[House Hearing, 108 Congress]
[From the U.S. Government Publishing Office]
H.R. 4283, THE COLLEGE ACCESS AND OPPORTUNITY ACT: DOES ACCREDITATION
PROVIDE STUDENTS AND PARENTS ACCOUNTABILITY AND QUALITY?
=======================================================================
HEARING
before the
SUBCOMMITTEE ON 21st CENTURY COMPETITIVENESS
of the
COMMITTEE ON EDUCATION
AND THE WORKFORCE
U.S. HOUSE OF REPRESENTATIVES
ONE HUNDRED EIGHTH CONGRESS
SECOND SESSION
__________
June 22, 2004
__________
Serial No. 108-64
__________
Printed for the use of the Committee on Education and the Workforce
Available via the World Wide Web: http://www.access.gpo.gov/congress/
house
or
Committee address: http://edworkforce.house.gov
______
U.S. GOVERNMENT PRINTING OFFICE
94-366 WASHINGTON : 2004
____________________________________________________________________________
For Sale by the Superintendent of Documents, U.S. Government Printing Office
Internet: bookstore.gpo.gov Phone: toll free (866) 512-1800; (202) 512�091800
Fax: (202) 512�092250 Mail: Stop SSOP, Washington, DC 20402�090001
COMMITTEE ON EDUCATION AND THE WORKFORCE
JOHN A. BOEHNER, Ohio, Chairman
Thomas E. Petri, Wisconsin, Vice George Miller, California
Chairman Dale E. Kildee, Michigan
Cass Ballenger, North Carolina Major R. Owens, New York
Peter Hoekstra, Michigan Donald M. Payne, New Jersey
Howard P. ``Buck'' McKeon, Robert E. Andrews, New Jersey
California Lynn C. Woolsey, California
Michael N. Castle, Delaware Ruben Hinojosa, Texas
Sam Johnson, Texas Carolyn McCarthy, New York
James C. Greenwood, Pennsylvania John F. Tierney, Massachusetts
Charlie Norwood, Georgia Ron Kind, Wisconsin
Fred Upton, Michigan Dennis J. Kucinich, Ohio
Vernon J. Ehlers, Michigan David Wu, Oregon
Jim DeMint, South Carolina Rush D. Holt, New Jersey
Johnny Isakson, Georgia Susan A. Davis, California
Judy Biggert, Illinois Betty McCollum, Minnesota
Todd Russell Platts, Pennsylvania Danny K. Davis, Illinois
Patrick J. Tiberi, Ohio Ed Case, Hawaii
Ric Keller, Florida Raul M. Grijalva, Arizona
Tom Osborne, Nebraska Denise L. Majette, Georgia
Joe Wilson, South Carolina Chris Van Hollen, Maryland
Tom Cole, Oklahoma Tim Ryan, Ohio
Jon C. Porter, Nevada Timothy H. Bishop, New York
John Kline, Minnesota
John R. Carter, Texas
Marilyn N. Musgrave, Colorado
Marsha Blackburn, Tennessee
Phil Gingrey, Georgia
Max Burns, Georgia
Paula Nowakowski, Staff Director
John Lawrence, Minority Staff Director
------
SUBCOMMITTEE ON 21st CENTURY COMPETITIVENESS
HOWARD P. ``BUCK'' McKEON, California, Chairman
Johnny Isakson, Georgia, Vice Dale E. Kildee, Michigan
Chairman John F. Tierney, Massachusetts
John A. Boehner, Ohio Ron Kind, Wisconsin
Thomas E. Petri, Wisconsin David Wu, Oregon
Michael N. Castle, Delaware Rush D. Holt, New Jersey
Sam Johnson, Texas Betty McCollum, Minnesota
Fred Upton, Michigan Carolyn McCarthy, New York
Vernon J. Ehlers, Michigan Chris Van Hollen, Maryland
Patrick J. Tiberi, Ohio Tim Ryan, Ohio
Ric Keller, Florida Major R. Owens, New York
Tom Osborne, Nebraska Donald M. Payne, New Jersey
Tom Cole, Oklahoma Robert E. Andrews, New Jersey
Jon C. Porter, Nevada Ruben Hinojosa, Texas
John R. Carter, Texas George Miller, California, ex
Phil Gingrey, Georgia officio
Max Burns, Georgia
------
C O N T E N T S
----------
Page
Hearing held on June 22, 2004.................................... 1
Statement of Members:
Kildee, Hon. Dale E., Ranking Member, Subcommittee on 21st
Century Competitiveness, Committee on Education and the
Workforce.................................................. 6
McKeon, Hon. Howard P. ``Buck'', Chairman, Subcommittee on
21st Century Competitiveness, Committee on Education and
the Workforce.............................................. 2
Prepared statement of.................................... 4
Porter, Hon. Jon C., a Representative in Congress from the
State of Nevada, prepared statement of..................... 59
Statement of Witnesses:
Crow, Dr. Steven D., Executive Director, Higher Learning
Commission, North Central Association of Colleges and
Schools, Chicago, Illinois................................. 28
Prepared statement of.................................... 30
Davis, Dr. James A., President, Shenandoah University,
Winchester, Virginia....................................... 17
Prepared statement of.................................... 19
Erwin, Dr. T. Dary, Associate Vice President of Academic
Affairs, Assessment and Program Evaluation, James Madison
University, Harrisonburg, Virginia......................... 8
Prepared statement of.................................... 9
Keiser, Dr. Arthur, Immediate Past Chairman, Accrediting
Commission of Career Schools and Colleges of Technology,
Ft. Lauderdale, Florida.................................... 22
Prepared statement of.................................... 23
Martin, Dr. Jerry L., Chairman, American Council of Trustees
and Alumni, Washington, DC................................. 12
Prepared statement of.................................... 14
Additional materials supplied:
Benson, Bruce D., letter submitted for the record............ 62
Council of Recognized National Accrediting Agencies, letter
submitted for the record................................... 63
Distance Education and Training Council, statement submitted
for the record............................................. 61
Wellman, Jane V., Senior Associate, Institute for Higher
Education Policy, letter submitted for the record.......... 60
H.R. 4283, THE COLLEGE ACCESS AND OPPORTUNITY ACT: DOES ACCREDITATION
PROVIDE STUDENTS AND PARENTS ACCOUNTABILITY AND QUALITY
----------
Tuesday, June 22, 2004
U.S. House of Representatives
Subcommittee on 21st Century Competitiveness
Committee on Education and the Workforce
Washington, DC
----------
The Subcommittee met, pursuant to call, at 10:30 a.m., in
room 2175, Rayburn House Office Building, Hon. Howard P.
``Buck'' McKeon [Chairman of the Subcommittee] presiding.
Present: Representatives McKeon, Isakson, Petri, Castle,
Ehlers, Osborne, Burns, Kildee, Tierney, Kind, Wu, Holt,
McCollum, McCarthy, Van Hollen, Payne and Andrews.
Staff Present: Kevin Frank, Professional Staff Member;
Alexa Marrero, Press Secretary; Catharine Meyer, Legislative
Assistant; Alison Ream, Professional Staff Member; Deborah L.
Samantar, Committee Clerk/Intern Coordinator; Kathleen Smith,
Professional Staff Member; Jo-Marie St. Martin, General
Counsel; Ricardo Martinez, Minority Legislative Associate/
Education; Alex Nock, Minority Legislative Associate/Education;
and Joe Novotny, Minority Legislative Assistant/Education.
Chairman McKeon. A quorum being present, the Subcommittee
on 21st Century Competitiveness of the Committee on Education
and the Workforce will come to order. We are holding this
hearing today to hear testimony on H.R. 4283, the College
Access and Opportunity Act: Does Accreditation Provide Parents
and Students Accountability and Quality?
Under Committee Rule 12(b), opening statements are limited
to the Chairman and Ranking Minority Member of the Committee.
Therefore, if other members have statements, they will be
included in the hearing record.
With that, I ask unanimous consent for the hearing record
to remain open 14 days to allow members' statements and other
extraneous material referenced during the hearing to be
submitted into the official hearing record. Without objection,
so ordered.
STATEMENT OF HON. HOWARD P. ``BUCK'' McKEON, CHAIRMAN,
SUBCOMMITTEE ON 21st CENTURY COMPETITIVENESS, COMMITTEE ON
EDUCATION AND THE WORKFORCE
Good morning and thank you for joining us for this very
important hearing today to hear testimony on accountability in
our Nation's higher education system. This is a continuation of
a series of hearings that we have held over the last few weeks
to examine the provisions of H.R. 4283, the College Access and
Opportunity Act, a comprehensive bill to reauthorize the Higher
Education Act that aims to expand college access for millions
of low- and middle-income students striving for higher
education.
I want to start by welcoming our witnesses and thanking
them for joining us today.
For decades, our Nation has used the peer reviewed
accreditation system to ensure the quality of an institution of
higher education. In order to be eligible to participate in
student aid programs under the Higher Education Act,
postsecondary education institutions must be accredited by a
recognized accrediting agency. To be a recognized accrediting
agency, the agency must be designated by the Secretary of
Education.
There are three kinds of accreditation: regional, national
and specialized. Regional and national accreditation are used
to assess overall institution quality and are required for the
participation in the student aid programs. Specialized
accreditation agencies look at specific programs offered by a
postsecondary education, such as medical or business programs,
and are generally not recognized by the Secretary as they do
not provide access to Federal student aid programs for the
institution.
As most of our witnesses on the panel can attest, the
accreditation system serves as the central component in the
Federal Government's effort to hold institutions accountable.
It is widely credited as an invaluable tool for measuring
institutional quality without undue Federal control and Federal
pressure.
At the same time, we also have to recognize that the
accreditation system is not perfect. While it may be a uniquely
American institution, it is also one that--all too often--
perpetrates the status quo on campuses. Even with the
additional requirement made in 1998 that accreditors begin to
focus on student outcomes, the system and the institutions they
accredit could be more effective when it comes to measuring
academic quality. This lackluster focus on academic achievement
and student learning outcomes has resulted in the fact that
more than half of our Nation's students do not graduate in 4
years. Low graduation rates may be compounded by the fact that
parents and students lack the necessary information to
determine whether a particular college or university is a
quality institution or appear to meet the needs of that
particular student. As we enter the 21st century, it is our
duty and obligation to act to drive improvements to the current
system.
Recognizing the importance of accreditation, last month
Chairman John Boehner and I introduced H.R. 4283, the College
Access and Accountability Act, which strengthens the
accreditation system by empowering consumers through sunshine
and transparency. The bill also maintains the important link
between eligibility for Federal student financial aid and
accreditation.
First, the bill gives consumers more information about what
they are getting for their money. Currently, institutions of
higher education are required to report a significant amount of
data to the Federal Government, but the information is not
available to students and parents in an easy-to-use and readily
available format. The bill will require the Department of
Education to use the information already reported by colleges
and universities to the Federal Government to create a College
Consumer Profile and make this information available to the
public in a readable, understandable, consistent and clear
format so students and families can make more informed choices
in the college marketplace. The bill will also clarify that
student academic achievement must be measured against the
institution's own desired learning outcomes, not federally
established guidelines.
Second, the bill would make accreditation agencies more
accountable by making information more public. Under current
law, accrediting agencies provide limited information about
their activities to the public and only upon request. The bill
will make the accreditation process more transparent by giving
students, parents and the general public more access to such
information, helping to ensure they know what they are getting
for their money.
Finally, among other provisions, the bill would make
transfer of credit policies public. With recent data showing
more than 50 percent of students attend multiple institutions
of higher education, it has become increasingly important for
students to have the flexibility to transfer their credits from
one school to another. To ease the burden of transfer for
students and ensure fairness to the process, the bill will
simply require institutions to have a transfer of credit policy
and make that policy public and follow that policy.
The College Access and Accountability Act also ensures
credits are not unfairly and arbitrarily denied based solely on
the accreditor of a college or university where the credits
being transferred were earned, so long as the accreditor is
recognized by the U.S. Secretary of Education.
Since the introduction of H.R. 4283, many of the changes
that the Chairman and I would make to the accreditation system
in the bill have been criticized by members of the higher
education community and have been portrayed as Federalizing
higher education. These same groups have argued as a result of
this bill that the Federal Government would be responsible for
making academic decisions that should remain in the purview of
those on college campuses. I am sure you will hear a little bit
about that today.
While I certainly respect those in the community who are
making such arguments, I wholeheartedly disagree.
I believe it is absolutely critical that institutions of
higher education provide better information to parents and
students so they can make informed decisions about what college
or university will meet their individual needs. Even though
institutions are required to report completion, graduation and
placement rates to ensure that students are prepared for entry
into the workplace, most of this information is not readily
available to the public. By creating a College Consumer
Profile, focusing on student learning outcomes and requiring
accreditors to make some of their reports public, we will
ensure that these consumers are able to accurately measure the
academic quality of a postsecondary education; and we do so
with no additional reporting requirements.
In addition, I do not believe that Congress should continue
to support institutional policies such as blanket denials of
transfer credits that are unfair to students. We should stop
this practice even though it may upset a few in the traditional
higher education community who believe there should be no
Federal role on what occurs on college campuses--except when it
comes to dramatically increasing Federal student and research
aid. The denial of credit transfers inhibits student completion
and drives up the cost of postsecondary education to everyone
involved by forcing students to take and pay for the same
course twice.
It is important to remember that the bill even contains
language specifying that institutions retain all rights to deny
credits based on the criteria they themselves established. In
addition, some in the higher education community are already
voluntarily implementing these provisions.
I believe that the American higher education system is the
best in the world. But I believe that we can still improve.
Over the last few years, other countries have invested heavily
in their higher education systems and are catching up to us in
the quality of their workforce. We cannot rest on our laurels.
By enacting these much-needed provisions, the bill will ensure
that our higher education system is strengthened and that
accreditors continue to play a key role in providing access to
quality higher education for American students.
As Congress continues the process of renewing and
reauthorizing the Higher Education Act and builds on efforts to
bridge the education divide for America's low- and middle-
income students, it is important for us to continue this dialog
and continue our work on evaluating ways to improve the
accreditation system and build on the academic excellence of
students.
Thank you again for joining us here today to discuss this
important topic, and we look forward to hearing your testimony.
I now yield to Congressman Kildee for his opening
statement.
[The prepared statement of Chairman McKeon follows:]
Statement of Hon. Howard P. ``Buck'' McKeon, Chairman, Subcommittee on
21st Century Competitiveness, Committee on Education and the Workforce
Good morning and thank you for joining us for this very important
hearing today to hear testimony on accountability in our nation's
higher education system. This is a continuation of the series of
hearings that we have held over the last few weeks to examine the
provisions of H.R. 4283, the College Access and Opportunity Act, a
comprehensive bill to reauthorize the Higher Education Act that aims to
expand college access for millions of low and middle-income students
striving for a higher education.
I want to start by welcoming our witnesses and thanking them for
joining us here today.
For decades, our nation has used the peer reviewed accreditation
system to ensure the quality of an institution of higher education. In
order to be eligible to participate in student aid programs under the
Higher Education Act, postsecondary institutions must be accredited by
a recognized accrediting agency. To be a recognized accrediting agency,
the agency must be designated by the Secretary of Education.
There are three kinds of accreditation: regional, national and
specialized. Regional and national accreditation are used to assess
overall institutional quality and are required for participation in the
student aid programs. Specialized accreditation agencies look at
specific programs offered by a postsecondary institution, such as
medical or business programs, and are generally not recognized by the
Secretary as they do not provide access to federal student aid programs
for the institution.
As most of our witnesses on the panel can attest, the accreditation
system serves as the central component in the federal government's
effort to hold institutions accountable. It is widely credited as an
invaluable tool for measuring institutional quality without undue
federal control and federal pressure.
At the same time, we also have to recognize that the accreditation
system is not perfect. While it may be a ``uniquely American
institution,'' it is also one that--all too often--perpetuates the
status quo on campuses. Even with the additional requirement made in
1998 that accreditors begin to focus on student outcomes, the system
and the institutions they accredit could be more effective when it
comes to measuring academic quality. This lackluster focus on academic
achievement and student learning outcomes has resulted in the fact that
more than half of our nation's students do not graduate in four years.
Low graduation rates may be compounded by the fact that parents and
students lack the necessary information to determine whether a
particular college or university is a quality institution or appear to
meet the needs of that particular student.
As we enter the 21st Century, it is our duty and obligation to act
drive improvements to the current system.
Recognizing the importance of accreditation, last month Chairman
John Boehner and I introduced H.R. 4283, the College Access and
Opportunity Act, which strengthens the accreditation system by
empowering consumers through ``sunshine'' and transparency. The bill
also maintains the important link between eligibility for federal
student aid and accreditation.
First, the bill gives consumers more information about what they're
getting for their money. Currently, institutions of higher education
are required to report a significant amount of data to the federal
government, but the information is not available to students and
parents in an easy-to-use and readily available format. The bill will
require the Department of Education to use the information already
reported by colleges and universities to the federal government to
create a ``College Consumer Profile'' and make this information
available to the public in a readable, understandable, consistent and
clear format so students and families can make more informed choices in
the college marketplace. The bill will also clarify that student
academic achievement must be measured against the institution's own
desired learning outcomes, not federally established guidelines.
Second, the bill would make accreditation agencies more accountable
by making information more public. Under current law, accrediting
agencies provide limited information about their activities to the
public, and only upon request. The bill will make the accreditation
process more transparent by giving students, parents and the general
public more direct access to such information, helping to ensure they
know what they're getting for their money.
Finally, among other provisions, the bill would make transfer of
credit policies public. With recent data showing more than 50 percent
of students attend multiple institutions of higher education, it has
become increasingly important for students to have the flexibility to
transfer their credits from one school to another. To ease the burden
of transfer for students and ensure fairness to the process, the bill
will simply require institutions to have a transfer of credit policy,
make that policy public and follow that policy. The College Access and
Opportunity Act also ensures credits are not unfairly and arbitrarily
denied based solely on the accreditor of a college or university where
the credits being transferred were earned, so long as the accreditor is
recognized by the U.S. Secretary of Education.
Since the introduction of H.R. 4283, many of the changes that the
Chairman and I would make to the accreditation system in the bill have
been criticized by members of the higher education community and have
been portrayed as federalizing higher education. These same groups have
argued as a result of this bill that the federal government would be
responsible for making academic decisions that should remain the
purview of those on college campuses. I am sure that you will hear a
little bit about that today.
While I certainly respect those in the community who are making
such arguments, I wholeheartedly disagree.
I believe that it is absolutely critical that institutions of
higher education provide better information to parents and students so
they can make informed decisions on what college or university will
meet their individual needs. Even though institutions are required to
report completion, graduation and placement rates to ensure that
students are prepared for entry into the workforce, most of this
information is not readily available to the public. By creating a
College Consumer Profile, focusing on student learning outcomes and
requiring accreditors to make some of their reports public, we will
ensure that these consumers are able to accurately measure the academic
quality of a postsecondary education. And we do so with no additional
reporting requirements.
In addition, I do not believe that Congress should continue to
support institutional policies, such as blanket denials of transfer
credits that are unfair to students. We should stop this practice even
though it may upset a few in the traditional higher education community
who believe that there should be no federal role in what occurs on
college campuses--except when it comes to dramatically increasing
federal student and research aid. The denial of credit transfers
inhibits student completion and drives up the cost of postsecondary
education to everyone involved by forcing students to take and pay for
the same course twice.
It is important to remember that the bill even contains language
specifying that institutions retain all rights to deny credits based on
the criteria they themselves establish. In addition, some in the higher
education community are already voluntarily implementing these
provisions.
I believe that the American higher education system is the best in
the world. But, I believe that we can still improve. Over the last few
years, other countries have invested heavily into their higher
education systems and are catching up to us in the quality of their
workforce. We can not rest on our laurels.
By enacting these much needed provisions, the bill will ensure that
our higher education system is strengthened and that accreditors
continue to play a key role in providing access to quality higher
education for American students.
As Congress continues the process of renewing and reauthorizing the
Higher Education Act and builds on efforts to bridge the educational
divide for America's low and middle-income students, it is important
for us to continue this dialogue and continue our work on evaluating
ways to improve the accreditation system and build on the academic
excellence of students.
Thank you again for joining us here to discuss this important topic
and we look forward to your testimony.
______
STATEMENT OF HON. DALE E. KILDEE, RANKING MEMBER, SUBCOMMITTEE
ON 21st CENTURY COMPETITIVENESS, COMMITTEE ON EDUCATION AND THE
WORKFORCE
Mr. Kildee. Thank you, Mr. Chairman. Good morning.
I join my good friend, Chairman McKeon, in welcoming the
witnesses before the Committee today.
Mr. Chairman, we have assembled a very distinguished group,
both individually and collectively; and I am sure we will
benefit a great deal from their testimony.
Accreditation is not a topic that many of us focus on in
higher education, but it is something that we touched in 1998
and are now looking at again. This Committee is often occupied
over what interest loans will be charged students or how much
grant aid will be provided to them and how will it be provided.
While these topics generate the headlines, accreditation is a
critically important element in ensuring that we have high-
quality institutions of higher education.
Strong accreditation agencies that are reasonably
transparent in their operation are one of the keys to ensuring
integrity and viability among institutions and the students
they serve. Without accreditation, we would lose an important
element of the governance triad, affecting the operation of
institutions of higher education.
The bill recently introduced by Chairmen McKeon and Boehner
makes a number of changes in the role that accreditors play. In
order for accreditation to be a positive force for improvement
in higher education, accreditors need to focus on improving
quality at institutions. We should not take away from this
focus by requiring accreditors to publicize information on
institutions. Instead, this is a more appropriate role I
believe for the U.S. Department of Education and State
Departments of Education. H.R. 4283 attempts also to ensure the
public has a better understanding of how accreditation works
and the results of the accreditation process.
I am interested in hearing more from our witnesses about
public disclosure. Overall, I think it benefits us to provide
information to the public on how accreditation works and the
results of the accreditation process. However, I am mindful
about the concerns of institutions that disclosure may lead to
unfair comparisons with other schools. The trick here is to
find the right balance. We need to work to do so. The overall
key to ensuring accreditation remains a positive force in
higher education and ensures its independence and integrity of
the process. The moment that Congress or the executive branch
begins to affect this independence, I believe this integrity
will be compromised.
I look forward to continuing our discussions on this matter
and yield back the balance of my time to my Chairman and
friend, Mr. McKeon.
Chairman McKeon. Thank you, Mr. Kildee.
We have a very distinguished panel of witnesses, as Mr.
Kildee has said; and we are going to introduce them.
First, we have Dr. Thomas Erwin. Dr. Erwin currently serves
as Associate Vice President of Academic Affairs for Assessment
and Program Evaluation at James Madison University. In this
capacity, Dr. Erwin coordinates the assessment of students'
learning and development, overseeing the assessment activities
of the center, including the collection and analysis and
reporting of assessment information for learning and
development.
