wih clear cuos below
which colleges lose heir accredied saus.
• Congress should require ha accrediors incorporae measures o service qualiy ha
evaluae how sudens respond o he services oered by colleges, including measures
o suden saisacion.
• Congress should require greaer ransparency rom accrediors in he ollowing ways: – Accrediors should make he repors rom heir sie visis available o he public so
ha policymakers can assess wheher oher changes are necessary in he accredia-
ion process, and so ha ineresed consumers can ake a deeper look a how col-
leges measure up. – Accrediors should make available o he public he merics hey use o evaluae
colleges, including suden learning measures, employmen raes, and suden
saisacion raes. Tese should be available separae rom accredior’s repors, and
he Deparmen o Educaion should ensure ha he inormaion is available in a
consumer-riendly orma.
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Endnotes
1 United States Senate Health Education Labor and Pensions Committee, “The Return on the Federal Investment in For-ProtEducation: Debt Without a Diploma” (2010); The Education Trust, “Subprime Opportunity ” (2010).
2 Accreditors are required to make public the reasons or denying or rescinding accreditation rom an institution.
3 New England Association o Schools and Colleges Commission on Institutions o Higher Education, “Standards or Accreditation”(2006), available at http://cihe.neasc.org/downloads/Standards/Standards_or_Accreditation__2006.pd .
4 U.S. Department o Education, “Accreditation in the United States, Subpart B: The Criteria or Recognition,” available at http://
www2.ed.gov/admins/naid/accred/accreditation_pg13.html#RecognitionCriteria.
5 Western Association o Schools and Colleges Accrediting Commission or Senior Colleges and Universities, “Handbook o Accredi-tation” (2008), available at http://www.wascsenior.org/ndit/les/orms/Handbook_o_Accreditation_2008_with_hyperlinks.pd.
6 National Advisory Committee on Institutional Quality and Integrity, Meeting on the Challenges and Perspectives on Quality inHigher Education, 2011, http://www2.ed.gov/about/bdscomm/list/naciqi-dir/appdx-a-naciqieb2011.pd
7 Testimony o Eduardo Ochoa at NACIQI meeting, February 2011.
8 Judith Eaton, “Accreditation and the Federal Future o Higher Education,” available at http://www.aaup.org/AAUP/pubsres/aca-deme/2010/SO/eat/eato.htm
9 Higher Learning Commission, “Dues and Fees Schedule or 2009-2010” (2009); Western Association o Schools and Colleges Ac-crediting Commission or Senior Coll eges and Universities, “Schedule o Dues and Fees 2010-2011” (2010).
10 U.S. Department o Education, “Accreditation in the United States” (2011), available at http://ww w2.ed.gov/admins/naid/accred/accreditation_pg6.html.
11 Kevin Carey, “Asleep at the Seal,”Washington Monthly, March/April 2010, available at http://www.washingtonmonthly.com/ea-
tures/2010/1003.carey.html; Andrew Gillen, Daniel Bennett and Richard Vedder, “The Inmates Running the Asylum?” (2010), avail-able at http://centerorcollegeaordability.org/research/studies/the-inmates-running-the-asylum; Senator Tom Harkin, “HarkinQuestions Accreditation and Oversight o For-Prot Colleges,” Press Release, March 10, 2011, available at http://harkin.senate.gov/press/release.cm?i=331821.
12 Richard Arum and Josipa Roksa, Academically Adrift (Chicago: University o Chicago Press, 2011).
13 Daniel Golden, “How Colleges Are Buying Respect,”Bloomberg Businessweek , March 4, 2010, available at http://www.businessweek.com/magazine/content/10_11/b4170050344129_page_2.htm.
14 Derek Quizon, “College Ofcials Ask Congress to Roll Back New Education Department Rules,” Chronicle of Higher Education, March11, 2011, available at http://chronicle.com/article/Administrators-Ask-Congress-to/126722/.
15 National Advisory Committee on Institutional Quality and Integrity, “Meeting on the Challenges and Perspectives on Quality inHigher Education” (2011).
16 Doug Lederman, “Mend It, Don’t End It,”Inside Higher Ed , February 4, 2011, available at http://www.insidehighered.com/news/2011/02/04/education_department_panel_hears_ideas_about_improving_higher_education_accreditation.
17 U.S. Department o Education, “Student Loans Overview, Fiscal Year 2012 Budget Request” (2011), available at www2.ed.gov/
about/overview/budget/budget12/.../s-loansoverview.pdf; Equal Justice Works, “Pell Grants Survive Federal Budget Process,” US Newsand World Report, April 20, 2011, available at http://www.usnews.com/education/blogs/student-loan-ranger/2011/04/20/pell-grants-survive-federal-budget-process.
18 Arum and Roksa, 2011.