Accreditation: In the Fight of Its Life? by Michael P. Lambert

Executive Director's Diary

Accreditation: In the Fight of Its Life?

By Michael P. Lambert, Executive Director

Winston Churchill once said that he always wanted to serve with a group of committed men engaged in a desperate struggle, the outcome of which was uncertain.

As one who has spent almost four decades making a living as an administrator of an accrediting association, I do not share Churchill's desire, as events swirling around a once staid and unremarkable American institution – non-governmental accreditation- are sweeping all us into uncharted and turbulent seas. And certainly, the outcome of what will happen to accreditation is uncertain.

For the past 3 years, voluntary accreditation, once widely hailed and credited being one of the most effective forces in shaping American higher education into being the most impressive, enviable and admired in the world, has recently come under some unfair criticism from those who do not have even a passing understanding of its true purposes.

Up until recently, accreditation has enjoyed widespread, implicit trust by the public and government as a dependable, reliable indicator of academic quality and ethical practice in an institution or program. It has stood the test of time.

Accreditation remains an enduring American institution, despite the complaints about it, and is a still a pervasive force in higher education. And contrary to what issues forth from its blogging critics, it continues to enjoy the strong support of the academic community, employers, counselors, parents and students looking for an education.

There is a debate taking place about the true role of accreditation in the 21^st Century: should it be an enforcer of laws or a peer evaluator? Is it a cop or a consultant? Are these two roles mutually exclusive?

In DETC, we have worked to find a middle ground between compliance enforcement within the overall construct of peer-group accreditation.

Accreditation is hardly perfect. But overall, most informed observers will agree that is has done its job well. It remains the best idea we have ever come up with to determine what represents quality in education. It is difficult to imagine a better way to determine academic quality, other than through the use of educational expertise on a volunteer basis by qualified and experienced educators themselves. What other system offers a more dependable indicator of academic quality to the public? It needs to be better appreciated for this alone.

Today, some 80 recognized organizations accredit more than 7,000 institutions and 19,000 programs serving more than 24 million students. In 2008-2009, there were 54,823 volunteers available to accrediting organizations, of which 19,423 volunteered their time to accreditation. The financial support allocated to volunteers across all accrediting organizations for this timeframe was $21,195,248. [1]

It is difficult to imagine what the nation could do replace this well-developed system for evaluating academic quality. The professional judgment exercised by this legion of volunteers is an asset that is not quantifiable and one that needs to be preserved.

In recent years, vocal and highly-placed critics are questioning accreditation's value, trustworthiness and effectiveness. It seems everyone is getting into the act of how to reform higher education, and accreditation has become a favorite whipping boy for many reformers.

The critics of accreditation charge that accreditation is:

• An "old boys club," or the proverbial "fox guarding the henhouse";
• Too dependent for its financing on the fees paid by institutions;
• Too secretive in its decision-making;
• Focused on counting the books in the library and not looking at outcomes;
• Conducted too infrequently; and
• Too slow when it comes to eliminating the "bad apple" schools through adverse actions

Overall, the critics of accreditation seem to feel that accreditation needs to step up and do much more in the area of assuring institutional compliance with state and federal regulations, assuring accountability for the billions of tax dollars being expended on higher education and better performing the public about the performance of institutions and the achievement of their students.

As Judith Eaton, President of the Council for Higher Education Accreditation (CHEA) wrote recently in an open letter to Senator Tom Harkin (D-IA):

Government now questions whether simply holding accreditors accountable for having and maintaining standards and process is sufficient. Officials are more and more inclined to decide the standards and processes for which accreditors are accountable. Government is taking a next step to determine the content and level of expectation of accreditation standards and how various accreditation processes are to be carried out. [2]

Senator Richard Durbin (D-IL), a legislator who has been an outspoken critic of accreditation, wrote individual letters to several Federally recognized accrediting associations this past March and said,

Current law affords accrediting agencies wide latitude in determining standards of academic quality and approval processes. But that latitude leaves you with an important responsibility. The federal government, tax payers, and students depend on your judgment and deserve assurances that your agency is weeding out low performing institutions…Looking at the current state of higher education, it is reasonable to question whether accrediting agencies have been living up to this responsibility. [3]

Dr. Eaton has also written, "Accreditation is being shaped by the changing face of higher education, the amount of money at stake, the view of some higher education as essential and the drive for public scrutiny and accountability, all captured by the emerging domination of the relationship with government over accreditation's relationship with institutions. [4]"

The Purposes of Accreditation, Then and Now

In one sense, the critics of accreditation have projected onto the once venerable accreditation enterprise a new, more compliance-centric set of duties and purposes not envisioned by the founders of the movement.

One of CHEA's publications defines accreditation succinctly:

Accreditation in the United States is a means to assure and improve higher education quality, assisting institutions and programs using a set of standards developed by peers. An institution or program that has successfully completed an accreditation review has in place the needed instructional, student support and other services to assist students to achieve their educational goals. [5]

Traditionally, accreditation has been viewed as a voluntary, peer-group process set up to:

• Identify academically sound and high quality institutions and programs for public purposes; and
• Stimulate self-improvement in institutions through continuous self-study and planning.