Next, we have Dr. Jerry Martin. Dr. Martin currently serves
as Chairman for the American Council of Trustees and Alumni.
From 1988 to 1995, Dr. Martin held senior positions at the
National Endowment For the Humanities, including Acting
Chairman in 1993. Prior to joining the NEH, Dr. Martin served
as Chairman of the Philosophy Department at the University of
Colorado at Boulder.
Next, we have Dr. James Davis. Dr. Davis has served as
President of Shenandoah University in Winchester, Virginia,
since 1982. Before joining Shenandoah University, Dr. Davis
held numerous faculty and administrative positions at Ferrum
College located in Ferrum, Virginia. Dr. Davis has also served
as an elected member of the Commission of Colleges of the
Southern Association of Colleges and Schools for 6 years.
Then, Dr. Arthur Keiser. Dr. Keiser is the Immediate Past
Chairman of the Accrediting Commission of Career Schools and
Colleges of Technology, a national accrediting agency whose
goal is to maintain educational quality in the career schools
and colleges it accredits by striving to ensure academic
excellence and ethical practices. Dr. Keiser also serves as
Chancellor and CEO of the Keiser Collegiate System.
And, finally, Dr. Steven Crow. Dr. Crow currently serves as
Executive Director of the Higher Learning Commission for the
North Central Association of Colleges and Schools where he
provides leadership to the Commission and its membership of 986
institutions. Previously Dr. Crow served on the Commission's
Critical Issues Committee and also served on the Commission's
Committee on Organizational Effectiveness and Future
Directions.
Before beginning, let me explain the system in front of
you. We have a timing system that comes on, a green light when
your time begins. When you have a minute left to go, it goes to
the yellow and then finally to the red, which means your time
is up. And if you haven't finished at that time, would you wrap
up.
Your full testimonies will be included in the record, and
we would like you to feel free to explain to us what you are
here to explain to us today.
Chairman McKeon. We will begin with Dr. Erwin.
STATEMENT OF DR. T. DARY ERWIN, ASSOCIATE VICE PRESIDENT OF
ACADEMIC AFFAIRS FOR ASSESSMENT AND PROGRAM EVALUATION, JAMES
MADISON UNIVERSITY, HARRISONBURG, VIRGINIA
Dr. Erwin. Thank you, Mr. Chairman.
James Madison University is a public institution of about
16,000 students in the Commonwealth of Virginia. Our Assessment
Center is probably one of the largest campus-based assessment
centers devoted to collegiate assessment in the United States.
We focus in three areas. We assess in general education,
which is the course work that all students take, regardless of
major. We also assess in the major, and we assess out-of-class
activities and student affairs. Some of the areas of general
education that we measure are information literacy and
technology, written communication, oral communication,
scientific reasoning and quantitative reasoning. We use the
assessment data to improve our curriculum, to improve our
degree requirements and to evaluate new instructional delivery
approaches, such as maybe a software package.
From the national picture, higher education institutions
have been slow and reluctant to systemically measure student
learning in general education in a programmatic way. It is a
very hard job, and it is threatening the faculty and presidents
alike and involves much complexity.
In terms of the State picture, most States have some kind
of policy or mandate about assessment in place. These policies
vary from Statewide tests such as Georgia's Regents Exam to the
majority of institutions where the States allow the
institutions to assess in their own way.
As you know, many States have funded their institutions
based on head counts or enrollments. But in the past few years
States have been experimenting linking quality with funding,
sometimes called performance funding and performance budgeting.
States have been struggling with doing this because they have
been struggling with how to define and measure college quality.
Often States will only collect what data are available, which
many times are things like outputs, which, as you know, does
not necessarily indicate what and how well students have
learned at a particular institution.
The current state of assessment practice still makes it
improbable to generalize beyond a single institution and in
many cases difficult to generalize within a single institution.
From the consumer point of view, as you have noted, the
consumers are hungry for information about college quality.
Perspective students, their parents, employers, for example,
desire information about what students acquire from a
particular institution and they want to know what the value of
the knowledge and skills is. All you have to do is look to the
rankings of institutions and see how popular those are. But if
you look to see how those are determined, if you use the U.S.
News and World Report as an example, they are largely
determined by institutional reputation, the amount of resources
deployed toward the curriculum, outputs, admissions selectivity
and alumni giving rates, nothing about achievement in student
learning.
In terms of accrediting organizations, as you are aware,
whether they are regional or professional, they are
increasingly emphasizing assessment of student learning. In my
opinion, the accrediting organization's role has been a very
positive influence, helping institutions focus on educational
results and not just description of resources, which is the way
it was in the past.
In terms of the Federal role, you may consider whether an
increased role would be beneficial; and I think it would. The
U.S. Department of Education's involvement in K through 12 has
been very positive, but there still seems to be a void at the
collegiate level when it comes to the assessment of collegiate
learning. The issues are so complex and the job is so big that
a single State can feel overwhelmed.
Regarding your H.R. 4283, in section 1025, I applaud
generally what you have in that section. I would offer one
suggestion that you consider that you might add. What you have
in the report is you have a review of current practice. What I
would suggest that you put in there is ask that Committee to
put in some action-oriented steps that would move us beyond
where we are today. I am not advocating a particular assessment
instrument, nor am I advocating that you dictate what we
measure. I use the analogy of the packages on foods, the labels
on the sides, the ingredients. Wouldn't it be helpful to know
what knowledge, skills and personal characteristics that
college graduates possess? Such information would benefit both
individuals and society.
So I applaud your Committee for looking at this issue of
collegiate outcome assessment, and I hope you can move us
beyond the current state of assessment. Thank you.
Chairman McKeon. Thank you very much.
[The prepared statement of Dr. Erwin follows:]
Statement of Dr. T. Dary Erwin, Associate Vice President of Academic
Affairs, Assessment and Program Evaluation, James Madison University,
Harrisonburg, Virginia
Thank you for the opportunity to discuss college student outcome
assessment. As background about my own institution, I started and
oversee the Center for Assessment and Research Studies at James Madison
University in the Shenandoah Valley of Virginia. James Madison is a
publicly supported institution of about 16,000 students.
Our Assessment Center is probably the largest campus based
assessment center in the country and has been in operation since 1986.
We have nine doctoral level assessment faculty and focus on assessment
of general education, the major, and out-of-class activities in student
affairs.
Since 1987, we have annually tested all entering freshmen, about
3600 students, just prior to matriculation, and then retest them about
two academic years later in general education. The general education
areas in which we regularly assess are: technology and information
literacy, oral communication, written communication, critical thinking,
arts and humanities, quantitative reasoning, scientific reasoning,
government, and wellness.
We utilize several analytical strategies for analyzing these data:
1. competency--in technology, in information literacy and in oral
communication--how many students reach a standard?
2. value-added or longitudinal change--in all the other areas of
general education listed above--how much do students change or learn in
their first two years of college?
3. course impact--compare students in a given area of general
education who have not yet complete any courses versus who have had one
course versus who have had two or more courses--student should do
better on the related outcome measure the greater number of courses
completed.
We use the assessment data to improve our curriculum, to improve
our degree requirements, and to evaluate the effectiveness of
instructional delivery approaches such as a particular instructional
software package.
For example, in 1996, we completely reworked our general education
program, which is approximately one-third of our undergraduate
curriculum, largely because we had mixed assessment results. In the new
curriculum, we established policies that every general education course
sequence must regularly demonstrate positive student learning for those
courses to remain in the curriculum. Each academic department's annual
report features their assessment results of their respective major
programs and if applicable their part of general education. Each
academic department unit lead is evaluated on the viability of their
department's assessment efforts.
National Picture
In general, higher education institutions have been slow and
reluctant to systematically measure student learning in a programmatic
way. It is a hard job, can be threatening to faculty and presidents
alike, and involves much complexity. Faculty, of course, give course
examinations, but most institutions do not use common measures
particularly in general education across an institution. General
education is the coursework that all students take regardless of major.
I view general education as the primary focus for accountability
purposes because it is the imprint of every graduate of the
institution.
According to Gaff of the Association for American Colleges and
Universities, over 90% of the colleges and universities deploy the
distribution system of general education whereby students select one to
three courses from a given distribution area such as social science
where many courses are listed. Generally, the more courses listed in a
given distribution area for students to chose from, the more difficult
it is to have commonalities among all the courses listed. Assessing a
given distribution area becomes problematic then when there is little
instructional content or skills in common.
The problem of defining and therefore assessing general education
is magnified if one goes beyond the institution and tries to develop
commonalities among several institutions such as at a state level. Most
institutions have not developed measurable, specific learning
objectives, sometimes referred to as ``content standards'' in general
education. Common ``performance standards'' are more rare when an
institution sets a single cut-off score on an assessment instrument in
any given area of general education.
States
Most states have some kind of policy or mandate regarding
assessment. These policies vary from statewide tests such as Georgia's
Regents Exam to the majority of states that allow for institutions to
choose their own ways of assessing. Some states such as Virginia
designate the areas that are to be assessed: technology, written
communication, scientific reasoning, quantitative reasoning, oral
communication, and critical thinking.
Too often institutions over utilize self-report surveys as the
primary measures of student learning. What students think they learn
can be different than what they actually learned.
In the past few years, states have been experimenting with linking
``quality'' and funding but struggle with defining and measuring
quality. Often states collect only what data are available, but these
data usually do not include about student learning. For example,
outputs such as graduation rates are available, but these do not
describe how or what students have learned. I believe many states would
benefit from assistance in improving their current policies and
procedures.
The current state of assessment practice still makes it improbable
to generalize beyond a single institution, and in many cases difficult
to generalize within a single institution.
Consumers
As you have noted, the consumer is hungry for information about
quality. Prospective students, their parents, and employers desire
information about what students acquire from a particular institution
and what the value of that knowledge and skills has. For instance, look
at the popularity of ranking systems such as the US News and World
Report rankings. Unfortunately, those rankings are determined largely
by reputation, resources, outputs, admissions selectivity, and alumni
giving rates. No comparable student learning data are available for the
public to view.
Accrediting Organizations
As you probably know, accrediting organizations, whether regional
or professional, are increasingly emphasizing assessment of student
learning. Before 1985, few institutions reported any results about
student learning in accreditation reports. In my opinion, the
accrediting organization's role has been a very positive influence
helping institutions focus on educational results not just description
of resources. But the acceptance of including student learning data in
institutional reviews has been slow.
Federal Role
In my opinion, an increased role by the federal government would be
welcome. The US Department of Education's involvement has been very
positive at the K-12 level, but there seems to be a void of leadership
when it comes to assessment of collegiate learning. No single entity
seems to be coordinating collegiate assessment. I believe some time and
effort could be saved if practices and instruments could be shared, for
example. The issues are so complex and the job so big that a single
state can feel overwhelmed.
Here are some current advances that could be spotlighted at the
national level that could raise the sophistication of all of collegiate
assessment: highlighting the advancements of automated computer scoring
of writing, using advanced measurement techniques such as item response
theory to reduce bias in assessment instruments, featuring computer
based testing that utilizes multimedia capabilities allowing us to
formulate better test questions, using advancements in cognitive
psychology to assess where a student's misconceptions lie so
remediation can be better planned, and encouraging new assessment
instruments to encourage greater sophistication of our measuring tools.
Regarding the last point, a colleague and I are designing an instrument
called the Curiosity Index to measure one's intrinsic motivation to
learn that is central to lifelong learning.
Similar to the food labels listing the ingredients, wouldn't it be
helpful to know what knowledge, skills, and personal characteristics
college graduates possess? Such information would benefit both
individuals and society. I applaud this committee for looking at the
issue of collegiate outcome assessment, and I hope you can help us move
the current state of affairs forward.
Some Miscellaneous Comments About Assessment Procedures
At my institution, we have designed our own assessment instruments
in general education, and are just establishing standards or cut-off
scores in each area of general education. Competence is then achieved
by an individual student reaching a particular cutoff score; again our
current areas of competency are in technology (Word, Excel,
Powerpoint), in information literacy (the ability to find, access, and
find credible information usually stored in electronic form), and in
oral communication. All of these instruments are computer-based tests.
As you know, there is much attention on the delivery of instruction
via technology, but there is little attention to the delivery of
assessment and testing via technology. We can ask better and more
sophisticated test questions by incorporating multimedia components
such as music, speeches from national leaders for government test
questions, and video vignettes of speeches for public speaking courses.
Testing, as you may know, also has a very technical side.
Reliability, or the precision at which we measure a student's ability,
is critical and is validity, or the match between the learning
objectives/content standards and the given test.
In general, most available collegiate assessment instruments have
not used the most advanced measurement techniques. When we reviewed the
problem solving, critical thinking, and writing collegiate assessment
instruments for the National Postsecondary Education Cooperative (which
receives financial support from NCES), very few testing instruments
were designed with advanced techniques such as item response theory,
generalizable measurement theory, or structural equation modeling.
For example, very few proprietary collegiate assessment instruments
examine test item bias. This procedure is very common in college
admissions tests and in K-12 tests. The shortage of reliable and valid
assessment instruments for our institution is one reason our Assessment
Center has the staff it does.
There are some exciting advances in the automated computer scoring
of writing. Research has shown that the computer is more consistent in
its ratings than people. And the relationship between the computer
generated ratings and human ratings is moderately high.
H.R. 4283
I applaud Sec. 1025, ``Study of Student Learning Outcomes and
Public Accountability'' (p. 201-203). I would offer two suggestions for
additions. First, under point 3, p. 202, regarding instruments, please
add ``and sophistication.'' For example, our most advanced thinking in
cognitive psychology and psychometrics should be brought to bear on
existing practice. And second, I would also submit for your
consideration that you request the report to offer recommendations for
further steps. It is certainly useful to have summaries of the current
status of state efforts, overlap in institutional effectiveness
requirements among the accrediting organizations, and a review of
existing instruments; but what is needed, in my opinion, is a series of
action-oriented steps that outline how to achieve that an assessment
process of student learning exists at each institution. This process is
outlined to some extent in the regional accrediting associations, but
more guidance could be established. Each college and university has
learning as part of its mission, but not every college and university
evaluates student learning in a programmatic way.
I am not advocating selection of a particular assessment
instrument, nor am I advocating that you dictate what is to be
measured. However, I do believe it is important to have aggregated
information about student learning in general education that is
available to the public.
Thank you again for the opportunity to share some ideas.
______
Chairman McKeon. Dr. Martin.
STATEMENT OF DR. JERRY MARTIN, CHAIRMAN, AMERICAN COUNCIL OF
TRUSTEES AND ALUMNI, WASHINGTON, D.C.
Dr. Martin. Amen to that, for openers.
I would like to commend the Chairman and Mr. Kildee and
members of this Committee for boldly thinking about these
issues and taking them seriously.
The American Council of Trustees and Alumni today would
like to testify in support of one particular provision in H.R.
4283, which is to restore the provision that allowed States to
qualify as accrediting agencies. As you know, that was the
original intent of the legislation. It was removed somewhat
arbitrarily about 10 years ago and should be restored.
I want to put that in a larger context. There is what some
people call an accountability revolution going on in higher
education. What you just heard from Dr. Erwin is part of that
revolution. The heart of the accountability revolution is an
emphasis on educational performance, on results, on outcomes
and not just inputs and on cost-effective education.
Who is leading the revolution? I will tell you. It is not
the institutions, despite some outstanding examples; and it is
not the accreditors, sad to say. It is really State leaders. It
is Governors, legislatures, State higher education commissions,
boards of trustees who are leading the accountability
revolution.
And if you ask why, you know, why is this such a burning
concern in so many States, well, they are responding to the
concerns of their constituents, of parents and students, of
employers and taxpayers who are really quite worried that we
aren't getting all we should for our investment and that the
next generation isn't going to be as well prepared as it should
be to face the challenges of the 21st century.
In fact, studies show that their concerns are well founded.
Employers report that college graduates can't write, as one
testified before one commission. They can do--speaking of his
employees in a high-tech firm, they can do the technicals but
can't write the memo.
Grade inflation, just to mention another example, is
rampant; and the leading researcher at Duke University reports
that at virtually every college that has studied the problem it
is getting worse.
At many colleges today, students can graduate without
taking such core subjects as English, history, math and
science. This new study, literally hot off the press as of
yesterday, called ``The Hollow Core'', referring to core
requirements, finds that of colleges studied, just to give you
a couple of examples, only 14 percent require either American
history or government, yet they are supposed to be preparing
people for citizenship. And not one requires economics, which
is really a scandal in today's economy. Instead, students are
permitted to meet requirements with courses such as--and these
are real examples, I kid you not--history of comic book art,
rock music since 1970, campus culture and drinking. And one can
go on with that list, where you would laugh; if not, you would
want to cry. Needless to say, all these schools are fully
accredited.
Accreditors talk about quality, but if you look at their
deeds or the results and not just their words, you really have
to ask, where is the beef? Over the last 4 years--the reports
themselves are secret, so you have to go with those reported in
the Chronicle of Higher Education, which is the newspaper of
record for higher education--47 cases have been reported where
accreditors are threatening a school over financial
mismanagement. They seem to do a good job when it comes to
helping to close down a financially insolvent school, although
the market is, in effect, closing the school down. The
accreditors want to make it official, I guess you would say, so
they are looking at financial issues. But not a single case has
been reported of an accreditor sanctioning a school or
threatening it because of grade inflation where its graduates
can't write, where its curriculum is incoherent, where the
teaching is poor. Not a single case.
In a way, you can't blame the accreditors. It is hard to
police your own members. They are part of that world of higher
education.
Well, the American Council of Trustees and Alumni think it
is time to go back to the original intent of the Higher
Education Act. Originally, the Act permitted two options for a
college. The college could be accredited either by a private
association, if they so chose, or by the State, if they so
chose. Either one was possible.
The system worked well and yet, in 1991, an arbitrary
restriction was put in disallowing States from being recognized
by the Secretary of Education as accreditors. One State was an
exception, and that was New York, who was grandfathered in and
still does accrediting in some areas to this day without any
problem.
Well, this arbitrary restriction should be removed. State
accreditation is OK for New York. It was OK for all States
until 1991. It should be OK for other States today.
To sum up, Mr. Chairman, let me just say there are three
advantages to allowing the State option:
No. 1, the States are well-equipped and motivated to do
this job. Every State already has a procedure for certifying
which institutions of higher education operate within its
borders. In recent years, State governments have made dramatic
efforts to improve accountability, reward performance and
achieve greater cost effectiveness, done without the help of
accreditors. After all, it is their young people and their tax
dollars at stake.
No. 2, the State option is entirely voluntary. They can
choose to do it or not do it. The college, they can choose to
go to their State or to remain with a private accreditor.
No. 3, the State option adds competition. There is little
incentive other than prodding from this Committee and this
Congress for accreditors to improve as long as they have a
monopoly. Competition can be a very effective motivator for
reform.
Thank you, Mr. Chairman.
Chairman McKeon. Thank you.
[The prepared statement of Dr. Martin follows:]
Statement of Dr. Jerry L. Martin, Chairman, American Council of
Trustees and Alumni, Washington, DC
It is often said that American higher education is ``the envy of
the world.'' This is certainly true in areas such as science, medicine,
engineering and other technical fields. It is also true with regard to
access--the large percentage of the population that attends college.
But in some other respects, American higher education is less
impressive.
Employers complain that graduates cannot write. ``They can do the
technicals,'' one said, ``but they can't write the memo.'' Yet not a
single case has been reported of accreditors sanctioning a school on
these grounds.
A Roper survey, described in the American Council of Trustees and
Alumni's report, Losing America's Memory, found that college seniors,
even at top colleges, do not know American history. Only one-quarter
could identify James Madison as the Father of the Constitution, George
Washington as the victor at the battle of Yorktown, or the most famous
words from the Gettysburg Address. It was not hard to locate one source
of the problem: none of the colleges require American history for
graduation. Yet they are all accredited.
Grade inflation is rampant, and is getting worse. Nothing is more
essential to upholding quality and motivating academic achievement than
giving honest grades. Another ACTA report, Degraded Currency: The
Problem of Grade Inflation, summarizes current research on the topic. A
comprehensive study by Columbia's Arthur Levine and Jeannette Cureton,
finds that the percentage of A's has increased from 7 percent of all
grades in 1969 to 26 percent by 1993. During the same time period, the
C grades fell by 66 percent. The problem has grown worse since that
time. Based on his ongoing study of grade inflation, Duke's Stuart
Rojstaczer reports that, ``The rise has continued unabated at virtually
every school for which data are available.'' To cite one particularly
timely example, the Boston Globe recently reported that, in the last
two years, the number of A's and A minuses at Harvard actually
increased from 46.4 percent to 47.8 percent. Every student graduates
with honors who is not in the bottom 10 percent of his or her class. In
spite of the pervasiveness of this problem, we are not aware of a
single instance of a school being sanctioned by the accreditors for
grade inflation. In fact, no case has been reported of the issue even
having been raised by accreditors.
Probably the most important question about a college is: What are
students studying and learning--in short, what is the college
curriculum? Most importantly: What courses are required for every
student? Yet, there is massive evidence for the fact that, under the
current accrediting system, the college curriculum has fallen apart.
ACTA's new study, The Hollow Core, examines the general education
offerings at 50 colleges and universities, including the Big Eight and
Big Ten, the Ivy League, and the Seven Sisters. The study finds that
college requirements have so many loopholes, students can often
graduate without taking core subjects such as math, science,
composition, literature, economics, or American history or government.
Not one of the surveyed colleges requires a general course in
economics. Only 12 percent mandate a general course in literature,
while a mere 14 percent insist that their students study American
history or government. Needless to say, all these colleges are
accredited.
Instead of solid core requirements, many colleges now offer
students a cafeteria-style menu of hundreds of often narrow and even
odd courses. At various universities, the humanities requirement, which
used to require broad courses such as History of Western Civilization,
can be met by such narrow courses--these are all real examples--as
``History of Country Music,'' ``Movie Criticism,'' or ``Dracula.'' The
literature requirement, once a survey of English literature, can now be
met by such courses as ``Quebec: Literature and Film in Translation''
and ``The Grimms'' Fairy Tales, Feminism, and Folklore.'' History
requirements can be met by ``History of College Football,'' ``History
of Visual Communication,'' or ``Sexualities: From Perversity to
Diversity.''
Borrowing from Cole Porter, the Association of American College's
study, Integrity in the Curriculum, concluded that, as for what passes
as a college curriculum, ``Almost anything goes.''
In theory, the accreditors should be the guardians of academic
quality. In reality, it has taken enormous external pressure, including
explicit Congressional directives, to persuade accreditors to address
more directly issues of educational quality and student learning. In
response, accreditors have added some general language like the
following from the Middle States Association: ``The kinds of courses
and other educational experiences that should be included in general
education are those which enhance the total intellectual growth of
students, draw them into important new areas of intellectual
experience, expand cultural awareness, and prepare them to make
enlightened judgments outside as well as within their specialty.'' The
North Central Association requires ``a coherent general education
requirement consistent with the institution's mission and designed to
ensure breadth of knowledge and to promote intellectual inquiry.''
It is hardly surprising that, when the Office of the Inspector
General of the U.S. Department of Education reviewed the criteria of
the North Central Association, it found them devoid of any ``specific
measures to be met by institutions'' and insufficient for
distinguishing between compliance and non-compliance. Such criteria
ensure that colleges will pay lip-service to sound educational goals,
but not that they actually deliver a solid education to their students.
Few and far between are the examples of colleges whose
accreditation has been denied on grounds of educational performance. As
DePaul University's David Justice writes, ``The truth of the matter is
that regional accrediting associations aren't very good about
sanctioning an institution for poor quality.''
If the accreditors are lax when it comes to enforcing standards of
educational quality, what demands are they placing on universities? The
accrediting reports themselves are secret, but a review of
accreditation problems reported over the last four years in The
Chronicle of Higher Education found that--with only a few exceptions
outlined below--all of the 47 U.S. colleges placed on probation were in
trouble because of financial insolvency.
Yet, in this area, accreditors are largely redundant. The market
has already rejected these institutions and is in the process of
putting them out of business. Moreover, the financial health of
institutions of higher learning is already certified by the U.S.
Department of Education. No institution may receive federal funds until
the Department verifies its eligibility and certifies its financial and
administrative capacity. In addition, as the accreditors themselves
admit, the bond-rating services establish financial viability on the
basis of a more thorough review than accreditors.
Accreditors mainly focus, not on educational performance or
results, but on a variety of inputs, including the number of books in
the library, the credentials and demographics of the faculty, student
credit hours, what percentage of students live on campus, how many
courses are offered at night, and so forth. They seem especially
interested in procedures--shared governance procedures, appointment and
tenure procedures, grievance procedures, program review procedures, and
so forth.
Former U.S. Senator Hank Brown, who recently served as President of
the University of Northern Colorado, reports that the accreditors did
not ask what the students were learning but focused mainly on whether
the faculty was happy.
The Chronicle of Higher Education reported last month that
accreditors told the University of North Dakota governing board to drop
the institution's Indian-head logo and Fighting Sioux nickname.
The same accrediting agency evaluated the University of Illinois at
Urbana-Champaign and objected to the University's mascot--Chief
Illiniwek.
Currently, Auburn University's accreditation is threatened
primarily because the board of trustees is said to micromanage the
athletic program. ``None of the problems relate to education,'' reports
The Chronicle.
One has to wonder whether challenging colleges over mascots and
trustee involvement in athletics are what Congress envisioned when it
gave accreditors the power to cut off a university's federal funds. Yet
these are the only reported cases of sanctions on non-financial
grounds.
Accreditors talk about ensuring quality but, if we look at their
track record, we have to ask: ``Where's the beef?''
What is the solution?
First, the ideal solution is to get the federal government of the
accreditation business. Let private accreditors be private again. That
worked fine before the federal government became involved and it will
work fine again. If colleges want to be accredited, fine. If
accreditors get out of line, as they sometimes do, the college can just
drop them. Private accreditors would no longer have the power of the
federal government behind them.
That does not mean that the federal government would have to become
an accreditor. For the purposes of making sure that federal funds going
only to bona fide colleges, a much simpler and less expensive procedure
could be established. Colleges could be required to answer questions
that demonstrated their legitimacy--with penalties for fraudulent
declarations. That should be sufficient to identify the institutions
that are ``colleges'' in name only.
Second, there is a lively market in higher education. What college
to attend is a decision that consumers take very seriously. Yet
accreditation evaluates colleges and then keeps the evaluations secret.
Useful information is being wasted. Massive data gathering occurs prior
to an accreditation visit. Relevant parts of this data should be shared
with the public. The College Consumer Profile envisioned in this bill
is very promising in this regard.
Third, if accreditors have a poor record when it comes to ensuring
quality, why not allow an alternative? There is an accountability
revolution in higher education, but it does not come from the
accreditors or from what is euphemistically called ``the higher
education community.'' It comes from the states--from Governors,
legislators, state higher education commissions, boards of trustees,
business leaders, and parents. Let me just give you two examples:
1. Trustees are appointed to represent the public interest and,
with the assistance of ACTA, are becoming increasingly active and
expert in overseeing quality. The City University of New York board of
trustees raised admissions standards, removed remediation from the
senior colleges, and now requires that students pass an independently
administered examination before they move to upper-division course
work. Boards of trustees in a number of states are taking proactive
steps to demand more rigorous core requirements for their students.
None of these improvements were the results of accreditors'
recommendations.
2. State higher education agencies--such as the Colorado Commission
on Higher Education and the State Council of Higher Education for
Virginia--are framing performance measures that look at educational
results and not just inputs. Hank Brown, who became a college president
after serving in the Congress, reports that, while the accreditors did
not ask questions about what students were learning, one agency did--
the Colorado Commission on Higher Education. Meanwhile, Virginia's
State Council now collects and annually releases the results of
institution-based assessments of student learning to help ensure
academic quality.
The regional accrediting associations function as de facto cartels.
Monopolies are not good at self-correction. The best medicine is
competition. Whereas accreditors have shown great reluctance to become
meaningfully involved in educational standards and student learning,
the states have shown an intense interest in making sure their colleges
and universities provide a first-rate education to all their citizens.
The money is coming out of their pockets, in taxes and tuition, and it
is their kids who are being educated--or failing to be educated. The
original Higher Education Act allowed states, if they so chose, to
provide an alternative to accreditors. About ten years ago, this option
was arbitrarily deleted. Now only New York has this right. H.R. 4283
wisely restores this option for any state that wishes to exercise it.
ACTA believes that eliminating this arbitrary restriction and
allowing all states the option of providing accreditation to
institutions within their states would provide several benefits:
1. Every state already has some mechanism for certifying
institutions of higher education operating within their states. The
states are competent to do the job of accreditation and might do it
better. In recent years, state governments have made considerable
efforts to improve accountability, reward performance, focus on outputs
not just inputs, and achieve greater cost-efficiency.
2. The states are accountable to the voters and the taxpayers. The
regional accreditation associations are accountable to their own
members, namely, the universities they accredit.
3. Colleges and universities that feel they are being treated in
unfair and arbitrary ways by accreditors should have recourse to a
legitimate alternative. Absolute power corrupts.
4. There is little incentive for the regional accreditors to
improve so long as they have a monopoly. Competition, even the
possibility of competition, can be very effective in motivating reform.
The American Council of Trustees and Alumni would like to thank the
House Committee on Education and the Workforce for addressing these
issues thoughtfully, candidly, and boldly on behalf of the students and
parents of America.
______
Chairman McKeon. Dr. Davis.
STATEMENT OF DR. JAMES DAVIS, PRESIDENT, SHENANDOAH UNIVERSITY,
WINCHESTER, VIRGINIA
Dr. Davis. Thank you Chairman McKeon, Ranking Member Kildee
and members of the Subcommittee. I feel a great deal of
affinity for your work today, having served three terms in the
Virginia legislature and sitting on the House Education
Committee there.
I am testifying today basically on behalf of the National
Association of Independent Colleges and Universities, which
represents nearly a thousand private, nonprofit colleges and
universities and related associations. My own university,
Shenandoah University, has approximately 2,800 students located
in the Shenandoah Valley of Virginia.
I think democracy is a wonderful thing, and my colleague
looks through one set of lens at higher education and I look
through an entirely different set of lens. I can assure you in
my work as a State legislator, the State option for
accreditation is not a good one; and if we have time we can
probably explore that in a little more detail.
The current accreditation system is a uniquely American
institution. In most other nations, quality reviews are done by
centralized government authorities. They do not have the best
higher education system in the world, we do; and we have it
because of the unique relationship that exists between peer
review and appropriate levels of government involvement.
Certainly peer accreditation has its challenges, but, by far,
it is still the best system in the world, and it is getting
better all the time.
I have to chuckle because I started out as a young critic
of accreditation of the Southern Association of Colleges and
Schools and of some 16 specialized accrediting bodies that
currently accredit programs at my institution. Over a period of
the past 30 years, I have now chaired more than 25 Committees
for accreditation at institutions throughout the South; and I
can assure you that those are rigorous reviews and that the
results of those reviews do bring about change.
Certainly, accreditation can be improved, but it is not a
system that you will want to destroy in any way. Well, how do
we make it continue to work? We make it continue to work
through partnerships. We need to continue to define roles and
maintain that appropriate balance between government and peer
independent review. That is essential if we want to maintain
the autonomy of the independent sector. Because the more
control that is put on our system the less freedom that is
there to be creative and bring about changes, oftentimes, that
occur in the public sector because of the ability to innovate.
Why does House bill 4283 have unintended consequences?
Primarily because it shifts responsibilities in some key areas
that I think are not wise for our country. One in particular is
shifting the enforcement of data collection that the Department
of Education should do for monitoring consumer profile
information. That should stay with the Department of Education
and not be pushed over into accreditation.
The monitoring of distance education on a greater basis
than is currently the case, in my opinion, would not be wise.
Almost every institution of higher education that I know today
has some distance education, either for their traditional
students or for other students. It is being evaluated.
Institutions do understand the cost and the integrity needs for
distance education; and it does not require, in my opinion,
drastic measures, simply tweaking and encouraging current
accreditation processes to continue to improve and work better.
Finally, I mentioned earlier the issue of moving
responsibility to the States for accreditation; and, again, I
urge you not to do that. My members will tell you independence
of the private sector would be greatly at risk if you did that.
From my own experience in being in the legislature and now
serving as President of an institution for 22 years, I do not
think it would be wise.
There was a good example in Virginia where we upgraded the
laws in Virginia to attempt to stop degree mills from
operating. In the process, a simple little piece of legislation
drew five institutions that had been in the Commonwealth for a
long time and were well established into a new maze of
regulations and fees that it required to undue this past
legislative session. Unfortunately, my institution was one of
those, and I was delighted that I had the legislative
experience to work to help bring about the change that was
necessary.
Well, this bill also deals with transparency issues; and I
want to emphasize that I think transparency is extremely
important. But we need to understand that transparency and
accreditation should be primarily for status of institutions,
for penalties, for infractions that may occur. It should not
destroy the consultative work that is done on peer
accreditation because it is almost half or more the value; and
when you publicize that information, you publicize members of
the Committees. All you are doing is reducing the willingness
of people to serve and the willingness of people to be truly
helpful in the accreditation proceedings.
In summary, I would urge you to believe that peer
accreditation which is relatively free of government
involvement is essential to democracy and the concepts of
freedom that we all enjoy. It is a unique American institution.
It is very fragile, and it can be destroyed very easily if we
are not careful.
I would urge you to believe that peer accreditation has
some challenges, but members like myself and others who
voluntarily participate in that process believe that we can
make it better, with your encouragement, with dialog. As
president of one of these institutions, I will invite you to
spend a few days with me as I work to satisfy all of the many
constituencies as have been mentioned here and others as we
make decisions about cost, quality and a number of other
things. It would be a joy to have you sit with me and
experience the kind of commitment that is there on the part of
my colleagues and others, and especially in the independent
sector that I am speaking for, for the work they do to keep the
system of higher education in America strong.
We are committed to cooperating with you on this bill. We
don't want to be protagonists. We don't want to stand in the
way of good change. But when we think you are wrong, Mr.
Chairman, we think we need to say we think you are wrong and
still respect you for your long-standing commitment to higher
education and also the affirmations that you gave in your
opening statement that I think are important.
Thank you and appreciate the opportunity to speak to the
Committee today.
Chairman McKeon. Thank you.
[The prepared statement of Dr. Davis follows:]
Statement of Dr. James A. Davis, President, Shenandoah University,
Winchester, Virginia
Chairman McKeon, Ranking Member Kildee, and members of the
subcommittee, I appreciate having the opportunity to appear today to
discuss accreditation and its role in U.S. higher education. My name is
Jim Davis, and I am president of Shenandoah University. I have been
involved with accreditation for approximately the past 28 years and
have served in a variety of capacities with the Southern Association of
Colleges and Schools Commission on Colleges.
I am testifying on behalf of the National Association of
Independent Colleges and Universities (NAICU), which represents nearly
1,000 private, non-profit institutions of higher education. NAICU
membership reflects the diversity of private, non-profit higher
education in the United States--including traditional liberal arts
colleges, major research universities, church- and faith-related
institutions, historically black colleges and universities, women's
colleges, performing and visual arts institutions, two-year colleges,
and schools of law, medicine, engineering, business, and other
professions.
Accreditation in the United States
The accreditation process is a private one that long pre-dates the
enactment of the Higher Education Act. It was devised as a means by
which institutions could engage in peer review and self study in order
to maintain and expand the quality of their educational offerings.
Accreditation is a uniquely American institution. In most other
nations, quality reviews are generally conducted by centralized
governmental authorities. The tradition of institutional autonomy in
the United States called for a different approach. It is an approach
that has proven highly successful over the years. It has allowed a
diversity of institutions to flourish and has helped make American
higher education the standard for the world.
The private-public partnership between the accreditation process
and the federal government began over 50 years ago with the enactment
of the ``Veterans' Readjustment Assistance Act of 1952'' (commonly
known as the GI Bill). That act required the U.S. Commissioner of
Education to publish a list of accrediting agencies and associations
that he regarded as reliable authorities as to the quality of training
offered by an educational institution. This requirement was
subsequently restated in other federal education laws, including the
Higher Education Act of 1965.
Federal reliance on accreditation in determining the quality of
institutional offerings was further formalized in the 1992 amendments
to the Higher Education Act as part of a broader effort to articulate
the respective roles of States (consumer protection), accreditors
(quality), and the Department of Education (program integrity and
administrative capacity) in the so-called ``triad.'' This basic
division of responsibility remains sound in concept but requires
careful delineation of roles to operate successfully. The failure, for
example, to limit the scope of State Postsecondary Review Entities
(SPREs) to consumer protection activities led to the repeal of this
portion of the 1992 amendments.
Clearly defining roles and maintaining an appropriate balance among
the entities that have a role in maintaining public confidence in
higher education is a challenging task, but it can be accomplished. And
it important to do so not only to preserve the autonomy of higher
education but also to permit accreditors and others to focus on what
they do best.
Accreditation Provisions of H.R. 4283
The accreditation provisions of the ``College Access and
Opportunity Act'' (H.R. 4283) cover a broad range of topics, including
consumer information disclosures, distance education, governance,
student learning outcomes, student complaints, and the transfer of
credit. In addition, the measure permits states to become accreditors.
Many of these provisions may well lead to unintended consequences.
Some provisions turn accreditation agencies into surrogate federal
enforcers, while others ask accreditors to assume responsibilities that
are far removed from assessing educational quality. Taken as a whole,
these proposals raise substantial concerns that the purpose and
effectiveness of accreditation will be weakened. Read simply, this bill
would interfere with the ability of accreditors to do their jobs well.
Our mutual goal is to assure that the quality of higher education
in the United States remains high and that the public can have
confidence in our institutions. I would like to highlight several of
the provisions that I believe will have unintended consequences.
1. States as accreditors.
Permitting states to become accreditors would set us on the path
towards the kinds of problems that Congress rightly chose to address by
repealing SPRE. There is a division of responsibility among States, the
federal government, and accreditors that should be maintained.
Otherwise, we will end up with inconsistent and uncoordinated
regulation. Moreover, NAICU member institutions are, by their very
nature as private, non-profit institutions, not under the direct
control of State governments. They should not be placed indirectly
under such control through the accreditation process. If that occurs,
we could easily start to look and feel like state institutions--losing
the overall diversity of American higher education.
2. Consumer information/College Consumer Profile.
The bill requires accreditors to assure that institutions develop
and make public a ``College Consumer Profile.'' Requiring accreditation
agencies to enforce data collection efforts by the Secretary is
inappropriate and unnecessary. The Secretary has all the authority he
needs to collect data from institutions. Requiring back-up enforcement
from accreditors only serves to distract them from their primary
purpose which is to assure the quality of education institutions.
I share the interest of members of the subcommittee in seeing that
students and parents have access to the information they want and need
about an institution of higher education. Institutions currently
provide substantial amounts of data to the Department of Education. A
concerted effort to determine which of this data is of value to
consumers and how to provide it in a user-friendly manner would be
useful. As currently devised, however, the proposed College Consumer
Profile does not accomplish this goal.
3. Consumer information/Public disclosure.
General disclosures of accreditation findings will substantially
change the nature of the accreditation process and undermine the
frankness and candor that help make the process successful. Inevitably,
negative information from a review will be reported out of context a
prospect that can have particularly devastating consequences for small
institutions.
Again, I believe the challenge here is determining what it is that
students and parents want to know. Much of the information provided in
accreditation reports is mainly consultative rather than directly
related to the standards or requirements. I am not convinced that many
students and parents would actually read a summary of accreditation
findings. On balance, this proposal would do little to advance public
understanding of accreditation and its finding while having the
potential to damage the process.
To the extent that the committee wishes to increase public
understanding of the accreditation process, I stand ready to help find
ways to increase transparency in ways that will not undercut the frank
exchanges that are critical to continued improvement.
Governance.
The bill would require accreditors to assess an institution's
``governance capacity.'' Most accreditors already review governance and
independence of boards that oversee the operations of institutions.
Including a standard in legislation only creates complications in
definitions, duplication of effort with current efforts by the Internal
Revenue Service, and the potential for inappropriate interference in
areas such as the board composition of religiously affiliated
institutions.
4. Transfer of Credit.
The bill sets up accreditation as a means of enforcing proposed new
transfer-of-credit requirements. Congressional involvement in transfer
of credit issues is unwise because these decisions go to the heart of
institutional integrity and ability to shape educational programs. This
issue is so complicated and includes so many variables that it would be
impossible to legislate appropriately.
The stated purpose of these provisions is to assure that transfer
credits are not rejected solely on the basis of the type of
accreditation of the sending institution. However, the most
controversial aspects of the actual language of H.R. 4283 goes well
beyond what is necessary to achieve that purpose causing even greater
concern about the pitfalls of legislating in this area.
For example, the bill also sets the standards upon which transfer
decisions should be made and requires disclosure on an annual and 3-
year rolling average the percentage of credits accepted in transfer and
fully counted toward degree/certificate completion requirements,
disaggregated by four categories: nationally accredited; regionally
accredited in the same State; regionally accredited in the same region;
and regionally accredited in a different region.
5. Student Learning Outcomes.
The bill expands the portion of the law dealing with student
achievement standards that must be assessed by an accreditor and
provides that accreditors evaluate the substance of the information
disclosed to students regarding an institution's learning objectives
for its academic programs.
Current law provisions are adequate to deal with review of student
learning. Accrediting agencies are placing great emphasis on such
reviews now. Linking this review with a new requirement that
institutions develop ``desired learning outcomes'' for each of their
academic programs could lead to standardized measurement of those
outcomes. Learning outcomes are the basis of the formation of
curriculum, which is best left to faculty and institutions to shape.
6. Distance Education.
The bill includes additional requirements an accreditor must meet
in order to include evaluation of distance education within its scope
of recognition and requires that accreditors monitor the growth of
distance education programs.
Already 90% of institutions of higher education offer some form of
distance education for their regular students or for those considered
non-traditional. Some refinement of the distance education provisions
would help assure that a separate accreditation process for distance
offerings is not established.
In addition, it is certainly important to monitor the growth of
distance education programs. At the same time, protecting student aid
programs from fraud and abuse is the direct responsibility of the
federal government. This responsibility should not be relegated to the
accreditation process, which is neither an authority on Title IV
administration nor regular enough to monitor excessive growth in
student aid funds. Monitoring the growth of distance education programs
should be the responsibility of the Department of Education not of
accreditors.
Conclusion
I contend that peer accreditation which is relatively free of
government involvement is essential to democracy and the concepts of
freedom we enjoy today. It is a unique American institution and
Congress should not destroy it with creeping legislation that is well
intended but directed toward the wrong entity. Peer accreditation has
some challenges but it is still considered to be the best system in the
world that has produced the best higher education system in the world.
______
Chairman McKeon. Dr. Keiser.
STATEMENT OF DR. ARTHUR KEISER, IMMEDIATE PAST PRESIDENT,
ACCREDITING COMMISSION OF CAREER SCHOOLS AND COLLEGE OF
TECHNOLOGY, FT. LAUDERDALE, FLORIDA
Dr. Keiser. Mr. Chairman and members of the Subcommittee,
thank you for the opportunity to testify about accreditation
and its ability to ensure institutional accountability and
quality for students and their parents.
I am Arthur Keiser, Chancellor of the Keiser Collegiate
System, which includes Keiser College, Keiser Career College
and Everglades University. I am testifying here on behalf of
the Accrediting Commission of Colleges and Schools of
Technology, a private, nonprofit national accrediting agency
recognized by the Secretary of Education since 1967. We
currently serve over 800 institutions with 400,000 students.
I will discuss four topics today: one, how greater
transparency in the accreditation process serves students and
the public; two, the role that accreditors can play in
improving institutional accountability; three, accreditation's
role in addressing problems raised by arbitrary denial of
transfer of credit; and, four, the enhanced role of
accreditation in assessing distance education.
In focusing on increasing transparency in accreditation,
the Commission believes that H.R. 4283's provision strikes the
appropriate balance between ensuring accountability and
maintaining the confidentiality and integrity of the
accrediting process. Our Commission supports these disclosure
requirements.
The bill's provision also requires public disclosure of
accreditation team members, a description of an accrediting
agency's processes for selecting and training these individuals
as well as disclosure for the agency's code of content. We
understand the intent but recommend that the bill require the
disclosure of an updated list on an annual basis without
disclosing the makeup of each specific team site.
In the area of accountability, ACCSCT believes that the
bill's provision to create a College Consumer Profile takes an
important step forward in providing more information about
schools to students that attend or would like to attend
particular colleges. In my capacity as Chancellor of Keiser
Collegiate System, I do not believe these provisions require
institutions or accreditors to develop or disclose a
significant amount of new data.
Public disclosure of student achievement will also improve
institutional accountability. ACCSCT believes it is
increasingly important that institutions participating in title
IV programs demonstrate the benefits that students will receive
from institutions' educational programs. In order to accomplish
this goal, ACCSCT believes that Congress should place a greater
emphasis on the use of meaningful performance measures that
affect an institution's participation in the student aid
program, including placement, completion and retention.
ACCSCT believes that House Resolution 4283's provision to
amend the student achievement standards required for
accrediting agencies reflect the consumers' interest in
outcomes, retention, completion and job placement. The bill's
provision accomplishes this in a manner that is differential to
the ability of institutions and accrediting bodies to determine
the appropriate measures of students' academic achievement
based on an institution's mission and the learning objectives
of individual programs.