"Accrediting," writes Judith Eaton, "exists to assure that baseline expectations of academic quality are met and to assist with improving quality….Accreditation is the voice of the professional community speaking to the worth of its efforts." [6]

Since the mid-1080s, new purposes/roles have been added by the stakeholders and users of accreditation, notably by government, including

1. Gatekeeping function: accredit only trustworthy institutions that can then receive public funds;
2. Consumer protection function: handle student complaints; provide data on student performance; publish outcomes data on institutions; and,
3. Compliance function: police compliance with state and federal laws; monitor sales recruiting activities.

How accreditation addresses its critics in the coming years will determine if it will enjoy a robust future.

DETC's Brand of Accreditation

Speaking from the perspective of my nearly 40 years of experience in the field, I have come to cherish the tremendous good accreditation has done to improve institutions and ensure students get the best possible education or training experience. Accreditation's contributions to improving education and protecting the students who study at a distance are beyond priceless.

In our view, any accredited institution delivers on its promises to its students. It behaves with honesty and integrity. It gives value for the tuition it receives. Its students achieve the stated outcomes for a particular program. In a word, it is an institution meriting the public's trust. And when a student graduates from a DETC institution today, he or she is happy. Just about every graduate - 96% was the average for all DETC institutions in 2010 - said that they would recommend their alma mater to a friend for enrollment.

Among the 107 DETC accredited institutions today, some of them founded a century ago, there exists an enthusiastic and unconditional support for the 56 year old DETC accreditation program. Senior DETC institution executives continue to volunteer their precious time to devote to a genuine "peer group" accreditation.

Overall, the DETC membership views our particular brand of accreditation as vital to their own strategic goals, essential to gaining the confidence of students and critical to their institutional improvement efforts.

Perhaps the most salutary perceived benefit, from the DETC institutions' viewpoint, is that accreditation has truly helped transform their institution into a more effective, stable, successful and student-centric organization. Every DETC on-site evaluation generates a fact-filled document called a "Chair's Report," which not only reports on compliance with standards for accreditation, but also contains several dozen suggestions for enhancement and strengthening of curricula, student services, teaching strategies and practical ideas in how to meet stated missions and goals.

As one DETC CEO said, "DETC represents not only an invaluable third party endorsement of our academic quality, it also provides value-adding insights and suggestions for our continuous improvement program. We would be hard pressed to go out and try to buy this insight."

If you were to watch DETC's recently-released history, The American Way to Learn (www.theamericanwaytolearn.com), it is clear the single most transformative and influential force in helping our sector gain public acceptance was the DETC accrediting program, founded in 1955, and going stronger than ever today.

DETC has taken a practical approach to the challenges posed by the critics of accreditation. We believe that we have found a way to address the issues of compliance enforcement with various laws and rules within the framework of voluntary accreditation. The culture within the DETC community is to strive for 100% compliance with all standards, laws and stakeholders' expectations for ethical conduct. It is simply the only way to do business.

Among some of the recent initiative undertaken by DETC to earn the public's trust are these:

• A comprehensive outcomes assessment program, with bright-line metrics customized to specific types of institutions, not a "one size fits all" standard.
• A requirement for every institution to make disclosures of student performance using a common DETC Consumer Information Disclosure form.
• Short, three-year grants of initial accreditation and maximum five year grant thereafter.
• Comprehensive email surveys of random samples of students.
• Specific, prescriptive "rules of the road" for ethical recruiting and marketing.
• A national, prescriptive and consumer friendly tuition refund policy.
• Strengthened accreditation standards for assessing financial condition, outcomes, graduate programs, and dozens of other changes designed to enhance the DETC method of evaluation.
• Stringent, DETC-imposed limits on Title IV participation levels: No more than 75% of institution revenues may come from Federal Student Aid (as compared to 90% for all other for profit institutions); only degree-awarding institutions may participate in the Title IV; and each institution seeking to participate in Title IV must first undergo a special on-site evaluation by DETC to assess its readiness to handle the complex program.

The Spotlights Are Turned On

A number of groups have started to undertake the task of evaluating accreditation and developing various solutions to what they see as accreditation's systematic shortcomings.

The Higher Education Opportunity Act is scheduled to be renewed in 2013, and already interested parties are preparing for new legislation that is sure to be proposed that will have a dramatic impact on the future of non-governmental accreditation.