ACCSCT shares the desire of the Chairman and the Committee
to eliminate the unnecessary burdens on students on the Federal
treasury. One important way in which to do this is to improve
the student's ability to transfer credits. In many cases,
students that rely on title IV student loans are forced to
retake courses for which credit is denied.
The standards for recognition by the Secretary are
identical for both national and regional accrediting agencies,
yet barriers to the transfer of credit are particularly
prevalent when students attempt to transfer credits from
national credit institutions to regionally accredited
institutions.
I am personally familiar with some of the obstacles that my
students have faced. I have included one student's story in the
written testimony and others as clear examples of the arbitrary
transfer process.
The Keiser Collegiate System is comprised of both
regionally and nationally accredited institutions. Although
there are differences in processes, expectations and standards,
I can attest from experience the national accrediting agencies
are as effective and comprehensive in reviewing institutional
quality and integrity as regional accrediting agencies.
During the last decade, the development of distance
education has provided another increasingly important means to
achieve a postsecondary education. The growth of on-line
education is particularly important to working adults and the
more diverse circumstances that students face.
The College Access and Opportunity Act takes important
steps by removing the 50 percent rules. In doing so, the bill
relies on accreditation to play an enhanced role in ensuring
quality. Whether the accrediting agencies choose to rely on
separate standards or discrete standards to review distance
education, we believe that legislation should focus on the
accrediting agency's capabilities to review these institutions
or programs with as much rigor as they do campused-based
institutions, while also recognizing the special attributes of
the campuses.
I thank you for this opportunity to testify before the
Subcommittee.
Chairman McKeon. Thank you.
[The prepared statement of Dr. Keiser follows:]
Statement of Dr. Arthur Keiser, Immediate Past Chairman, Accrediting
Commission of Career Schools and Colleges of Technology, Ft.
Lauderdale, Florida
Mr. Chairman and Members of the Subcommittee, thank you for the
opportunity to testify about accreditation and its ability to ensure
institutional accountability and quality for students and their
parents. I am Arthur Keiser, Chancellor of the Keiser Collegiate
System, which includes Keiser College, Keiser Career College, and
Everglades University. The Keiser Collegiate System comprises 16
campuses in the State of Florida with over 7,000 students. Sixteen
accrediting agencies review these institutions, including both national
and regional agencies, as well as those that provide institutional and
programmatic review. I am testifying here today on behalf of the
Accrediting Commission of Career Schools and Colleges of Technology
(ACCSCT or the Commission). I am completing my term as an ACCSCT
Commissioner in July and I just completed a two-year term as Chairman.
ACCSCT is a private, non-profit independent accrediting agency
recognized by the Secretary of Education since 1967. It is a national
agency that accredits approximately 800 institutions with over 400,000
students throughout the country. ACCSCT-accredited institutions are
both non-profit and for-profit, degree and non-degree granting. These
institutions prepare students for trade and technical careers in many
areas including computer programming, commercial art, culinary arts and
medical technology, among others.
ACCSCT applauds you and the Subcommittee for holding this hearing
today to ask the important question of how accreditation performs in
providing accountability and quality control. Accreditation predates
the Higher Education Act and has always been voluntary in nature.
However, since the enactment of the Higher Education Act in 1965
accrediting bodies have held an important role in the regulatory
process that determines whether institutions participate in Title IV.
Without accreditation by an agency recognized by the Secretary, an
institution may not access Title IV funds. For those institutions that
participate, accrediting agencies have the important responsibility to
ensure the quality and integrity of their programs. For those
accrediting agencies that seek recognition from the Secretary, the Act
currently contains a number of obligations that must be met with regard
to accreditation review and operating procedures. ACCSCT believes that
the accreditation community provides quality assurance and
accountability for students and their parents. ACCSCT also shares your
interest in strengthening that current role through passage of H.R.
4283's provisions on accreditation.
In the testimony that follows, I would like to provide you with
background regarding ACCSCT's accreditation mission and process and
then share the Commission's view on what particular goals might be
achieved through the reauthorization process to enhance accreditation's
consumer protection role. Specifically, I will discuss four topics: 1.
how greater transparency in the accreditation process serves students
and the public; 2. the role that accreditors can play in improving
institutional accountability; 3. accreditation's role in addressing
problems raised by the arbitrary denial of transfers of credit; and 4.
the enhanced role of accreditation in assessing distance education.
I. Overview of ACCSCT's Accreditation Practices
The Commission has thirteen members: six are public members
representing government, industry or the higher education community,
and seven members represent the private career school sector. School
members are elected by ACCSCT institutions, and public members are
selected by the Commission after being recommended by ACCSCT's
nominating committee. Each commissioner serves for a maximum of four
years.
The Commission is well suited to provide its perspective on whether
accreditation, and ACCSCT specifically, assures students and parents
institutional accountability and quality. We believe that the
Commission's focus in these areas provides protection for students'
investments in their educations. The Commission's mission is to
accredit career schools and colleges in the United States, its
territories and abroad. Its mission has two primary goals: to assure
students and the general public of the quality of education provided by
institutions and their programs, and to assist institutions in
continuously improving to better serve students.
The Commission has adopted detailed standards which ACCSCT-
accredited institutions must meet in order to maintain their
accreditation status. The standards define a model of accreditation
that assesses the effectiveness of an institution by examining faculty,
admission practices, facilities and equipment, financial and
administrative capability and student services, as well as the
performance outcomes of students, such as favorable completion and job
placement rates, and pass rates on state licensing or national
certification examinations. These standards reflect a concern for
consumer protection and student satisfaction. For example, the
Commission requires its institutions to disclose to prospective
students before enrollment information regarding tuition, incidental
costs and refund policies. The Commission also requires institutions to
provide students copies of the complete enrollment agreement, including
both the student's and institution's obligations. A copy of the
Commission's standards is included with this testimony.
Through the self-evaluation process, an institution has the
opportunity to assess its programs against ACCSCT's established
standards and to identify areas of strength and those that need
improvement. Once an institution completes its self-evaluation report,
a team visit is conducted by ACCSCT to verify the information submitted
in the report and to determine the institution's adherence to its
stated objectives and compliance with the Commission's standards of
accreditation. These visiting teams generally include a team leader to
review an institution's administration, student services and financial
position; an occupation specialist to evaluate the training and
equipment for each discipline in which the institution provides
instruction; and an education specialist from an accredited two- or
four-year college or university for review of faculty, libraries and
instruction. All teams include an ACCSCT staff member as well.
Once a team visit is complete, the team prepares a written report
to which the institution has the opportunity to respond. The Commission
then reviews these reports and comments before a decision on
accreditation is made. In addition to these materials, the Commission
may seek additional information from state and federal agencies, other
accrediting agencies and the public. The institution may respond to
these third party comments.
ACCSCT meets at least quarterly to conduct business related to
school actions. The Commission can grant accreditation to an
institution for up to five years. Shorter accreditation periods are
granted in instances where the Commission sees the need to closely
monitor an institution's compliance. The Commission may take the
following actions on an institution: accredit/reaccredit (with or
without stipulation); defer action pending additional information;
order the institution to Show Cause as to why accreditation should not
be revoked; place an institution on probation; deny or fail to grant
accreditation; and remove an institution from accreditation.
We strongly believe that the Commission's standards and procedures
provide the public with the assurance of quality and accountability.
Can accrediting agencies do more to improve in this area? The
Commission believes they can and early in the Reauthorization process,
the Commission focused its attention on how the Act might be amended to
provide more information to students and to the public regarding the
quality of an institution's programs, while at the same time preserving
the integrity of the accreditation process.
II. Improving Transparency in the Accreditation Process
The Commission believes H.R. 4283's provisions strike the
appropriate balance between assuring accountability and maintaining the
confidentiality and integrity of the accreditation process. The bill
would require accrediting agencies to provide both the Department and
the public a summary of actions taken on an institution. The Commission
supports the disclosure of information relating to final actions. In
fact, at a minimum, accrediting agencies are already required to notify
the Department of actions taken. In the case of a final decision to
deny, terminate or suspend, accreditation agencies currently are
required to provide a notice and summary of such actions to the
Department. Such disclosures must be made available to the public upon
request. The most significant change under the bill is with regard to
the public disclosure of these summaries. The expansion of information
required to be disclosed should not represent a dramatic change for
accreditors or the institutions. These provisions simply enhance and
clarify many of the current provisions of the Act.
The bill's provisions also require public disclosure of
accreditation team members, a description of accrediting agencies'
processes for selecting and training these individuals, as well as
disclosure of the accreditor's code of conduct. The Commission
understands that the intent of these provisions is to assure the public
that accrediting agencies and their representatives are qualified to
review their institutions and ensure quality. With the significant
number of evaluators used by all of the recognized accrediting
agencies, we recommend that the bill require the disclosure of an
updated list on an annual basis without disclosing the make-up of each
specific site team.
III. Improving Institutional Accountability using Accreditation
ACCSCT has worked to examine ways in which both institutions and
accrediting agencies can provide the student-consumer more information
about the schools they attend or would like to attend. We believe that
the bill's provisions to create a ``college consumer profile'' take an
important step forward in this area. In my capacity as Chancellor to
the Keiser Collegiate System, I do not believe these provisions require
institutions or accreditors to develop or disclose a significant amount
of new data. Much of the information to be disclosed relates directly
to the criteria already required to be reviewed under the Act's
provisions on accrediting agency standards. What is important and new
about the development of the profile is that the information will be
provided and disclosed to the public in a consistent manner by a single
entity, the Department. Under the bill, accrediting agencies would have
the role of ensuring that institutions comply with these requirements.
Public disclosure of student achievement would also improve
institutional accountability. As recently demonstrated by the Education
Trust, graduation rates are disturbingly low at many American
institutions. ACCSCT believes it is increasingly important that
institutions participating in Title IV programs demonstrate the
benefits that students will receive from institutions' educational
programs. It is important for institutions to be more accountable with
regard both to student completion rates and other appropriate outcomes
that demonstrate student achievement and learning. In order to
accomplish this goal, ACCSCT believes that Congress, through
Reauthorization, should place a greater emphasis on the use of
meaningful performance measures to affect institutions' participation
in student aid programs, including placement, completion and retention
rates.
ACCSCT, like other national accrediting agencies, already assesses
student outcomes and each accredited institution's performance in this
regard. Our standards require reasonable and acceptable levels of
completion, placement and pass rates on licensure and certification
examinations. We have collected extensive hard data on these and other
measures of institutional performance. The statutorily mandated
recognition criteria for accrediting agencies have included assessment
of institutions' student achievement since 1992. In 1998, Congress
increased the emphasis on accrediting agencies' assessment of student
achievement by placing it as the first criterion to be considered in
recognition reviews of accrediting agencies. ACCSCT has developed an
equation in response that requires institutions to calculate completion
and job-placement rates and to maintain rates that are within one
standard deviation of the average for comparable programs or schools.
ACCSCT's ability to collect important completion-rate and job-placement
data on its institutions provides its institutions with clear bright-
line goals to meet. In 2002, the average completion rate for all
programs at ACCSCT-accredited institutions was 68.6%; the overall job
placement rate as 84.3%.
A recent article in the New York Times highlighted that a
significant majority of all students seek a higher education in order
to improve their career opportunities. According to a survey conducted
by the Center for Survey Research and Analysis at the University of
Connecticut, 64 percent of students surveyed indicated that the primary
purpose of a college education is to prepare students for specific
careers.\1\ The article provides an overview of efforts made by
traditional institutions to accommodate this purpose.
---------------------------------------------------------------------------
\1\ New Course for Liberal Arts: Intro to Job Market, The New York
Times, Saturday, June 19, 2004, A1, A15.
---------------------------------------------------------------------------
H.R. 4283's provision to amend the student achievement standards
required for accrediting agencies reflects the consumer interest in
outcomes, retention, completion and job placement. The bill's provision
accomplishes this in a manner that is deferential to the ability of
institutions and accrediting bodies to determine the appropriate
measures of student academic achievement based on an institution's
mission and the learning objectives of individual programs. As
mentioned above, ACCSCT and many other national accrediting agencies
have required a review of such data for a number of years and believe
that all institutions, and their accrediting agencies, should be
capable of collecting and reviewing such data as a way of strengthening
programs and holding them accountable for meeting their objectives, as
they define them.
IV. Addressing the Denial of Credit Transfers based on Accreditation
ACCSCT shares the desire of the Chairman and many on the Committee
to eliminate unnecessary burdens on students and on the Federal
Treasury. One important way in which to do this is to improve students'
ability to transfer credits. The ability of students to transfer credit
between institutions is a critical component to ensuring the efficiency
and effectiveness of Title IV funding.
According to one study performed by the Institute for Higher
Education Policy, over 50 percent of 1996 baccalaureate graduates
attended at least two colleges and universities. With the increased
number of adult students and the increased desire and need to continue
or expand one's education, this trend is expected to continue. Barriers
to the transfer of credit seriously affect the cost, time and the
student initiative needed to complete a higher education program. In
many cases, students that rely on Title IV student loans are forced to
retake courses for which credit is denied. This situation puts an
unnecessary financial strain on both individual students and on our
Title IV student aid system. At a time when the postsecondary student
population is increasing, unduly restrictive transfer policies burden
the already stretched capacity of the postsecondary education system.
Barriers to the transfer of credit are particularly prevalent when
students attempt to transfer credits from nationally accredited
institutions to regionally accredited institutions. The study described
above reviewed the established Transfer Credit Practices directory
(TCP), which surveys the transfer policies of major receiving
institutions throughout the U.S., and found that the vast majority of
regionally accredited institutions are included in the directory as
acceptable institutions of transfer, while most nationally accredited
institutions are not. The standards for recognition by the Secretary,
however, are identical for both national and regional accrediting
agencies. Thus, national accreditation is not provided the same status
as regional accreditation for transfer purposes despite the equivalency
of their quality assessment standards for the purposes of recognition
by the Department of Education.
I am personally familiar with the obstacles that some of my
institutions' students have faced. One student's story demonstrates the
problem. This student is a graduate of a bachelor's degree program at
one of the nationally-accredited Keiser schools, Everglades University.
Early last year, he sought admission to Nova Southeastern University, a
regionally-accredited institution, to receive a master's degree in
computer information systems. His admission was denied because he did
not receive his bachelor's degree from a regionally-accredited
institution. This denial was made in spite of Everglades' membership in
Florida's common course numbering system.\2\ NSU recommended to the
student that he retake two years' worth of courses in order to receive
a second bachelor's degree from NSU before advancing to the master's
program. Many other students attending ACCSCT-accredited institutions
have faced similar obstacles and we have provided specific examples to
the Committee with this testimony.
---------------------------------------------------------------------------
\2\ To be approved by the common course numbering system, the State
of Florida's Department of Education reviews the course content,
faculty credentials and outcomes of the applicant institution for
overall comparability. Approved courses under the system must be
accepted by all colleges and universities participating in the Florida
Statewide Course Numbering System.
---------------------------------------------------------------------------
Receiving institutions should not be permitted to deny the transfer
of credits based on the transferring institution's type of
accreditation. The Keiser Collegiate System is comprised of both
regionally and nationally accredited institutions. Although they differ
in processes, expectations and standards, I can attest from experience
that the national accrediting agencies are as effective and
comprehensive in reviewing institutional quality and integrity as the
regional accrediting agencies, if not more so.
The Commission supports H.R. 4283's provisions to alleviate these
transfer of credit concerns. We believe that the bill strikes an
appropriate and needed balance between the federal government's
responsibility to protect against waste and undue burdens tied to Title
IV funds with the need to protect the autonomy of institutions to make
appropriate transfer decisions based on course equivalency and student
proficiency. The bill accomplishes this by requiring that both
institutions and accrediting agencies adopt policies prohibiting the
denial of the transfer of credits based solely on accreditation, if the
institution from which the student is transferring is accredited by an
agency recognized by the Secretary. The bill explicitly protects the
rights of institutions to consider course equivalency and student
proficiency and explicitly states that the Department shall not
interpret these provisions to allow regulation in the area of
institutional curricula. Finally, the Commission believes the bill's
provisions to require that public disclosure of institutional transfer
practices by both institutions and the accrediting agencies will assist
in reducing arbitrary transfer decisions and will give students
critical information as they plan for higher education.
V. Reliance on Accreditation to Ensure Quality in Distance Education
During the last decade, the development of distance education has
provided an increasingly important means to achieve a postsecondary
education. The growth of online education is particularly important to
working adults and the more diverse circumstances of students. Today,
43% percent of the undergraduate population is over the age of 25. Many
of these adults are attempting to work and raise families while earning
their degrees. An online education provides opportunities to many
students who otherwise would not be able to earn a degree. Over 250,000
students have enrolled for an online degree to date, and enrollment is
expected to reach one million by 2010.
In expanding access to higher education, ACCSCT has emphasized that
one area in which accreditation could play an enhanced role in ensuring
quality is in removal of the 50 percent rules, which currently serves
as a barrier to distance education. Everglades University is a small
institution offering both campus-based programs and distance education
programs. Despite our success in distance education and a separate
rigorous and successful accreditation review process by ACCSCT of our
distance education programs, Everglades is limited by the 50 percent
rules in its ability to expand in this area.
The College Access & Opportunity Act takes important steps by
removing the 50 percent rules barrier. In doing so, the bill requires
accrediting agencies to have, within the scope of their recognition
from the Secretary, the evaluation of distance education programs.
ACCSCT strongly supports the bill's reliance on accrediting agencies'
ability to review and monitor the quality of distance education. ACCSCT
has already supplemented its own standards of accreditation to include
specific provisions and principles for distance education review and is
currently recognized by the Department as having distance education
within its scope of recognition. Whether accrediting agencies choose to
rely on separate standards or existing standards to review distance
education, we believe that the legislation should focus on the
accrediting agencies' capabilities to review these institutions or
programs with as much rigor as they do campus-based institutions, while
also recognizing their special attributes.
VI. Conclusion
In conclusion, the Commission strongly believes that accreditation,
and in particular national accreditation, provides a strong assurance
of quality for higher education in the United States. The Commission
also believes that Reauthorization of the Higher Education Act presents
an opportunity for Congress and the higher education community to
strengthen accreditation and to increase public disclosure of
information that is so important in determining the quality of our
higher education institutions. I thank you again for this opportunity
to testify before the Subcommittee.
______
Chairman McKeon. Dr. Crow.
STATEMENT OF DR. STEVEN CROW, EXECUTIVE DIRECTOR, HIGHER
LEARNING COMMISSION, NORTH CENTRAL ASSOCIATION OF COLLEGES AND
SCHOOLS, CHICAGO, ILLINOIS
Dr. Crow. Mr. Chairman and members of the Subcommittee, you
have already heard the scope of my enterprise accrediting
agency with about a thousand institutions. I am here
representing also CRAC, the Council of Regional Accrediting
Commissions. Together, the regionals accredit over 3,000
colleges and universities, with a total enrollment of
approximately 16.7 million students. I appreciate the
opportunity to be here today.
I also want to express the appreciation of my colleagues
and myself for over the past few months we have had good access
to many of you as representatives and to your staff to discuss
accreditation and reauthorization.
First, we are pleased that accreditation will continue to
play a key role in providing quality assurance useful to the
Federal Government. While honoring the distinctive and multiple
missions of U.S. Institutions of higher education so essential
for access for students, we will show our responsiveness to
changing expectations for higher education and the public
policies reflecting those changes.
H.R. 4283 proposes several new responsibilities for
accreditation, the major ones of which I will address. We have
recommended specific modifications of language to clarify the
exact scope of some of the new responsibilities. Understanding
that these modifications will be made, we have registered our
support for the role of accreditation as stated in specific
provisions of section H of H.R. 4283.
On agency accountability for student learning, we believe
that the approach in the bill is constructive to the extent
that it first continues the expectation that standards of
federally recognized agencies assure that we pay attention to
how institutions define and assess student learning. Moreover,
it appears to recognize the breadth of measures appropriate to
the diverse types of institutions that we accredit.
Second, it requires institutions receiving title IV monies
to provide public information about educational performance,
most of which we already require in our standards. We expect
that institutions will be able to provide a report fitted to
their educational objectives and drawing on the variety of data
they use to determine their own effectiveness.
And, third, it establishes reasonable expectations for
accrediting agencies to vouch for the effective distribution of
this information and to consider that information as part of
their on-campus review.
On agency accountability, as we expected, the bill includes
provisions for agency accountability.
First, we are to provide the Secretary with new information
about our site visitors. Much of it we have it in electronic
format, so we can provide it easily. We understand the
Committee has accepted our proposal that instead of providing
the Secretary annually with a list of all the site visitors
within our data bases, we would provide more useful information
by posting to our Web sites the names of evaluators that were
used in the previous year.
Public disclosure of accrediting actions and the findings
related to those actions is the largest single new
responsibility for accrediting agencies. Accreditors have
always disclosed actions, and several also give information
about subsequent required reports or visits. But disclosure of
information specifically useful to students in particular and
the public more generally will be a challenge. At this point,
the regional commissions have not agreed on a consistent
template that we might use, but it is one of our highest
priorities. We will need time to discuss among our ourselves
and our members the components of a program of disclosure that
will be accurate and fair.
On student mobility and transfer of credit, my colleagues
and I support how the bill reinforces the responsibility of
accreditors in encouraging greater transparency of transfer to
the extent that it affirms that accreditors will continue to
assure that institutions have appropriate transfer policies
which now will also comply with Federal requirements about
those policies. It affirms that the policies of an accrediting
agency would not limit acceptable practices solely on the basis
of what agency provides accreditation, and it sets a reasonable
expectation for an agency to have procedures for which it
reviews transfer policies during each accreditation review.
Several higher education organizations have expressed
concerns about the significant new recordkeeping and reporting
requirements in H.R. 4283, with a special note on those related
to transfer. At a time when students in their academic careers
move credits among institutions several times, we suggest that
the Committee and staff would be well served to hear from
institutions and those organizations their best estimates of
the time and expense that such new recordkeeping might entail.
And, last, on distance education and eLearning, concern
about eLearning seems to be directly related to the end of the
50/50 Rule. Very few institutions accredited by regional
agencies are disqualified by the 50/50 Rule, and almost all of
those that have are participating through the Department's
Demonstration Project. We do not believe that the price for the
abolition of the 50/50 Rule should be increased scrutiny of
eLearning provided by all of our member institutions. Moreover,
the quality of institutions accredited by us and now
participating successfully in the distance demonstration
project is evidence that even in the new emerging group of
virtual institutions we can successfully recognize the quality
the Federal Government should expect of us.
We, therefore, support the approach of the bill to distance
education to the extent that it recognizes that distance
learning should be judged by the same standards as all
learning; and we think the extra obligations asked of us about
distance education are ones that we are willing to accept.
Mr. Chairman, thank you very much for the opportunity to
testify today. All regional agencies would probably prefer that
the 1998 section H actually remain unchanged, but most of us
have engaged in discussions that help us understand why it may
be changed. Where it deals directly with accreditation, H.R.
4283 reflects that our recommendations have been heard and in
many respects honored.
Thank you.
Chairman McKeon. Thank you very much.
[The prepared statement of Dr. Crow follows:]
Statement of Dr. Steven D. Crow, Executive Director, Higher Learning
Commission, North Central Association of Colleges and Schools, Chicago,
Illinois
Mr. Chairman and Members of the Committee, I appreciate the
opportunity to be here today to discuss the potential impact of H.R.
4283, The College Access & Opportunity Act, on higher education
accreditation. On behalf of my Executive Director colleagues, and
myself I also want to express appreciation for the numerous
opportunities we had over the past few months to meet with
Representatives and their staffs on both sides of the aisle. Because we
know that time is a precious commodity on the Hill, we are particularly
grateful that so many made time to visit with us when we traveled to
Washington, D.C.
I head The Higher Learning Commission of the North Central
Association of Colleges and Schools. Recognized by both the United
States Department of Education and the Council on Higher Education
Accreditation, the Commission has a membership of 985 colleges and
universities located in the 19 states of the north central region. We
also are proud to count in that membership almost two dozen tribal
colleges whose authority comes from sovereign nations located within
those states. My Commission has accredited colleges and universities
since 1913. I also serve as the vice-chair of the Council of Regional
Accrediting Commissions (C-RAC). The seven regional accrediting
associations accredit 3,022 institutions enrolling approximately
16,619,890 students.
The United States has a system for quality assurance for higher
education unique in its ability to support the rich diversity of higher
education institutions so vital to the strength and capacity of higher
education in this nation. Regional accrediting agencies have assured
the quality of higher education in the United States for over 100
years. For the past 50 years these agencies, originally established to
provide self-regulation and shared assistance in stimulating
institutional and education improvement, have also served a unique
quasi-public role in that their accreditation decisions on institutions
have been accepted by the federal government as sufficient evidence of
educational quality to warrant disbursement to those institutions of
federal student financial aid and other federal grants. For the past 15
years in particular, Congress, the Department of Education, and
accrediting agencies have all been engaged in the very unique and very
American effort to create an effective and trustworthy partnership
through which privately held, voluntary self-regulation supports the
broad public policy agenda for higher education as defined by the
federal government.
During the decade since the Reauthorization of the Higher Education
Act in 1992, regional accreditors have shown that they can serve as an
effective shield against the types of fraud and abuse that concerned
the Congress then. As part of the on-going discussions that have
occurred every five years since the passage of the first Higher
Education Act, today we review again how effectively accreditation
generally, but regional institutional accreditation in particular,
serves the public interest through its gate-keeping role for federal
funds. Although deeply concerned by the new levels of federal oversight
established in 1992, most federally recognized accrediting agencies
have come to understand and accept the relationship we now have with
the Department of Education.
Before responding directly to the new expectations of accreditation
being proposed in H.R. 4283, I want to indicate for the record the
hallmarks of a successful link between regional accreditation and Title
IV gate keeping:
Effective Co-operation with Government: Accreditation has
proven to be an effective partner with the federal government over the
decades, responding effective) to new federal requirements adopted in
1992 and continued in 1998.
Best Qualified to Assure Student Learning: Accreditation
has proven to be responsive to changing public policies for higher
education through standards that emphasize access and equity and most
recently, assessment of student learning.
Necessary to Maintain Diverse Institutional Missions:
Accreditation honors and supports the multiple missions of U.S.
institutions of higher education so essential to the success of higher
education and to increased access for students.
Saves Taxes: Accreditation through private, non-profit
agencies provides exceptional service at no direct cost to taxpayers.
Support Institutional Improvement: Most institutions
support the claim that accreditation contributes value to their
operations and supports them as they strive to improve the quality of
education they provide.
Provides Expertise: Self regulation of the quality of
higher education through recognized accrediting agencies is an
effective tool because its reliance on expert peer review has
credibility with the public and with institutions.
All of us who lead regional institutional accrediting agencies
understood that legislators have expressed concerns about, areas that
affect regionally accredited institutions. To this end, we have spoken
with legislators and staffs not on , to explain how accreditation
currently addresses many of their concerns but also to suggest as well
legislative language for those concerns that legislators might
determine to need explicit attention in the law. H.R. 4283 does make
new demands of all of us. I should note that many higher education
organizations have registered reservations about the new requirements
in H.R. 4283 on institutions as well as accrediting agencies, We share
some of their concerns, particularly those about the extent of new
institutional reporting and record keeping included within the bill.
Therefore, we support continued discussions between higher education
organizations and the Committee and its staff
In this testimony I will focus on the new responsibilities H.R.,
4283 proposes for accreditation. They include expectations that through
our standards we will provide increased attention to student learning
as well as review the capacity of board governance, We will need to
provide strengthened evidence of our capacity to provide effective
quality assurance for distance education. H.R. 4283 sets expectations
for greater transparency in our processes and actions. It also calls
for our focused attention on institutional compliance with new federal
requirements regarding transfer. The bill sets new reporting
requirements with the Secretary related to our site visitors as well as
monitoring of the new Student Consumer Profile required of colleges and
universities. Several of my Executive Director colleagues and I have
recommended specific modifications of language to clarify the exact
scope of the new responsibilities, and, understanding that the
modifications will be made, have registered our support for the role of
accreditation as stated in Section H of H.R. 4283.
I believe it fair to say that disagreements about accreditation and
H.R. 4283 hive less to do with what constitutes good and acceptable new
activities by accrediting agencies than with whether it is appropriate
for the federal government through law and subsequent regulations to
require the new activities. Those of us who have worked closely with
legislators on Section H of H.R. 4283 appreciate the need to show a
somewhat skeptical public-and Congress-that we intend try assure that
higher education accreditation serves the common good. Now to some of
the details and recommendations.
AGENCY ACCOUNTABILITY FOR STUDENT LEARNING
Starting with the 1988 reauthorization that explicitly mentioned
the expectation that a Department-recognized accrediting agency include
within its standards measures of student learning, the federal call for
increased accountability for educational performance has been heard. In
fact, my Commission initiated its student academic achievement
initiative that year, and we have been energetically pushing our
institutions to conceptualize and implement assessment programs ever
since. Each of the other regional associations, as well as our national
counterparts, has made evaluation of student learning a central focal
point of our work. Each of the five regional associations that rewrote
their standards in the past four years placed achieved student learning
at the center of those new standards.
In determining how best to measure and share documentation of
student learning with current and prospective students and the public
at large, the Committee appears to have taken into consideration the
variety of learning goals and types of institutions in the United
States. The fact is that a surprisingly large number of our colleges
and universities have considerable amounts of outcome data that they
use to evaluate their own educational effectiveness. For some types of
institutions the data are fairly standard and provide grounds for
comparison. graduation rates, job placement rates, licensing rates, and
so forth. Each institution has data that are institutionally specific,
testifying to an educational mission achieved but not allowing for easy
benchmarking with other colleges and universities. We believe that the
approach of H.R. 4283 to accountability is constructive to the extent
that it:
Continues the expectation that a federally recognized
accrediting agency's standards include review of its institutions
programs to define and measure successful student earning. Moreover,
H.R. 4283 appears to recognize the breadth of measures interpretation
of this requirement that gives discretion to the Department to
interpret the law to allow for qualitative standards instead of the
bright-Line performance standards being called for by the recent Office
of the Inspector General report (EDOIG/A09-C0014, July 2003).
Therefore, we have proposed that broad language about threshold
requirements for vocational and technical programs be narrowed to speak
only to non-degree certificate programs. Even this change may involve
such significant new institutional record-keeping that the Committee
may want to consider whether the costs outweigh the benefits.
Requires institutions receiving Title IV monies to
provide public information about educational performance easily
understood by prospective and current students. However, we would allow
each institution to create its own report fitted to its educational
objectives and drawing, as appropriate, on the variety of data it uses
in determining its own effectiveness.
Establishes for Department-recognized accrediting
agencies (l) the responsibility to vouch for the effective distribution
of this public information and (2) the expectation that within an
accreditation visit the agency will consider the publicly-disclosed
student learning data as part of the review.
AGENCY ACCOUNTABILITY
Perhaps the most significant new responsibilities for accrediting
agencies are captured in new reporting requirements to the Secretary of
Education and a new requirement for new public disclosure of
accrediting actions and the findings behind them. While we understand
the goal of the bill to ensure greater access to a wide variety of
information about colleges and universities, we are concerned about the
scope of information gathering and dissemination that H.R. 4283 places
on the Secretary of Education. We have proposed, for example, that
instead of sending the Secretary hundreds if not, thousands of names in
our site visitor database, it makes more sense for each recognized
agency to post to its web site the names of site visitors used by the
agency in the previous year. We are pleased that the Committee has
expressed their willingness to accept this recommendation.
Since most regional commissions currently have information about
selection, training and evaluating site visitors on our web sites, we
can readily provide the data to the Secretary. Perhaps the Department
might be best served by simply using this information as well as the
names of site visitors when posted to each agency s web site. We are
somewhat concerned about the massive amount of consumer information the
Department will need to collect and assure its currency.
Public disclosure of accrediting actions and the findings directly
related to the actions is the largest single new responsibility in H.R.
4283 for accrediting agencies. All regional accrediting agencies
disclose accreditation actions, and some of them also disclose required
ongoing monitoring. Because for decades we have considered our
institutions to be our primary if not sole audience, disclosure of
information specifically useful to students in particular and the
public more generally will be a challenge. At this point, the regional
commissions have not agreed on a consistent template that we all might
use, but it is one of our highest priorities. We will need some time to
discuss among ourselves and with our members the components of a
program of disclosure that will be fair as well as honest; therefore,
we strongly urge that Congress signify to the Department that the
template for public disclosure should not be narrowly defined in
regulations.
STUDENT MOBILITY AND TRANSFER OF CREDIT
Accrediting standards hold that the institution ranting degree must
be accountable for the integrity of that degree. Although we also
require that institutions have transfer policies that are clear to
students, we appreciate the fact that transfer of credit continues to
be a matter of public concern. Although none of the regional
accrediting associations has policies that limit the variables an
institution should consider in determining transfer, we have conic to
learn that many of our members act as though we expect them to limit
transfer to credits coming from other regionally accredited
institutions. In recent years we have all adopted the CHEA principles
on transfer (November 2000), which mark a new consensus on good
practices in transfer, and we have forwarded them to our institutions
for study and implementation.
My colleagues and I support how HR 4283 reinforces the
responsibility accrediting agencies h) encouraging greater transparency
in transfer to the extent that it:
Affirms that accreditors should continue to ensure that
institutions have clear transfer policies, but adds the responsibility
reviewing compliance with new federal requirements that Title IV
institutions have in those clearly-stated transfer policies the
commitment to weigh more than the accredited status of an institution
in determining transferability of credits awarded by it.
Affirms that the accrediting agency itself not have
policies that would limit acceptable transfer policies and practices
solely on the basis of what agency provides accreditation.
States that a Department-recognized accrediting agency
will have procedures throng I which it reviews transfer policies during
each accreditation review to ensure that appropriate policies are in
place.
The law proposes that an accrediting agency also will review the
consistent application of transfer policies. We understand this can be
achieved through a spot audit of a random set of transfer records to
ensure that decisions are not made solely on the basis of the
accreditation of the transferring institution. The accreditation
process cannot be expected to judge the subjective decisions inevitably
involved in many transfer decisions.
Several higher education organizations have expressed concerns
about the significant new record keeping and reporting requirements on
transfer alone. At a time when many students move some academic credits
among institutions two or more times, we suggest that the Committee and
its staff would be well served to hear from those organizations or
institutions themselves their best estimates of the time and expense
this record-keeping might entail.
DISTANCE EDUCATION AND ELEARNING
Each regional Commission believes that it has been doing a sound
job of evaluating distance education generally and eLearning
specifically. We joined together just a few years ago to adopt a set of
best practices that inform our institutions as they implement eLearning
and our teams as they evaluate it. While we appreciate the concerns
that many legislators have about this particular modality of providing
education, we draw attention to the fact that on-line courses serve
large numbers of campus-based students as well as students studying at
a distance. In short, legislation that classifies all elearning as
distance education and then calls for different regulation of it will
inadvertently set expectations for what some institutions and their
campus based students now treat as scheduling option. We support the
approach of H.R. 4283 in avoiding such an approach, because we believe
that it would seriously impair the constructive adoption of improved
methods for teaching and for reaching underserved student populations.
The concern about eLearning appears to be directly related to the
call to end the 50150 rule that now disqualifies from eligibility for
student financial aid certain types of institutions heavily involved in
eLearning. Very few institutions accredited by regional agencies are
disqualified by the 50/50 rule, and almost all of those that are have
been participating in the Department of Education's Distance
Demonstration Project. We take no stand on the 50/50 rule, but we do
not believe that the price or its abolition should be enhanced scrutiny
of distance education (eLearning) currently provided by our member
institutions. Moreover, we would argue that the quality of institutions
accredited by us and now participating successfully in the Distance
Demonstration Project is evidence that even in the new groups of
virtual institutions, we can successfully recognize and encourage the
quality the federal government should expect.
Therefore, my colleagues and I support the approach of H.R. 4283 to
the extent that it recognizes that distance learning should be judged
by the same standards as all learning. We were pleased to see that many
of our views regarding distance education had been heard. H.R. 4283:
sets a reasonable expectation' that Department-recognized
accrediting agencies document that their existing standards provide for
effective evaluation of the quality of distance education, in the same
way that is done for all types of learning. Instead of providing new or
extra standards, it accepts the standard of comparability: namely, that
student learning in eLearning programs be comparable to that in campus-
based programs.
sets a reasonable expectation that a recognized agency
create and implement processes that allow it to monitor when
appropriate those institutions with dramatically increasing student
enrollments in their eLearning programs; this seems to mirror
appropriately current expectations that accreditors have set for
ourselves for rapid expansion of site-based delivery.
sets a reasonable expectation that our existing processes
for selecting and/or training peer reviewers include their capacity to
evaluate eLearning.
sets a reasonable expectation that accreditors evaluate
how institutions offering eLearning document the integrity of the
student engaged in eLearning courses and programs. Our colleagues in
the distance education field suggest that ``authenticity'' is a better
word that ``integrity'' since we want to ensure that the person taking
exams is the person who is receiving credit.
Mr. Chairman, thank you very much for the opportunity to testify
today. We all know that good legislation involves discussion and
compromise. All regional accrediting agencies would probably prefer
that the Section H remain unchanged from what it is currently. But most
of us have engaged in the discussions that help us understand why it
will be changed. Where it deals directly with accreditation, FIR. 4283
reflects that our recommendations have been heard and, in many
respects, honored.
______
Chairman McKeon. Mr. Kildee leaned over and said that is a
great panel, and I agree. I think your testimonies have been
very good, both your written and your oral comments here. And I
think that while I would prefer that we would just sit around
and have a visit, this is the system that we use. So I
appreciate you being here.
Dr. Keiser, one question. We have been criticized--or the
authors of the bill have been criticized for the transfer
policy that we put forward, that we shouldn't stop transfers
based solely on who is doing the accrediting. Members of
Congress have documented evidence that some institutions of
higher education accredited by regional accreditors refuse to
accept the transfer credit from schools that are nationally
credited. You made comment in your oral testimony that you have
a story about that. How widespread or pervasive is this
problem? Can you provide us with any examples of how students
have been affected by decisions to deny transfers based on
accreditation? If you could speak to that provision in the bill
that attempts to address this issue.
Dr. Keiser. It is a problem, and it is a problem that is
not just limited to Florida but to the 50 States. In many
cases, it is not based on malicious intent but just based on a
lack of understanding of the comparability of accrediting
agencies, whether it be regional or national. In some cases, it
is just between institutions and interest to maintain a
specific type of control over the number of courses taught by
institutions.
We had an example--and I submitted it in my written
testimony--about a student of ours who went through our
baccalaureate program at Everglades University. Everglades
University is a full participant in the common course numbering
system of Florida, which requires that each of the courses that
Everglades offers is evaluated by an independent staff of both
public and independent educators who review curriculum, review
course content, course objectives and faculty credentials and
the standards are comparable that the State requires as to the
southern region's requirements. Yet in the letters that I
submitted to you, Nova Southeastern University just wrote a
letter to the person dismissing the institution's courses, the
comparability of courses and said, because it was accredited by
ACCSCT, we could not accept their credits and suggested that
the student take all the courses over again. You would be
accepted, but you have to take all the courses that you took
already over again. This is a waste of resources, especially
that student, a title IV participant who would have to go back
and repay for courses that he already took; and we feel this is
inappropriate.
Florida--just as an aside, the reason the common course
numbering was created in Florida by our State legislature was
because the same problems exist between community colleges and
State universities. So it is not just the national, regional.
It is a problem for students in making sure that transfer of
credit is available to them in comparable and appropriate
times. We are not trying to force on students, but we believe
the Committee has taken a very reasonable approach to this in
at least the disclosure as to the policies and clear-cut
disclosure of the policies.
Chairman McKeon. Thank you.
Dr. Davis challenged the idea of letting the States do
accreditation. Could I hear from the rest of you how you feel
about that? I guess Dr. Martin took the opposite position.
Could I hear from the rest of you how you feel about letting
the States also participate in accreditation?
Dr. Erwin.
Dr. Erwin. Well, the current system is both the accrediting
organizations and the States ensuring quality; and I haven't
seen a conflict between the two. I think we have seen the
accrediting organizations evolve over a period of years and
become a bit more specific and strict in focusing on learning
outcomes than probably many of the States, but I really don't
see a conflict there. I think the accrediting associations, as
I said in my testimony, have had a positive role.
I think there has been some unevenness in terms of the
institutional teams. I think they are moving more toward data
and away from peer review. Let the data speak and not so much
someone's subjective judgment about what the students are
learning. But I see that has been evolving over a period of
more than 10 years.
At least the regional accrediting associations have been
going in a positive way. I don't know that I would replace
their role with the States. States sometimes have some specific
goals in mind for economic development that maybe an
accrediting association would not.
Chairman McKeon. Thank you.
Anybody else wish to respond?
Dr. Martin. We are very much for allowing the States this
option. Dr. Erwin slightly misspoke, and I think others may
slip into this language. We are not talking about replacing
private accreditation. We are simply saying that if colleges
want to go to private accreditors as they always have, fine,
but we should restore the situation where it was prior to 1991
where the world didn't fall apart and accrediting went on just
fine, but States were also an option.
I have to tell you, college presidents, board chairmen
speak to us and say that they are actually afraid that if they
do the kind of bold, innovative things that will rock the boat
within their institutions that they feel should be done that
they will get into trouble with the accreditors because there
is such a kind of interlocking network there; and some have
reported experiences with accreditors along those lines.
I have to tell you that this Committee should understand
that I have not yet found a sitting college president willing
to come forth and talk candidly about this issue, because the
accreditors have a lot of power over them. There are certainly
ones that will say what their colleagues would like them to
say, and I don't mean that they don't genuinely agree with
that. But that is a real concern and you have to think what an
awesome power this is. Accreditors like to talk about it being
accrediting and it is all private, private, private. Well, the
power they have is not private. They control $60 billion in
Federal funds; and the way it is today, a college cannot
survive without access to those student loan programs. So they
have a power this Committee, this Congress does not have. They
can close down a university. You could not do that. The
Secretary of Education could not do that. This Committee can't
do that. Accreditors can do that.
Right now, they are threatening to close down Auburn
University. What grounds? No educational issues have been
raised. It is because the board is overly involved in the
athletic program. Maybe that is an issue to be addressed, but
is that why the institution should be closed, with this
Congress trying to make such an effort?
So the accreditors have this enormous power; and one way to
put that power a little bit in a box is say, well, let us have
an alternative. If you want to be bolder than the accreditors
are comfortable with or if they are just being unreasonable,
there is at least a second alternative you could go to. I think
that be would be very healthy.
Chairman McKeon. My time its up. We will come back to this.
Mr. Kildee.
Mr. Kildee. I think I will come back to it right now. This
is a great panel, and we have point and counterpoint by Dr.
Martin and Dr. Davis. I think that is helpful to this
Committee.
Mr. Kildee. You mentioned the State option, Dr. Martin. And
Dr. Davis took a different position on this. In 1992, when I
was serving on the full Committee, we grandfathered in the
State accreditation. I don't know how many States, there are
not many.
Dr. Davis. Just New York.
Mr. Kildee. New York. I was going to say, I was pretty sure
it was just New York. New York is the one. Good staff right
here. So New York is the one. Might there not be a different
agenda--start with you, Dr. Martin--for the State in
accreditation than, say, an agency like North Central? Could
there be a different agenda, and maybe a university would be
tempted to move toward one rather than the other?
Dr. Martin. Yes. We have to look at the agendas here. You
mentioned North Central. I have to say some schools are now
being hassled by that accreditation because the Association
doesn't like their mascot. Well, that is not what Governors and
State higher ed commissioners are thinking about. What they are
wanting is what Dr. Erwin was talking about; many are looking
at performance budgeting. Can't we reward quality and
excellence and innovation? Can't we find ways to determine
which ones are educating students? Can their graduates write?
Reward that. That is the emphasis we find.
If you just ask as a matter of fact--and, you know, you can
go look at the Chronicle of Higher Education and see what the
different States are doing. This is what they are doing. They
are emphasizing performance, learning outcomes, accountability,
cost effectiveness. And I have to say, it seems to me that the
existing accreditors, they inch along in this direction, but
they kind of have to be a bit dragged, kicking and screaming.
Well, why not at least allow us an option, people who really
seem to care about these outcomes?
Mr. Kildee. Dr. Davis.
Dr. Davis. Thank you. I appreciate the opportunity to
respond to that. I can't help but look around the room and
wonder where all of them are. Because ``they'' is me, all the
other presidents. If you are talking about government, it is
you and us. And so often we do this, we put these labels of
saying they are doing all this to us. But in effect, reasonable
accreditation is peer accreditation. We help shape that. We
work at that all the time. It is not an easy process, not even
a tidy process. I compare it a lot to what goes on in both
legislatures and in Congress, a lot of debate, a lot of
difference of opinion. But it is not a they-and-us. It is all
of us working together to try to achieve the highest standard
we can for program quality, for accessibility for students, for
transparency for what we do.
There is very little that is not known about our
institutions, in truth. If you check with the IRS, with IPEDS,
with what we report to the states even as independent colleges
and universities, we are basically open books. And you know
what? I don't dislike that. I find that much of what we do
should be open to the public. But it should not be legislated.
And we should be very careful both the at State and Federal
level how far we go with doing that, as opposed to encouraging,
having public hearings to cajole and direct, even having the
Department of Education work with us in studies to determine
where we have shortfalls.