Key efforts to evaluate, with an eye toward transforming, accreditation that are currently underway include:

The CHEA Initiative: The CHEA Initiative seeks to (1) enhance accountability in accreditation and (2) sustain a balance and distinction between accountability to the federal government and the academic work of accreditation-its focus on institutional mission and independence, peer/professional review and quality improvement. Through the Initiative, CHEA is working to build consensus for action on the issues of greatest importance to the accreditation and higher education communities. [7]

NACIQI: The National Advisory Committee on Institutional Quality and Integrity has undertaken a long term inquiry on accreditation and has invited expert testimony. The inquiry is addressing 3 key issues: 1) Regulatory Burden and Data Needs (the regulatory burden and costs of accreditation to institutions, students and tax payers and the data gathering and reporting required on the part of institutions and accrediting organizations), 2) "The Triad" (federal, state and accreditor entities and their roles, responsibilities and capacities) and 3) Accreditor Scope Alignment and Accountability.

NACIQI is also considering such questions such as:

• Does the current model of accreditation still work given the changing landscape of higher education with new and different providers?
• Does the current regulatory structure foster or impede innovation? What about access?
• How can accreditation and higher education be more responsive to the public in terms of accountability and transparency?
• Are accrediting agencies being over managed by the federal government?

Congress: The Senate Committee on Health, Education, Labor and Pensions has conducted a number of hearings on postsecondary education over the past year, and one of the issues that will be on the agenda for future hearings is the topic of accreditation.

GAO: The Government Accountability Office has conducted a number of studies and issued reports to accreditation as it relates to federal student funding programs, including military tuition assistance and the G.I. Bill programs.

The Wish List

We cannot predict with certainty what the future holds for accreditation, and how it will change-or be changed-to accommodate the interests of all its stakeholders.

From my experience in having worked in the field for many years and having served on hundreds of accrediting teams, and having seen all the good that has been accomplished by accreditors, I respectfully offer these suggestions to those who undertake the job of changing what has worked well for so long.

1. Keep the volunteers in voluntary accreditation. They are invaluable to the academy and the government. It is professional judgment of peers that sets apart America's approach to education assessment. Preserve the ability to exercise unfettered judgment, and avoid the temptation to reduce evaluation of education quality to the level of a State Car Inspection program-complete with 49 quality checkpoints.
2. Be careful with the political arithmetic. Avoid the temptation to impose arbitrary, numeric standards and a homogenizing set of metrics on something that is impossible to measure solely with numbers: a quality education.
3. Do not abandon the "inputs" to quality learning in favor or "outputs." Both are needed for a balanced evaluation. Good schools have good physical plants, great teachers, sterling student services, etc. An institution or program could conceivably produce impressive output numbers but remain a less than quality learning experience for students.
4. Reject the rush to have "federalization" of a non-governmental enterprise. Do not expect voluntary accreditation to do government's "police work." Accreditors do not have any police powers, subpoena powers or the ability to force compliance with regulations.
5. Remember that one of the most important roles of accreditation is to stimulate and encourage institutional self-improvement. To jettison this role would be tragic for students.
6. Find a solution to the vexatious problem of post-adverse decision school litigation. Litigation is unduly expensive, debilitating, and much too lengthy. All accrediting associations might do well to consider mandating binding arbitration for aggrieved institutions, as DETC has attempted to do. [8]
7. Finally, find a way to strike a reasonable balance among the needs of students, the needs of government, and the needs of the institutions. This may require the creation of a wholly new system to make institutions eligible for Federal aid programs while not deforming the historic strengths of accreditation.

American higher education remains the envy of the world. It is clear that accreditation helped the academy get to where it is today. It is also clear that accreditation is being asked to change dramatically to meet evolving needs of the nation for competitive workforce and an educated population.

The challenge now is to find the best ways for accreditation to help America live up to its vaunted reputation as having the best institutions anywhere. I can only hope that in seeking to transform accreditation, we do not deform or destroy it in the process.

As Dr. Kenneth E. Young, former President of the Council on Postsecondary Accreditation, once wrote: "Institutions should recognize that the greatest value of accreditation is perhaps as an evaluative tool, that institutions should use accrediting process as an unequaled opportunity for improving educational quality." [9]

[1] The Council for Higher Education Accreditation, The CHEA 2009 Almanac of External Quality Review, (CHEA, 2009), 4-7.

[2] Judith S. Eaton, "Open Letter to Senator Harkin," Inside Higher Ed, May 16, 2011.

[3] Durbin, Richard J. "Letter to Michael P. Lambert," March 14, 2011

[4] Judith S. Eaton, ed., Reflections on the Future of Accreditation (CHEA, 2011), vii.

[5] The Council for Higher Education Accreditation, The Value of Accreditation, (CHEA, 2010), 1.

[6] Judith S. Eaton, ed., Reflections on the Future of Accreditation (CHEA, 2011), vi.

[7] The Council for Higher Education Accreditation, The CHEA Initiative: Building the Future of Accreditation, (CHEA, 2011), 1.

[8] Michael P. Lambert, "Is Arbitration a Solution?," in Reflections on the Future of Accreditation (CHEA, 2011), 42-47.

[9] Kenneth E. Young, Understanding Accreditation. (Jossey-Bass, Inc., 1983), 35.