But we should be very careful, in my opinion, about adding
a new process, particularly at the State level, with 50
different opinions about how it is be done. I was a legislator;
I know the number of demands on the people's time. And the
ability to know enough about a subject like accreditation is
very limited. So I would urge caution with adding any other
State to that list as an accreditor.
Mr. Kildee. Dr. Crow.
Dr. Crow. As a purely practical matter, we weren't very
concerned about it, because we couldn't think of a State that
really wanted to do this. To be quite honest, if any of you
have watched the New York Board of Regents try to maintain its
status through the Department of Education, I don't know why a
State would want to do it, because the regulations are really
set up for accreditation as a private voluntary organization.
And to get a State agency in there, and to try to look and act
like one, is turning out to be very difficult work. So I simply
didn't think that there was--it was there. If a State wanted to
do it, fine. I doubt if very many institutions would choose it
as a gatekeeper, and I think they would find working with the
Department to be an incredible hassle.
Mr. Kildee. So you didn't really see States lining up for
this?
Dr. Crow. I can't think of a single State in the North
Central region that is going to line up to become its own
accrediting agency--or to provide its own accreditation.
Mr. Kildee. I thank the three of you for your responses.
Chairman McKeon. Mr. Ehlers.
Mr. Ehlers. Thank you, Mr. Chairman. A very, very
interesting hearing. I suspect I may be the only one, or one of
the few in this room, that has suffered through the
accreditation experience. Fortunately, I wasn't in charge, but
my closest friend at our institution was. And I have to say it
was a very healthy experience. But not so much the actual site
visit and discussions, but the 2 years of preparation for the
accreditation visit at the institution at which I taught, at
that time; Calvin College, Grand Rapids, Michigan took it very
seriously and did a complete review of the curriculum of
college, et cetera. And that was very helpful. I was, however,
not impressed with some of the issues that were addressed by
the accreditors: the matter of counting how many books were in
the library on certain topics and things of that sort.
But I guess what did concern me was an issue that has been
mentioned. I am not sure that they really looked at the quality
of the product coming out the door at the end of 4 years, and I
wish there was some way to do that.
And then, some of you have mentioned this already, we get
some measure with the GRE exam, but that is very specialized
and it is a small number of--relatively small number of people
that take that.
But it was clear to me that there are some institutions
that do very well and some that do not do very well. And rather
than a simple pass/fail, which is what you have with current
accreditations, I think it would be very useful to have--since
we are used to using As, Bs, and Cs, give rankings to
institutions as part of the accreditation process. That would
be a real guide to the students, to the parents, and so forth.
But it also would be nice to have good a national collegiate
assessment tool that you can assess the quality of the
students, what they have learned, and some overall sense. And
if any of you have any comments on that, I would appreciate
hearing that.
But let me bring up another point that concerns me. And
that is, if we get a number of different accrediting agencies,
as we discussed, the States and others, wouldn't the poorer
schools simply choose the easiest accreditation process rather
than choosing the more stringent one? That is another concern.
And a final concern is distance learning. I have--even
though my field is a technical one, and I have been using the
Internet for years and I think it is wonderful, it bothers me
that distance learning is somehow considered equivalent to
attending class, going one on one with faculty members. And
perhaps in my field of physics, even more important, students
learn a great deal from each other because they work on the
various assignments together. And that is missing with distance
education.
So there is a potpourri of issues that I have raised here,
and I would appreciate comments from any of you about any of
those points. We won't have time to do all of them, but fire
away.
Yes, Dr. Davis.
Dr. Davis. I will be glad to speak briefly to the first
point about outcomes, education. In the Southern Association of
College and Schools, especially with my years of involvement
there, probably the last 10 years have shown a major effort to
start to develop ways of assessing outcomes. And we use the
terminology ``institutional effectiveness'' to deal with that.
And a lot of the institutions really chafed under that for the
first 4 or 5 years until they began to realize the benefits of
actually assessing outcomes of student educational process.
Today, it is very difficult to be accredited by the
Southern Association of College and Schools unless you have a
well-defined institutional effectiveness plan that has a way of
assessing the outcomes of every single major at that
institution.
If you then add on top of that specialized accreditation,
which we do in a large number of fields, I think I indicated I
have 16 at my institution, they even go further with learning
outcomes in those specific areas that they are accrediting. And
we are making progress in that area. But it is a very inexact
science as compared to physics. And I think there is going to
have to be work that will have to be done for quite a few years
before we reach that point. But it is happening. And I believe
it is happening across the country. I know it is happening
quite effectively in the Southern Association.
Mr. Ehlers. I believe it essential to happen in view of the
great inflation mentioned and the Mickey Mouse courses that I
think Dr. Martin mentioned. We certainly have to do it.
Dr. Keiser.
Dr. Keiser. In the national accrediting arena, outcome,
evaluation, and performance is absolutely critical in terms of
especially the career colleges. Institutions are measured on a
very specific set of benchmarks as it relates to retention--
that is, students' graduation rates, placement, which is how
well they are--once they achieve their educational objective,
how well they do in the field--and then pass rates on national
licensing examinations.
It is my belief as well as the Commission's that it can be
done and it is being done to use very specific measures. Now,
the measures are not bright lines to each institution. It is
comparable institutions, comparing their data, and trying to
improve the institutions by having a measure of what a standard
deviation is. So we look at very clearly what the peer groups
are doing, and how do you improve? And you have a benchmark in
national accreditation.
Even in the regional accrediting arena, there has been
significant improvement in asking us to measure the learning.
And in our institution, we measure through use of pre- and
post-tests, what actual learning occurs.
And if I may talk about the distance learning, I would
gladly invite you to sit in on one of our classes. And what you
were saying is that students learn among each other in the
classroom. It is even more prevalent in an effective
interactive distance learning environment where, using thread
of discussions in chat areas, students get to know each other
better than sitting in a classroom, with the person in the back
falling asleep or not paying attention in the classroom.
Everyone has to participate and be involved. And if you have
taught like I have an on-line class, it is exciting learning.
Very exciting learning.
Mr. Ehlers. My time has expired. But may I just ask Dr.
Crow a quick comment on distance learning? You represent a very
venerable accrediting institution.
Dr. Crow. And I would repeat much of what Dr. Keiser just
said. Those who know how to engage students in a distance-
learning format, just as you know how to engage them in any
classroom setting, actually find ways to get students, the kind
of learning community there, that at times simply can't be
duplicated in a large classroom.
And so I would agree that good distance education--and that
is what we are after, good distance education--is a very
effective way for students to learn. And it is also a very
effective way for teachers to help them learn.
Mr. Ehlers. Thank you for giving me a few extra minutes,
Mr. Chairman.
Chairman McKeon. Thank you.
Mr. Andrews.
Mr. Andrews. Thank you, Mr. Chairman. I also would like to
thank the panel for their outstanding preparation and their
time this morning.
When it comes to transfer of credits among institutions, we
want to foster a policy of high quality. We never want an
institution to be compelled to accept credits that would fall
beneath its own high standards. But we don't want to encourage
discrimination either. And Dr. Keiser, your story about the
student at Everglades who was denied transfer of credits to
another institution accredited by a regional agency, was that
student given any other reason other than the fact that the
institution from which he transferred was not regionally
accredited?
Dr. Keiser. In the initial letter--and you should have a
copy of the letter in the material--it just clearly states: We
just do not accept credits from national accrediting agencies.
And that was the only reason. And I pursued it. It was very
frustrating to our institution. And they would not relent.
Mr. Andrews. Dr. Davis, it is great to see there is life
after being a legislator. I congratulate you on your
presidency, and I appreciate very much your unique perspective
as someone who has sat on both sides of the table.
In your testimony, you say that, about the provisions of
the Chairman's bill that deal with transfer of credits, that
the most controversial aspect of the actual language of the
bill goes well beyond what is necessary to achieve the purpose
of--and here I am paraphrasing--of having more transparency in
transfer of credits. And then you go on and say that the bill
also sets standards upon which transfer decisions should be
made.
I want to read to you from the language of the bill, on
page 166 of the bill, section 495, language that says, nothing
in this review--and by which they mean the review by the
accreditation agency. You understand the way this is set up is
that you now would have to have a policy that makes transfer of
credits more transparent, more readily available. And then when
they talk about the reviewing agency that is looking at that
policy, the bill says: Nothing in this review shall restrict
the right of the receiving program or institution to determine
on any other basis--meaning other than who did the
accrediting--or on a combination of that basis, together with
other bases, the credits the receiving program or institution
will accept for transfer.
Now, how is it, then, that there is such an abrogation of
the receiving institution's opportunity to set the standard? I
don't understand your testimony.
Dr. Davis. I think there are a couple of issues there. One
is I don't think any of us argue very much about the idea of
having a written disclosed policy about transfer of credit. I
think as long as we are allowed within the institutions to
determine the degree credibility, which is related to what
courses are accepted toward that degree--a very important
factor, because as you evaluate that, you can have a name on a
course but the actual content and the syllabus can be quite
different when an institution receives that information.
The whole area of transfer of credit, because there are so
many students transferring today, region to region, regionally
accredited to regionally accredited, specialized, and also even
nationally accredited, that it is one of the great
responsibilities within an institution to determine what really
relates to a degree. And more often than not, today what is
happening as we evaluate those credits is trying to give some
credibility to a degree.
Mr. Andrews. But, Dr. Davis, in the case we just talked
about, shouldn't the receiving university have had to--
Dr. Davis. They should have responded.
Mr. Andrews.--meet some--more than respond. Shouldn't they
have to say, look, there was something deficient about these
courses that you want to transfer, and they just don't measure
up to our standards? Shouldn't they have to do that?
Dr. Davis. I think they should not base it strictly on
accreditation. I do not disagree, But I do think--
Mr. Andrews. So that is what the bill says. How would you
then differ from the bill?
Dr. Davis. Well, one of the main differences that I think
is extremely important is all the data collection that is being
proposed about the percentage of what you accept and do not
accept, that is going to be one huge burden of cost within an
institution. Already--I hardly can describe for you the number
of people that is required to actually determine whether or not
credits are appropriate and should be accepted toward a certain
degree.
Mr. Andrews. But aren't those data you are already
collecting?
Dr. Davis. No.
Mr. Andrews. Tell me what happens. If someone receives a
transcript of a student, and the student says I would like all
my credits accepted, and someone in some office, the provost's
office or whomever, says, no, we are going to accept these 60
and reject these 40; isn't it just a matter of keeping track of
the 60 and 40?
Dr. Davis. It sounds very simple; but one student may have
four transcripts, one student may attend three or four
institutions. And when you start collecting that data and then
putting it in formats that you are oftentimes asking for, it is
a burden on the institution.
Mr. Andrews. But it seems to me, by definition, you are
already collecting those data, because you are making an
internal decision about which credits to accept and which
credits not to accept. You must have a record somewhere of what
you have looked at. Isn't it a matter of simply formatting the
record and disclosing it?
Dr. Davis. It sounds simple, but it is not simple. I can
assure you.
Mr. Andrews. I would be curious to hear why.
Dr. Davis. It is because of the volume. It is because of
the volume of transfer credits that are involved. It is because
of the complexity of the number of different kinds of courses
that you are evaluating--
Mr. Andrews. But don't you do it now?
Dr. Davis. To meet general education, to meet specialized
education.
Mr. Andrews. But you are already doing that now, Aren't
you?
Dr. Davis. I won't admit that it is simple, because it is a
complex process, and it will be made more difficult by what you
are proposing.
Mr. Andrews. I am not asking you to say it is simple. I am
just asking you. You said the data collection was a burden. It
seems to me you have already collected the data to make your
own institutional decision about which credits to accept and
which to reject. It is just a matter of to whom you disclose
the data, isn't it?
Dr. Davis. I respectfully disagree with you in terms of
what is required to provide that information. Even if you are
making a record of whether or not you accept a credit, it is
not easy then to put that in the format and make it available
for public disclosure, or for someone to understand, because of
the complexity of transfer credits.
Mr. Andrews. OK. Thank you very much.
Dr. Davis. Thank you.
Chairman McKeon. And I thank you very much.
What the letter said is that transferred credits earned at
an institution not accredited by a regional accounting body
such as North--is unable to accept.
So if you take that kind of a policy, it is very easy to
just say the credits are no good, and the student pays the
price.
Mr. Osborne.
Mr. Osborne. Thank you, Mr. Chairman. I would like to thank
the members of the panel for being here today.
I was interested in many of your comments. Dr. Erwin, I
think you mentioned that there is a void at the collegiate
level assessment of learning. And I certainly agree with you in
that regard. And I just wondered if you had any thoughts as to
how this might best be accomplished. You mentioned the NAPE
test, which is at the secondary education level. And we
obviously don't have anything like that at the postsecondary
level. And do you have any thoughts in that regard as to how
this might be undertaken?
Dr. Erwin. If you could ensure that there would be an
evaluation process where there would be some information
available--I mean, I listened, and a lot of the decisions you
are trying to make right now about whether distance education
is effective, whether transfer credit is effective, whether any
new instructional approach is effective, the only way to answer
that is to have a consistent measuring instrument, and then
where you will set standards and say we would like to see
students perform at this level for the college-educated person.
And then it becomes an empirical question.
But in terms of the Section 1025, I would like to see
perhaps that counsel make some specific action-oriented steps
to move us toward a more consistent evaluation policy where
each institution, for example, would collect, in a programmatic
way, student learning data about general education.
Mr. Osborne. Are you advocating some type of a national
test? Because it seems to me if you are going to compare--if
each school does its own evaluation, you really are going to
have a hard time. Like when you mentioned the NAPE, you don't
have anything like that.
Dr. Erwin. Dr. Osborne, I think the question you all have
to answer is do you want to compare institutions. I think you
all have to answer that question first. If the answer is yes,
you need a common measuring device. It is just like you would
have to ask the same question within a given State: Do you want
to compare the institutions within a given State? And if you
want to, you are going to have to have the same yardstick. You
can't have one yardstick over here in metric and another
yardstick in the English system and try to compare those
easily. There is a lot of error involved already in any kind of
test, because there is a lot of human error involved in any
measuring device of human abilities.
Mr. Osborne. Well, I agree you need a common standard,
certainly. And having been in a university for a lot of years
and having looked at a lot of transcripts, I saw tremendous
differences in what we were getting out of one school as
compared to another. And you are a little concerned about the
overall quality.
And, Dr. Martin, I guess I have a question for you. You
mentioned the lack of any core curriculum, and that so often
students graduate without much or any English or government,
math, science, economics. And would you advocate a core
curriculum being a part of a college degree?
Dr. Martin. Well, absolutely, Congressman. You know, if we
really cared--sometimes I feel the problem with higher
education, it is successful, of course, in so many ways, but
you feel there is a lack of central passion about making sure
the students are well educated. Because, really, I don't know
any 40-year college that doesn't have it as a general goal that
students be able to write well, for example. Well, then why
don't they all test and see whether their seniors can write
well? I often ask college presidents, do you do anything to
find out if you are succeeding? It is as if General Motors put
out automobiles and never tested one of them.
And, well, they tend to give me the process, saying: Oh, we
have got a writing center, we have got this and that. We have
got these various inputs. Well, do you know if they are
working?
And this is exactly--it is one reason I am so and my
organization is so passionately for the State option, is this
is exactly the kind of question a lot of the States are asking
because the parents and taxpayers are asking: Can the graduates
write? Do they have the quantitative skills? Easy to test. Why
not?
Mr. Osborne. Well, it does seem--when you listen to people
in the industry, the biggest complaint is inability to write
and communicate. And in almost every job you have to have some
ability.
The last question. Dr. Davis, you mentioned that we have
the best higher education system in the world. And I guess in
some ways that is true. But I wondered how you arrived in that
conclusion. What would your definition be of the best in the
world? We certainly have a lot of people being educated, but
is--and this is a tough question.
Dr. Davis. That is always a dangerous thing to give a
president the chance to say that.
I have spent 22 years as president thinking perhaps I might
serve as much as 5. And that 22 has given me a wonderful
perspective to look at the changes that have occurred in higher
education, because most of you know that the tenure of a
college university president is 5 to 7 years.
I have had a chance to travel in at least 20 countries
around the world, to work with at least 32 different
institutions scattered from Thailand to Japan to South America
to Africa, and I have not seen a better system anywhere in the
world, anyplace I have been, as far as the creativity, as far
as the diversity, and as far as the basic skills set that our
students have.
I will give my colleague Dr. Martin credit, he can pick out
one or two examples of the failure to do something within an
institution and condemn the whole system, but our system is the
best in the world. And you--why would students from all over
the world seek to come here the way they do today if it was not
the best? I will tell you what, they are discerning customers.
They know we have the best system in the world, and they want
to come. That is the best judge I have of having traveled and
seen, and to hear from those students.
We have students from more than 40 countries at my
institution, for instance, that judge us every day. And I thank
you for the opportunity to share my personal perspective on
that one.
Mr. Osborne. Well, thank you. I am sure there are a variety
of reasons why they want to come here, but maybe we do have the
best. I hope we do. I yield back.
Chairman McKeon. I thought that was an excellent question,
because many times many of us say we have the best. And I don't
know what we are actually measuring it against. I don't think
Dr. Martin said that it is a failure, and I don't think he
picked out one or two.
Dr. Davis. And I didn't mean--
Chairman McKeon. Just because we say we can do things
better doesn't necessarily mean it is a failure. And Mr. Kildee
asked if he could make a comment on that.
Mr. Kildee. Just to comment. I really--you know, looking at
our trade deficit, one of the great things that we export is
higher education. And I see that in Michigan, at the University
of Michigan, Michigan State, Wayne, Kettering, different type,
public and nonpublic universities. It is really one of our good
exports, higher education. Thank you.
Chairman McKeon. Thank you.
Ms. McCarthy.
Mrs. McCarthy. Thank you, Mr. Chairman. And I thank you for
the panel. It has been very interesting. And all the questions
I had, some have been answered, others have been rewritten. But
I will say, because I do spend an awful a lot of time in my
universities and I have had the privilege of going overseas and
seeing universities in other countries, and I have always
believed that our students are the best because they are well
rounded and they have the opportunity to learn so much in
different areas and come together.
Free thinking I guess is the word that I can think of. And
I think how we can measure that is on how well our students do
when they go into these big companies, and our companies are
doing well. So I think that is a good measure right there.
But going back on to the issue. Dr. Davis, you said it
would be a burden on schools to keep track of data related to
credit transfers. Isn't it a tremendous financial burden on
students to have credit denied out of hand just to be--just
because of the accrediting agency? But I want to follow through
with that, too. And I will go back to Dr. Martin, if the both
of you could answer this.
The question to follow up on the State accreditation: What
if any appeal process is there for a school which is denied
accrediting or whose accrediting is revoked? Did you hear me?
Dr. Martin. I didn't hear the end of that.
Mrs. McCarthy. It is my New York accent. Oh, and that is
the other thing, because New York already has this, so why
aren't we doing what New York does? So, basically, it goes:
What if any appeal process is there for a school which is
denied accrediting or whose accrediting is revoked, you know,
taken away? Which led back to your testimony.
And if I can throw one more in, because this is important
to me. When we have the transfer of credits, my special concern
for the bill would do away with specialized accreditation, for
example, the nursing accreditation. Being that I am a nurse, I
want to know how that is going to be handled as far as with
this bill. And I yield back to the panel.
Dr. Martin. Well, within the accrediting process there are
appeals procedures; schools get warnings, placed on probation.
There is a back and forth. In the end, these things often end
up in court, where the school being threatened with
deaccreditation is claiming some illegality took place. Of
course, that is very expensive and cumbersome. But the
accreditors in the end have sole authority over whether to
close--in effect, to close the school by withdrawing
accreditation.
Ms. McCarthy. Dr. Davis.
Dr. Davis. Again, I have had the experience of sitting at
all levels of this at one time or another. An institution
actually has the right throughout the process of peer
accreditation to respond to questions that will lead to a
status change for them. And they even can appear before panels
of the Commission to respond to concerns that have been raised
by the visits to the campus. If then the Committee, which votes
on whether or not to approve their self-study and the results
of their visit--which I served on that panel as well--they can
appeal that then. And there is an established process. And
after about 10 years--I have served on that appeals panel as
well. Not for the same institutions that we acted or
otherwise--and that process follows due process. Attorneys are
present. There is a long involved process for an institution
before they are ever rejected for membership.
But I will say this to you. Institutions have been denied
membership because they did not measure up to the standards.
And that to me establishes the fact that the system works.
The other question you asked about was specialized
accreditation. I am hoping, as I read the bill--and I have to
admit that I still do not fully understand it all, and the
Chairman has instructed me already on one or two items.
Specialized accreditation I don't think is going to be harmed
by this, because that is a voluntary form of accreditation that
institutions choose: I voluntarily agree to invite 16
specialized bodies to come and certify our program, so when our
students want to be licensed, they are able to sit for
licensure exam and be a professional. And I think those are
wonderful additions, to be quite honest with you, to regional
accreditation for institutions that are good and strong.
Mrs. McCarthy. And can we go back to--go ahead, Dr. Keiser.
Dr. Keiser. Well, in the national, similar to regional, it
is a very special process. For a school to lose its
accreditation, it will have many opportunities to respond to
the concerns that the Commission has, both in writing and in--
eventually in a presentation before an appeals panel. So when a
school is removed from accredited status, it is a very
stringent and--and due process is protected at all times.
In the terms of specialized accrediting agencies, our
institutions have--we have a total of 16 distinct
accreditations. It is voluntary, it is very cumbersome. But the
ultimate is to give our students that additional recognition.
And that is why they are all voluntary. Some requirements for
practice require accreditation, like in terms of x-ray
technology or things like that. But we--you know, we invest in
that process, one, to make our programs better, and, two, to
give our students the ability to have recognition by the
community. So it is a--you know, it is a burdensome process,
but it is valuable.
Dr. Martin. If I could, Congresswoman, just to make it
crystal clear. There is due process, but it is due process
within the accrediting association that is really in the role
of judge, jury, and prosecutor, but conducting those roles
under certain rules that are well known and well established.
Mrs. McCarthy. Thank you very much.
Chairman McKeon. Thank you.
Mr. Castle.
Mr. Castle. Thank you, Mr. Chairman.
As the Chairman knows, I head a Committee that deals with K
through 12 education--Subcommittee--and No Child Left Behind,
which I thought was going to be the toughest piece of
legislation. But the more I look at this higher ed bill, the
harder I think it is. And I just give you credit for trying to
work through this. You and Mr. Kildee deserve gold stars for
this one. This is really tough.
I have some general comments and then perhaps a question or
two. I mean, I agree with everybody else that has spoken about
this, that we probably have, collectively, the best higher
education system in the world. That doesn't mean that we don't
have flaws, problems, and some doing better than others.
And, to me, there are certain inherent problems. I think it
has become too expensive. And I think the rate of increase in
expenses is, frankly, absurd. That is not a subject of this
hearing, but I just can't resist saying that with all of you
there. I just think something has got to happen about the cost
of higher education in America. And we as a Federal Government
just can't increase Pell Grants and other things and loans, et
cetera, in order to accommodate that. There has to be--
something has to be done.
I also think it is not transparent enough. You probably
worry about what is the U.S. News and World Report when they
come out with their various ratings, et cetera, what are they
going to say, or whatever. But I think the reason people are
interested in that is it really gives you sort of a broad--
whether you agree with all the categories or not, it gives you
sort a broad interpretation of what is going on in colleges.
People don't see that. And that is why there is so much
readership interest in that.
Most Members of Congress have college degrees, but frankly,
most of us didn't do it by distance learning. So we talk about
distance learning, we get a little confused about an area that
we aren't really used to in talking about that. And we are not
really, frankly, used to for-profit institutions in education.
That is new to us as well. Not to suggest that any of those
things are bad. Or even career education, per se. It is more--
to me, it is more specific than it used to be and it is more
prevalent than it used to be in some form of higher education.
And now there is this accreditation confusion. I just, I
thought, sort of basically understood accreditation until I
started preparing for this hearing. This is the most difficult
and confusing subject I have ever dealt with, and it is going
to take a lot of resolve, I think, for all of us to work out
something that will work well enough.
But I actually want to go back, Dr. Erwin, to what you said
early on actually. And it is something which I think you are
doing internally rather than externally, and that is that I
don't think there is enough focus on education in higher
education right now. And that worries me a lot. I mean,
frankly, this whole business of grade inflation, of reduced
weeks of the year the kids are going to school now, the Fridays
off, the lack of discipline in terms of what is demanded of the
students, has really started to bother me a great deal.
And I was very interested in your comments in terms of all
that you are doing with respect to looking to the schools and
the--I am sorry, the students in the first year they are there,
and then thereafter, to see how much gain they have really
made. I assume that that is an internal mechanism? Or you do it
for the process of accreditation? And do you know of other
schools which are doing it? Because I think it is frankly,
something that we need more of in terms of looking at how our
colleges and higher education in general is really doing.
Dr. Erwin. We go way beyond what is required. There are
very few institutions that are probably out there doing as much
as we are. But you are exactly right, we do--we have two broad
analytical strategies. We look at students, we test them when
they come in and almost 2 academic years later to see how they
change over time. Some people refer to that as value added to
the institution.
In some other areas, we also set a standard. When I think
of standard, I am talking about a standard on a particular
assessment instrument. And we say that when students have these
courses they should be performing at this level. When we won't
let them in some areas, like information literacy, which is the
ability of people to find and access information, whether it is
on the Web or any kind of electronic data bases, we want them
to be able to meet that standard before they can go on to the
second year of their undergraduate experience.
Mr. Castle. Not to interrupt you, but my time is obviously
running out. Do you make decisions about the continuance of a
particular course of study as a result of what you learn from
that, or how a particular professor is doing from looking at
that? Do you actually make decisions from it?
Dr. Erwin. We have not used it for personnel evaluations
for faculty. We have used it for student progression. They have
to know this material or do this skill before they move on. But
we have not used it for individual faculty evaluation.
Mr. Castle. Well, I am concerned about the proliferation of
offerings out there by our schools. I am a believer in sort of
a tighter education system, and make people like me take math
courses and things like that. I think it is a good discipline.
Does this help you--or if you know about other colleges, does
it help you in terms of perhaps elimination of some of those
rather esoteric, perhaps unnecessary, courses?
Dr. Erwin. Well, what we do is in our general education
program, we require that the courses that are initially in the
curriculum, they have to have positive data, positive student
learning data, for those courses to remain part of the option
in the general education curriculum. So, I mean, that is part
of the institutional policy. No one has told us to do that
outside the institution.
And so what has generally been tradition in higher
education is once you have a course approved in a particular
curriculum, whether it is for general education and the major,
it kind of tends to stay there for a long time, if not forever.
So we try--we took apart, abolished our entire general
education program--which, at my institution and typically at
most institutions, is one-third the undergraduate curriculum--
and we rebuilt it a block at a time, trying to--very
deliberately deciding what we wanted the college-educated
person to know to be able to do.
So, yeah, those courses--if the students are not learning
what we want them to learn in particular courses, those courses
cannot be used to satisfy requirements anymore.
Mr. Castle. Well, thank you. And I thank the entire panel.
I am sorry I didn't have a chance to ask the rest of you
questions, but I think the Chairman would have had a fit if I
started to do that.
So I would yield back to the Chairman.
Chairman McKeon. Thank you.
Ms. McCollum.
Ms. McCollum. Thank you, Mr. Chairman. I have a lot of
questions, but I want to maybe get some quick responses on a
few questions that I do have.
Dr. Martin, can you provide to this Committee the school
that wasn't allowed to be credited because of its mascot? Do
you know which school it was?
Dr. Martin. The controversy. One is University of North
Dakota, and another at the University of Illinois.
Ms. McCollum. And they were going to be refused entire
accreditation by every--regional and national accreditation?
Dr. Martin. I just know that they are being given trouble
by the accreditors over those.
Ms. McCollum. Oh, you know--
Dr. Martin. There is controversy in the papers.
Ms. McCollum. That was a very broad statement that you
made.
Dr. Martin. I used the word ``hassled,'' I believe.
Ms. McCollum. Well, I won't get into arguing. Words are
important for choice. You also, after we heard one of the
gentlemen, part of the panel, saying that there is due process,
going all the way through to due process within our courts,
you, Dr. Martin, also then came back and said that these
accreditation bureaus--there is no court--you said they were
judge, jury, and everything?
Dr. Martin. The process is entirely within the accrediting
organization itself. It is not in any kind of an appeal to an
independent body outside the accrediting organization. So the
very group bringing--threatening your accreditation is also
conducting the appeals process and deciding whether your plea
should be upheld or not.
Ms. McCollum. And so any gentlemen on the panel, you agree
with that? Or is there another, is there another appeals
process and we are not having full disclosure here? Gentlemen?
Dr. Davis. There obviously is a different appeals process.
Different individuals are involved in that appeals process.
And, again you remember, this is a peer process that we are
talking about. And due process is followed throughout and with
all the rights, as I said, of attorneys present, records kept.
And then the final appeal body--and most people don't object to
this, we all recognize this--the courts are the final arbiter
if we can't solve our own problems.
Ms. McCollum. And, Dr. Davis, what courts are those?
Dr. Davis. Those are the courts of the land, both State and
Federal, depending on what the violation or the charge might
be.
Ms. McCollum. So it isn't all internal?
Dr. Davis. No, it is not.
Ms. McCollum. Thank you.
Dr. Keiser, I fully understand the frustration about not
having credits transferred. Minnesota just recently--well, not
that recently--went through and tried to do it seamless, for
parents, for students. But people still have to have personal
responsibility in the college that they choose, the courses
that they choose if they are looking to transfer.
Personal responsibility. When you haven't been able to get
your programs regionally accredited, were you given a course of
action to take in which to have your programs accredited?
Dr. Keiser. In this particular case, the school is a
nationally accredited institution. Yet, it is also part of a
Florida common course numbering program where each course was
evaluated by groups of educators, including from State
universities and independent institutions, to determine
comparability. Those credits would have been and ultimately
were able to be transferred into a public university. The fact
was, there was no evaluation process other than the fact who
accredits the institution. In this particular case, it was ACC-
SAT, and yet one of my institutions which did the freshman/
sophomore, which is regionally accredited, was automatically
accepted. So it was very arbitrary and very capricious. And
there is no appeals process to institutions like that, at least
not at the institutions I discussed, because in fact I talked
to the president, talked to the president personally as a
personal friend, and, you know, there was just a stone wall.
Ms. McCollum. I just have another second here left. And I
find it interesting that we are holding colleges responsible
for students entering college not able to write. And I do know
that students sometimes need a little brush-up or something
like that. The college will offer a remedial writing program.
They take it, they don't get a credit for it. They might try to
push it when they go to transfer to get a credit for it, but
they are going to say no, I am sorry, this isn't going to
transfer. This was a brush-up course.
Is it the college's responsibility to be held accountable
when a student who is a freshman, that they are allowed to come
in, needs to take these remedial classes, that somehow they be
transferred, or somehow the college somehow isn't living up to
its accreditation when it tries to help, and in some cases an
adult returning after being out of the process maybe for 20
years where math and science has really changed?
Dr. Davis. May I respond? You have just touched on the most
sensitive question related to the transfer of credit, in my
opinion. And that is, all of us accept transfer of students, a
lot of them. And when we do that, we take responsibility for
certifying on graduation that they meet the requirements of our
degrees. So we do share that responsibility with the student.
And I emphasize that to parents and to students regularly when
this question comes up at the end, that is a shared
responsibility. We are going to do everything we can to help
you meet the requirements of our degree, but you came in as a
junior and you have already in effect been given credit for
knowing how to write, in effect, from freshman writing.
And we do have some responsibility there. And we oftentimes
even have remedial efforts at writing at the junior and senior
level when we know that occurs. But it is a shared
responsibility, and I appreciate your bringing that forth very
quickly, that, when you choose your institution, when you
choose what courses you are going to take, you are setting some
of the answers to what is going to happen when you apply for
transfer of credit to other institutions.
Ms. McCollum. Thank you, Mr. Chairman.
Chairman McKeon. Thank you. And that is why in the bill we
are asking that we have a transfer policy that is up front,
objective, and the student when they start a school will know
what will transfer when they leave that school. That is why we
are asking for that in the bill.
Mr. Burns.
Mr. Burns. Thank you, Mr. Chairman. I thank the panel. You
have been very gracious with your time and your expertise.
I spent 20 years in the university system at Georgia, and I
have been on accrediting task forces at my university for SACS
and AACSB, and I represent the University of Georgia along with
another dozen or more schools of higher education. So I have
been down the road. I have even taught an on-line course. So,
you know, I have a bit of experience there, as a matter of
fact, a whole lot more than one.
I want to talk about accrediting bodies. There are national
bodies, there are regional bodies, there are professional
accrediting agencies. Are there too many? Are they
proliferating? How do we--we are going to rely heavily on
accreditation as a measure of quality. Now, how do we ensure
that the accrediting bodies indeed have the capability and
skills and ability to indeed evaluate their members?
Dr. Martin or Dr. Davis.
Dr. Martin. Well, I must say I certainly wouldn't want to
narrow it. It is already, in effect, regional monopolies with
just a few exceptions of certain kinds of institutions that go
national. That is one reason our organization has endorsed the
idea of restoring the right of States to also be recognized by
the Secretary as accreditors, because you get a little more
competition into the system and some alternatives from the
people we know to be very, very concerned with the educational
performance of the institution. So I think we need more
competition, not less.
Mr. Burns. Dr. Davis?
Dr. Davis. Yes. We live in a wonderful country and we have
a great arbiter here that we oftentimes don't pay enough
attention to, and that is the consumer, the student. And I can
assure you, if you have AACSB accreditation within a
university, you are going to do better competitively with
students and business because they know the value of that. It
says something. And I think the same is true for nursing, I
think it is true for a number of the disciplines. It is an
important consideration.
I don't think there can be too many reviews of an
institution. I wish we could coordinate those more. I am
certainly not encouraging you to legislate that, however. I
think that is the responsibility--we have to figure out how to
do that.
I have 16 different groups come and visit my institution
over a 10-year period in addition to regional accreditation.
And that is a chore to coordinate all that. But there is value
from that, and the consumer eventually decides the value of it,
and they encourage us then to have those accreditations.
Mr. Burns. I would agree. I think that certainly in the
specialized areas where we are having new disciplines that are
developing, and new standards, especially when you get to
licensures and those kinds of issues. I am a little cautious
sometimes in competing--in competing environments where new
accrediting agencies may pop up in lieu of the recognized
standard.
I would like to go back to my colleague Mr. Osborne's
comments a few minutes ago. How do you compare institutions?
And I will tell you, I have some reservations about a national
standard. I am not sure that is something reasonable that can
be achieved. I don't think the government needs to evaluate the
institutions, but I certainly agree with Mr. Castle that the
consumers need to be able to do that. They need to be able to
look at the outcomes, the associated outcomes with prospective
students, and certainly their families, as they do that.
I want to shift a minute to distance learning. The biggest
challenge that I faced in dealing with distance learning was we
were moving from a contact model, contact hours, to an
outcomes-based measure. Can you provide input on how you are
going to evaluate those two things? Dr. Keiser?
Dr. Keiser. I am not sure that is a necessary requirement
in distance learning. In fact, we have very strict standards in
contact. The only difference is it is an asynchronous process
that students can be involved 24 hours a day, 7 days a week. We
have very specific contact requirements, and our software
measures the amount of time that is invested in the process. We
have a specific amount of time that the students must invest in
communicating through our various communication models. And we
have evaluate the students by the time involved in the process.
So we are very outcomes-oriented, but at the same time we still
have a very strict requirement in terms of time on task.
Mr. Burns. Is this model--again, I have taught in a number
of options. But contact in the on-line world is different from
contact in the traditional world. And I concur with you, the
quality of contact can be far superior in an on-line
environment because of the direct involvement. But again, the
challenge for the faculty member is ensuring that level of
involvement.
Dr. Keiser. Absolutely. And that is the critical
difference. The same faculty who are speaking and may be doing
just a platform kind of environment where they are lecturing
are not necessarily the appropriate faculty members for
distance learning. And you have to train your faculty to
produce the same kind of outcomes you would in a classroom
environment but using different strategies. So we find--and,
again, we are very excited by the contact time, in fact greater
amount of time by students, in an on-line environment than just
sitting in class, going to class 3 hours a week in a particular
class for 16 weeks.
Mr. Burns. Thank you, Mr. Chairman. I yield back.
Chairman McKeon. Thank you very much.
Mr. Payne.
Mr. Payne. Thank you very much. This has been a very
interesting--something I have never given too much thought
about, only being in elementary and secondary education as a
former teacher. But I did follow students as they applied to
college and, you know, happy when some got in to where they
wanted to, others on waiting lists and so forth.
But I just have a quick question because I know very little
about the way colleges--the accreditation organizations become
assigned. Do colleges have the right to select the accrediting
organization or is it done at the regional base?
Dr. Davis. The regional accreditation is based on where
your institution is located. There are five regional bodies;
and depending on where your institution is located, if you want
to receive Title IV funds and if you want to be regionally
accredited, you have to do it within that region.
There are some programs that cut across regions, however,
and that requires the cooperative agreement between the two
regional bodies to work out how that is done.
Specialized accreditation, on the other hand, is by choice
of the institution for the program that they have. Some people
would say you don't really have a choice if there is a
licensure exam that you must prepare for that student in order
to graduate and be a professional. So if you want to have, for
instance, a physical therapy program, you must be accredited by
that body, and your students then can sit for a licensure exam
at the end of it.
Now, national accreditation is slightly different. People
do choose to apply for accreditation with national bodies.
Mr. Payne. Now, I heard--that is very clear. I heard that--
I know that Dr. Martin supports the States being able to
accredit colleges within their States. Where did the rest of
you fit in on that, quickly?
Dr. Keiser. Our organization has not taken a position on
the States. But what is interesting is the issues that Dr.
Martin brings up I think are addressed right now by States,
because all institutions have to be approved or licensed at a
State level prior to receiving accreditation. And the States,
if the States wanted to impose a particular set of educational
requirements, they have that opportunity now.
I served on both State licensing boards in the independent
sector in Florida for vocational and collegiate institutions,
and frankly we don't have the resources or the structures to
provide the same kind of function that accreditation does,
because, first of all, there are so many more institutions and
many of them are not accredited, and we have different
requirements for the diverse group of institutions that we
license.
With accreditation, you are taking a different kind of
institution that is more focused toward the needs of
improvement, self-improvement, development, and not all
institutions want to be accredited.
Mr. Payne. Dr. Crow.
Dr. Crow. And I will--just to repeat. Most States at this
point, I think, feel that they have the flexibility and the
freedom to shape the education in their States as they want to.
I just don't see them as being answerable to the Department of
Education for how they are going to do accreditation for
gatekeeping purposes. I don't think they are interested in that
business.
Dr. Martin. Well, I must report for the record that we are
in contact with some people in States who are interested in
that option.
Mr. Payne. Dr. Erwin.
Dr. Erwin. I think the States have taken a more precise
role, and that is, they review specific major programs. They
have to approve them before they go--before an institution can
grant a new major program in many States; and in many States
they also can abolish particular programs because they are
obsolete. So I think there is still going to be a shared
responsibility, regardless of what you do.
Dr. Davis. I will just add one word. I am opposed to States
being accreditors. The States have always exercised their
responsibility to determine who will operate within that State,
and they have been very reasonable with the independent sector
of higher education with not restricting the freedom, then, to
create new programs that are oftentimes not able to be done by
public institutions or through public treasury. And, as a
result, everybody has benefited.
And I hope that in what we do here, we don't encourage
something that is not needed. And that is the position that I
take. It is not needed or desired to encourage States to be
accreditors.
Mr. Payne. I have three quick questions, since there is no
one behind me, and I know the Chairman might give me the
latitude to ask these quick questions because he is a very nice
person. You should hear me in the other room talk about him.
But that is another story. I just need the time now.
How do you feel about this U.S. News and World Report
business? I mean, they come out with the--do you think that
they do a credible job? Do you think that they are helpful? Are
some categories destructive? You know, the party college of the
system and the one where you have the--whatever. You know, some
of the categories. And how do the colleges feel that they can
actually react against that? I don't want to abuse the time too
quickly, but it is too important, and maybe a quick answer.
Dr. Erwin. Well, I had already responded to that in my
testimony. You have to ask the question initially, how much
students learn. Is that important to you as a consumer? And if
it is, you are not going to find that in the ratings. Now, it
is not U.S. News and World Reports' fault. It is because many
institutions do not collect that information. Specifically, The
U.S. News and World Report rankings are based on reputation,
amount of resources, alumni giving rate, for example.
And, for example, there is a survey given to the presidents
and the directors of admissions, asking them to rank or
evaluate the reputation of a long list of institutions.
Dr. Erwin. Often, they really have not heard of what is
going on at another institution, much less how do you really
know much students are learning. If your concern is about
learning, you are not going to get that.
Dr. Martin. I wouldn't be critical at all of those surveys.
They are reporting the information they have. But you do
wonder, why isn't higher education focusing more on this
question of what students are learning? Why aren't there
results being made available to consumers? Why isn't that a
real part of the accreditation process?
And I suggest you look at the track record. You look in
vain for cases where that is the issue that a school's
accreditation is being threatened on.
Dr. Davis. Presidents like myself chuckle with the U.S.
News and World Report because if you happen to be ranked really
high, it is nice. But if you happen to be not ranked in the top
20 or so, then it is not a very good report.
It gives you basic information about a number of factors
that the public wants to know. They would buy the paper
otherwise. It is a consumer-oriented thing that works for U.S.
News and World Report. They could go further, if they wanted
to, with the data they have, with analysis. They choose not to
because the public will only read so much and their magazine is
very popular. That is a very popular issue that comes out.
It is slightly dangerous for a student and a parent,
however, to sit down with that and find a match for a son and
daughter. It takes more than U.S. News and World Report to do
that. And finding that match in the diverse system of education
that we have in this country is hard work for parents. And
those of us who run these institutions like to work with
parents and help get a good fit, because when we do, that
student stays for the 4 years and then we are not in the hot
seat for not graduating the right percentage of those students
that come. Because that decision, more often than not, is made
by the student more than it is the institution; but we get
credit or blame when it works, and we share that credit and
blame.
Dr. Keiser. Career education, which is increasingly a large
portion of higher education, is not really relevant to us.
However, we would like to see a U.S. News and World Report
looking at institutions that have career focuses, looking at
how many students that start the school actually complete and
how many of the students who started in a particular major get
in the field that they are trained for and how many people that
went into nursing or went into lab tech, how many actually
passed the national boards. We would love to be compared in
that environment.
Dr. Crow. I think about 80 percent of our students choose a
college by its convenience of location. They are not, in fact,
shopping. They want some assurance if where they are going to
go is, in fact, going to provide an effective education. They
don't have many options. They are not ready to move across the
country or move out of the city.
U.S. News and World Report, as far as I am concerned, is
really valued by the top 100 and they try to maneuver who gets
in it. But for the vast bulk of our students in today's
American higher education system, they don't have choices like
that. They are going to choose what is most convenient, and
they want to know that it is going to be effective and OK for
them.
Mr. Payne. Thank you. This may be a yes or no answer, the
new laws we have--PATRIOT Act, et cetera--has that impacted on
your foreign students? I know in some local schools in the New
Jersey area, especially New Jersey Institute of Technology, the
College of Medicine and Dentistry, they have not only had a
tremendous impact on students, graduate students and faculty--I
wonder if that is general or just close to the East Coast. Just
``yes'' if there is an impact, or ``no,'' more difficulty
getting in and out of this country.
Dr. Erwin. Yes, it has impacted our institutions, made it
more difficult for us to have international students admitted
into the country, and we have--admitted into an academic
program.
Dr. Davis. Yes. In a number of countries, it is five times
harder to get a visa today than it was, for the safety of our
country.
Dr. Keiser. Yes. We had a major program in China and we
don't have that program anymore.
Dr. Crow. What I am seeing is a concurrent push toward
setting up American higher education abroad. If it is difficult
to get the students into the country, then let us set up
centers abroad to serve them there.
Mr. Payne. I thought that outsourcing was bad already.
Thank you very much. I agree that, you know, the students are
the ones coming over here primarily, and we are keeping out the
wrong people. I wish we could keep out the people who want to
do harm to this country, but the students and the professors
who are foreign born are having an absolutely horrible time.
We had students afraid to go home for Christmas or
Thanksgiving a couple of years ago because they were afraid
they wouldn't be able to get back in.
Once again, I appreciate the testimony, and I appreciate
the Chairman giving me this extra time. I don't want to get
into how jobs and areas that--you talked about the 80 percent
going regional. And if you are going to make an evaluation
based on job--job performance, and if you are in a depressed
part of the country, then you are not going to show the same
kinds of high indices that you are going to have in an area
that is booming. But I don't have time to get into that.
Chairman McKeon. Thank you.
Mr. Tierney.
Mr. Tierney. Mr. Payne yield? Thank you and thank the
members of the panel. Let me take this on a different tack, if
I could. What effect, if any, does a school's technology, the
ability of that school to have technology on campus, provide it
for the students or have its faculty use it as a tool in
teaching, what effect does that have on accreditation or what
should it have going forward?
Dr. Davis. It is an expectation and a requirement that you
have up-to-date technology, that you have policies that
describe how you use that technology and that you evaluate it,
the results of what it does to the educational process. And
pretty much, in my experience, institutions that are not up to
date, that have not done what they should do in terms of
investment are not teaching at the level today that they should
because it greatly enhances interaction between faculty and
students and brings a world of knowledge to your fingertips
that you have spent days trying to find in the library. The
Internet itself is used every day in the classroom, in a
pharmacy class or in a number of other programs. It is
extremely important.
Mr. Tierney. My concern with that is that with public
higher education institutions, where they don't have the big
foundations to provide them with resources to get those kinds
of assets on campuses and where the State legislatures have
been cutting back significantly every year, if we don't do
something here and we have a piece in title 3 that allows us to
do some grants for public higher education institutions to help
smart campuses move forward, if we don't do that, then they are
going to run the risk of falling out of accreditation.
Dr. Keiser, I didn't mean to cut you off.
Dr. Keiser. The national accreditation, especially our
commission, we do two things that evaluate that process: One,
we usually send out an employer, someone who is in the field,
in the area, to help in the evaluation process to see that the
equipment and the facility and the teaching methods are up to
date and appropriate for the community.
Additionally, we have a very specific requirement, program
advisory Committees, that are including employers that review
curriculum and review the technology that are included in the
program.
Mr. Tierney. Let me ask you: A number of campuses now are
giving credit for life experiences, particularly to
nontraditional students who are returning. What are your
opinions on that and is it a good thing or a bad thing? Is it
structured properly? And how do you evaluate the school's
performance in granting that? How do you know when they are
giving it appropriately and when they are not?
Dr. Crow. I would be glad to speak to that. Structured
appropriately--and that is, in fact, the key secret to it--I
think it is an effective way to help, particularly adult
students who are returning to the academy, to be able to show
they have learned. It is not life experience; it is actual
learning to show that they have achieved. And for many people
in the kind of work they have been--and they have been active
learners. It is not a classroom setting, but they have been
active learners.
I think part of the problem with the whole process is when
an institution becomes too anxious to move people through a
portfolio evaluation process or maybe doesn't use testing to
double-check some of their evaluations. And there have been
problems with that when an institution has been too generous in
the award of credit. I think, well done, according to CAEL
guidelines and some of the other agencies that really try to
provide guidance about best practice in this, that it is an
effective way, particularly to help adult learners move back
into the academy.
Dr. Erwin. In some areas, not all areas, we have assessment
instruments in place where we require a level of competency. In
some sense, we don't really care how students reach that level
of competency. It could be through distance education, it could
be through work experience or whatever. We just want to ensure
that they are able to perform at a certain level in certain
areas, not all across the institution, but certain areas.
Mr. Tierney. Let me ask you, in the accrediting process
does it take into account as a positive or a negative a
school's attempts or efforts to expedite matriculation, to get
students through faster than the 4-year process, maybe to
either reach out to high schools and use some of the unused
senior's high school year, time when they are hanging around,
thinking that they have got all their requirements met? Does
that weigh in at all, and how does it weigh in on a school's
accreditation?
Dr. Davis. In the independent sector, we pride ourselves in
getting students through the 4-year program in 4 years or even
faster. And many of our institutions will work with advanced
placement programs from high schools. We will also work where
they can advance their programs by going through the summers.
And all of these--this is an attempt to help that student
minimize the total cost while still assuring they get the
quality education they need to be successful in whatever they
are going to do.
Mr. Tierney. Is the accreditation process interfering with
that?
Dr. Davis. It does require that you document that and does
require that you evaluate and have records to show the basis on
which you are doing that.
Mr. Tierney. Dr. Martin, if I could exercise the license
that we are doing around here.
Chairman McKeon. Mr. Payne got extra time because he said
nice things about me. He almost lost it, though, because he
said different things in the back room.
Mr. Tierney. There is an old saying that everything has
been said, but not everybody said it yet. If we allow States to
accredit, what is to stop them from not looking objectively
enough at their own State institutions?
Dr. Martin. The track record of a State's involvement in
higher education in recent years is that they are looking very
objectively because what they are trying to find objective
measures of performance. In other words, they are interested in
the kinds of questions we have been discussing here: What are
the students actually learning? Can they write when they leave
college? Do they have the quantitative skills they are going to
need, the whole emphasis within the States these days?
The State higher ed commissions and the people involved at
the statewide level in higher education have been involved on
these objective accountability measures. There is talk about
performance funding: Can we shift the funding just from per
student to some kind of performance success and quality
measures? And so that is their passion.
Mr. Tierney. I wonder about that. I see how radically they
are cutting back on their State budgets for the public higher
education institutions, and it borders on criminal. And I
wonder if it is not going to get into a budgetary situation
where they lower the bar just to prove that they weren't wrong
politically when they cut them out of the budget. I see some
heads nodding, and I guess I am not alone.
Dr. Davis. If you check the staffing levels in many States
over the last 10 years because of the budget crunch they have
had, you will find they have reduced their staffs in some cases
by half.
Mr. Tierney. They will only have adjunct professors. They
don't hire full-time professors in too many instances, I think.
Dr. Keiser, did you want to answer?
Dr. Keiser. My experience would be in working with the
State agencies, that that would be a pattern. And again, the
objectivity--I mean, they own the public institutions and they
also would ultimately be a creditor and evaluator of
institutional quality, and I am not sure that is the
appropriate--
Mr. Tierney. It doesn't bother you?
Dr. Martin. One State does this now in a couple of areas
and it wasn't a problem. It was open to all States until 1991.
And some States are really interested in taking this job on
because they are concerned about outcomes and performance.
And you know, Justice Brandeis said that a great thing
about federalism is, you have 50 laboratories in the States. So
I think you would want to try it out. These are speculations.
Mr. Tierney. You would reserve to the Department of
Education the oversight of evaluating?
Dr. Martin. Yes. They have to meet all the same standards
that private accreditors do, and that is how it worked until
1991 when a rule was somewhat arbitrarily imposed saying, let
us let New York keep doing it, but not let anybody else.
I think it is time to allow another option.
Mr. Tierney. Thank you.
Chairman McKeon. Thank you very much. We have a letter from
a colleague not serving on this Committee. He is from your
State.
Mr. Tierney. Is my understanding correct on that, Mr.
Chairman, that you prefer that be entered in another hearing,
but there will be another hearing at which you will let it in?
Chairman McKeon. Yes, before this Congress ends. It regards
a different subject in the broader reauthorization, but a
different subject. We will hold a hearing that will be more in
tune with that. So we will hold that.
Again, I want to thank the witnesses. I think you have done
an outstanding job, and I think the members have asked good
questions and this has been an outstanding hearing.
There no further business. This Committee now stands
adjourned.
[Whereupon, at 12:45 p.m., the Subcommittee was adjourned.]
[Additional material submitted for the record follows:]
Statement of Hon. Jon Porter, a Representative in Congress from the
State of Nevada
Good Morning, Mr. Chairman. Thank you for convening this hearing on
the best course of action that this Congress can take in increasing the
accountability and quality of postsecondary education in this nation. I
welcome our witnesses today and thank them for their willingness to
share their valuable insights into this issue which so critically
impacts the lives of all Americans as they seek the resources for
continued success in our dynamic workforce.
As we increase the accessibility and affordability of higher
education, we must ensure that the quality of that education remains at
the highest levels possible. Only by maintaining the quality of our
postsecondary education can we expect Americans to successfully compete
in our world economy. One particularly important aspect of this quality
control issue is ensuring that we utilize all available resources in
educating our students. Most notably, the advantages of the internet in
disseminating knowledge and education will prove to greatly augment the
levels of education available to those in outlying areas. We must
ensure, however, that those institutions providing online education are
providing just as good, or better levels of education than traditional
brick and mortar establishments.
With its mix of rural, suburban, and urban areas, my Congressional
district, Nevada's Third District, will benefit greatly from expanded
access and continued quality control. Our booming population requires
increased access to higher education to ensure that Nevadans can access
the increasingly skill-based jobs with which they are presented.
Accreditation provides one means of ensuring that all schools that
receive federal funding are meeting acceptable levels of teaching. I
look forward to our continued investigation of the best means of
implementing further accreditation requirements as we seek to improve
the levels of higher education in our country. I wish to thank our
panel of witnesses today and look forward to their testimony and
insights into this most important issue.
______
Letter from Jane V. Wellman, Senior Associate, Institute for Higher
Education Policy, Submitted for the Record
June 30, 2004
The Honorable Howard McKeon
Chairman
Subcommittee on 21st Century Competitiveness
U.S. House of Representatives
Dear Mr. Chairman:
I am pleased to submit comments as requested by your staff on
Section 1025 of H.R. 4283, the proposed legislation to reauthorize the
Higher Education Act. This section directs the Secretary of Education
to provide for a study of the best practices of States in assessing
postsecondary student learning, particularly as such practices relate
to public accountability systems. I base these comments on my
experience in work with several States on public accountability
systems, as a consultant to the Business-Higher Education Forum on
their work on public accountability for student learning, with the
State Higher Education Executive Officers Commission on Accountability,
and on work I have done on these issues with the National Governors
Association Center for Best Practices.
Section 1025 requires the Secretary of Education to select an
organization or association for the study based on: expertise in state
practices, access to state officials, expertise in evaluative and
qualitative policy research for best practice models, the capacity to
convene experts, and the capacity to formulate policy recommendations.
The language requires that the work be done in consultation with an
advisory committee, but permits the contracting organization to draw
its own conclusions potentially independently of the advisory process.
Based on my work in this field, I am confident there are several
organizations that could meet these criteria, and could perform the
study as required. I also believe the topic is an important one that
will benefit from the work described. A good deal of work is being done
on this issue, including the current work of the SHEEO Commission and
the Business Higher Education Forum. But much more remains to be done,
especially at the national level, to bring focus to the topic. And as
it develops, the timing of the reauthorization now means that there
will be an opportunity for the Congressionally mandated study to build
on these other processes now underway.
I'd like to confine my comments on a few elements where the bill
language is potentially ambiguous, and might benefit from some
modification.
1) Selection of advisory committee members. I am not clear whether
the advisory committee members are to be selected by the Secretary, or
by the contracting association. I believe the latter to be preferable,
to remove any ambiguity about authority, and to expedite the work.
2) Section 3 requires the organization to examine ``The
reliability, rigor, and generalizability of available instruments to
assess general education at the undergraduate level.'' This language
seems perfectly clear; however, higher education being what it is, some
clarification of focus might be helpful. The language implies that the
Committee is interested in supplemental assessments beyond those that
are required at the individual course level. Also, the words
``reliability'' and ``generalizability'' suggest that the Committee may
want to confine the review to instruments that have been externally
reviewed for statistical reliability. If these interpretations are
correct, the language might be clarified to remove any potential
ambiguity.
3) The study requires conclusions to be drawn about ``best
practices'' of States in assessing undergraduate postsecondary student
learning as an element of state accountability systems. For good or
ill, a ``practice'' can become a ``best practice'' because it is
pervasive, or readily available, or inexpensive, and not necessarily
because it helps states to improve their state policies. To do this
study well, the association should be able to reach judgments about
best practices in state accountability systems, as well as in the
relation of student learning assessment to state accountability. It
could be the case, for instance, that some states have decided not to
embed direct assessments of student learning into their public
accountability systems, and one would not want to exclude these systems
from a best practice assessment because of this.
4) Paragraph c/4 requires the study to comment on ``roles and
responsibilities for public accountability for student learning.'' The
association should be required to comment in particular on the best
role for federal policy in supporting public accountability for student
learning--understanding that the ``right'' answer to the question
depends on the results of the study and the judgments of the
organization conducting it. There is a good deal that is known about
effective practices for student learning assessment at the individual
course level. There is also a large body of expertise about best
practices for institutional policies on student learning assessments.
The topic becomes much murkier about the purpose of governmental
attention to student learning assessments, in particular the
appropriate role for the federal government. So special attention to
that important and difficult topic may be warranted.
Thank you for the opportunity to comment.
Best wishes,
Jane V. Wellman
Senior Associate
The Institute for Higher Education Policy
______
Statement of the Distance Education and Training Council, Submitted for
the Record
H.R. 4283 would make significant changes to federal student aid
programs affecting millions of students and thousands of institutions.
The Distance Education and Training Council (DETC) feels privileged to
be offered the opportunity to comment briefly on the Bill's
accreditation and accountability sections.
DETC supports H.R. 4283, and commends its sponsors for their
efforts to open up the financial aid system and take the needs and
interests of students to heart.
Transparency
Accreditation actions would become more transparent to the public
under the Bill, and DETC supports transparency when it is uniformly
applied. Although the accreditation transaction historically involved
only the accrediting association and the institution, it also affects
the public in general and students in particular.
DETC has always acknowledged that it plays a quasi-governmental
role, and that by serving as a gatekeeper for federal funding for
students, it has a serious obligation to protect the public interest.
DETC already publishes a great deal of information about its
accrediting decisions and is willing to publish more, such as an annual
list of evaluators who volunteer to serve the accrediting program.
However, we must not forget that ours is a litigious society, and that
accrediting agencies are sometimes sued when they remove accreditation.
Any step toward providing more transparency in the process should be
taken only after assuring all parties that volunteers will not become
vulnerable to legal actions.
Disclosures
We understand H.R. 4283 can address the critical issue of
accountability by requiring that more information be made available to
help students make better-informed decisions. DETC supports the concept
of providing useful information to potential students. As an
association which accredits only distance education institutions which
make significant use of the Internet to market their offerings, DETC is
familiar with the promotional tactics of all online learning
institutions in the country. The current state of marketing practices
suggests that the field is not level when it comes to fair play in
terms of disclosing meaningful information and credit transfer
practices.
DETC strongly endorses making commonly accepted data and
information available in a usable and easily understood form that would
empower students to ``comparison shop'' on their own. We would expect
similar benefits to flow to students if they are well informed when
comparing one college's fixed facility programs with another.
DETC welcomes disclosures when they are uniformly and fairly
applied across the spectrum of higher education institutions.
Access to a Degree
DETC enthusiastically supports the Bill's efforts to make higher
education more accessible to low and middle-income students. DETC
accredits institutions whose students include many individuals unable
to afford the increasingly high costs of attending a traditional
college.
Many thousands of adults in our society face the demands of full-
time employment and/or raising a family. For example, DETC Outstanding
Graduate Sharon Steinbacher was determined to further her education,
but her full-time job and family responsibilities limited her time.
Sharon enrolled in a DETC school and earned her Bachelor of Science in
Information Systems in only sixteen months. She graduated magna cum
laude. Distance learning gives motivated students like Sharon a
wonderful, affordable opportunity to earn a degree and improve their
lives. DETC is a proud advocate of distance learning and what it has
been able to do for these deserving citizens.
Lifting the ban on institutions that teach solely through distance
education via telecommunications is perhaps the single most powerful
feature of H.R. 4283. The Bill's sponsors are to be commended for
taking this much-needed action to reach out to deserving adult
learners.
Fair Credit Transfer Policies
For many years now, DETC institutions have had to intervene on
behalf of their graduates in presenting their cases to collegiate
registrars and faculty at other institutions who observe outdated
credit transfer policies.
DETC strongly supports the Bill's goal of reducing the systemic
bias in higher education on the matter of credit transfer. Admittedly,
there are many sensitive academic considerations involved, and
institutional autonomy is vital, but we have yet to see a convincing
justification for rejecting student requests for transfer credit based
solely on the source of the accreditation yet this happens routinely
today.
DETC welcomes the effort to provide opportunities for learners to
transfer their credits and degrees to other institutions. DETC strongly
believes that academic transcripts should be considered on the merits
of their content and relevance, not simply on the accreditation source.
A Word About DETC
DETC has a unique program to ensure educational quality. By design
and intent, distance education programs are content-rich, and curricula
materials play a major role in determining a program's educational
effectiveness.
DETC evaluates every program offered by an applicant institution,
with an exception made for military institutions that offer hundreds of
programs, such as the Army Institute for Professional Development, the
Air Force Institute for Advanced Distributed Learning and the U.S.
Marine Corps Institute.
The overwhelming majority of students in DETC-accredited
institutions are adult learners who are already employed. They are in a
good position to assess the value of these programs.
DETC's outcomes assessment program tracks and compares program
completion data. The assessment also includes the consideration of the
usual third-party evaluations (e.g., state license examinations). But
many other programs do not have such individual third party tests. It
is important to note that DETC's primary emphasis in outcomes
assessment focuses on whether the student is satisfied with his or her
educational experience. This is the kind of data that we think should
be disclosed: Are the students satisfied? Do they feel they attained
their education goals?
Finally, we believe the public has a legitimate interest in
accreditation. This is why the Chair of our Accrediting Commission has
always been drawn from the public sector, and why, for several decades,
public members constituted a majority of our Commission membership.
These characteristics of DETC probably make it easier for us to
support H.R. 4283's efforts to make higher education accreditation more
transparent, better understood and more accountable to students and
taxpayers.
We believe that H.R. 4283 takes some good steps toward opening up
the process and making the playing field level for all institutions.
______
Letter from Bruce D. Benson, Submitted for the Record
6 July 2004
Mr. John Boehner
Chairman
House Education and the Workforce Committee
2181 Rayburn House Office Building Washington, DC 20515
Dear John:
I am chairman of the board of trustees of Metropolitan State
College and former chairman of the Colorado Commission on Higher
Education. Based on my experience, I would like to endorse Section
495(a)(1)(B) or HR.. 4283, the College Access & Opportunity Act, which
restores the provisions of the Higher Education Act That allows the
states, as well as private accreditors, to certify colleges for
purposes of the federal student loan program.
In Colorado, the public--including parents, employer's students and
taxpayers--is concerned about whether today's students will be
adequately educated to face tomorrow's challenges. As a result, state
leadership--especially the Governor, legislators, and the Colorado
Commission on Higher Education--is looking for ways to raise academic
standards and improve educational results.
In an ideal world, regional accereditors would already be
effectively addressing these issues, but that is not the case.
Accrediting criteria focus on inputs rather than outputs. Accreditors
seem more interested in up holding the status quo than in demanding
real academic improvements.
The original Higher Education Act was wise in allowing states, as
well as private accreditors, to certify colleges. That would prevent
accreditors from being monopolies and would provide healthy competition
that would encourage them to do a better job. The state alternative
would also give colleges like my own, which do care about educational
quality, certification by an agency that shares this concern.
Every state already has procedures for certifying institutions of
higher education that operate within its borders. And state agencies
like the Colorado Commission on Higher Education already collect data
and conduct a variety of quality reviews on schools in their states. I
understand that, thanks to a grandfather clause, New York already
accredits some types of higher education institutions. If New York can
accredit, why not Colorado and other states, if they choose?
In short, allowing states to accredit brings healthy competition
into the world of accreditation, and provides a valuable alternative to
colleges which have a strong desire to improve the quality of education
for their students.
I would like to thank you for your leadership on this issue
Sincerely,
Bruce D. Benson
Denver, Colorado
Letter from the Council of Recognized National Accrediting Agencies,
Submitted for the Record
July 19, 2004
The Honorable John A. Boehner, Chairman
Committee on Education and the Workforce
U.S. House of Representatives
2181 Rayburn House Office Building
Washington, DC 20515
The Honorable Howard ``Buck'' McKeon, Chairman
Subcommittee on 21st Century Competitiveness
2351 Rayburn House Office Building
Washington, DC 20515
Dear Congressmen Boehner and McKeon:
On behalf of the Council of Recognized National Accrediting
Agencies (CRNAA), we would like to express our support for the
provisions of H.R. 4283 that address the role of accreditation. The
CRNAA commends you and the Committee staff for making accountability
and transparency in accreditation a priority during reauthorization of
the Higher Education Act. We would also like to thank Chairman McKeon
for holding the June 22``dhearing on accreditation and for including
Art Keiser as a witness representing the Accrediting Commission of
Career Schools and Colleges of Technology (ACCSCT) and the views of
national accrediting agencies generally.
CRNAA is an alliance of national accrediting agencies. All of these
accrediting agencies are recognized by the Secretary of the U.S.
Department of Education under Section 496 of the Act. Together, the
accrediting agencies participating in the CRNAA accredit approximately
3,100 institutions with four millions students trained and educated
each year.
Accrediting bodies have served for many years in a gatekeeping
capacity, ensuring both quality and integrity in higher education.
CRNAA's members share your interest in increasing both student and
parent awareness of the accreditation process; the important role it
plays; and information to guide their consideration in selecting a
school to attend. CRNAA believes that several of the disclosure
provisions included in section 495 of H.R. 4283 accomplish this goal.
CRNAA also agrees with the legislation's intent to strengthen the
role of accreditation as part of the effort to level the Title IV
playing field for all higher education institutions and their students.
In particular, CRNAA welcomes the bill's provisions on the transfer of
credit. These provisions would prohibit institutions and accrediting
agencies from adopting or applying policies that restrict or deny
students the transfer of their credits solely on the basis of an
institution's accreditation, on the condition that the agency
accrediting the institution is recognized by the Secretary. These
provisions would also require accrediting agencies to include a review
of an institution's policies on transfer of credit.
Increasingly, students decide to continue or expand their education
at multiple institutions, but are often hindered by their inability to
transfer credits. The denial of credit transfers inhibits individual
student initiatives, delays completion, and increases the cost of
postsecondary education by forcing students to pay for comparable
courses more than once. This situation puts an unnecessary financial
strain on both individual students and on our Title IV student aid
system. Unduly restrictive transfer policies burden the already
stretched capacity of the higher education system. CRNAA appreciates
the inclusion of language addressing this problem in both the
institutional disclosure section of the bill, as well as in the
accreditation section. Importantly, the legislation is also careful to
recognize that institutions must maintain their autonomy over making
transfer of credit decisions but based on more relevant criteria, such
as the student's proficiency and equivalency in courses.
CRNAA additionally supports the legislation's intent to rely on
accreditation as a gatekeeper to quality in the area of distance
education. However, CRNAA's members have concerns with the current
legislative language requiring a comparison of distance education to
campus settings as the measure of quality for instruction and support
services in the distance education area. Distance education is
different from education provided in a campus setting and while
accrediting agencies should review all institutions with the same
rigor, it is important that the distinctions in distance education be
recognized by accrediting agencies in their assessment of quality.
CRNAA understands that you have received specific comments on
student achievement, transparency and distance education from some of
its members. We are hopeful that you and the Committee will consider
those comments and that the issues we have raised will be addressed
during the continuing legislative process.
The Commission looks forward to working with you and the staff as
the legislation advances through Congress.
Sincerely,
Roger J. Williams, Executive Director
Accrediting Council for Continuing Education and Training (ACCET)
Carol Moneymaker, Executive Director
Accrediting Bureau of Health Education Schools (ABHES)
Elise Scanlon, Executive Director
Accrediting Commission of Career Schools and Colleges of Technology
(ACCSCT)
Steven Eggland, Executive Director
Accrediting Council for Independent Colleges and Schools (ACICS)
Gary Puckett, Executive Director
Council on Occupational Education (COE)
Michael Lambert, Executive Director
Distance Education and Training Council (DETC)