[Senate Hearing 108-434]
[From the U.S. Government Publishing Office]
S. Hrg. 108-434
HIGHER EDUCATION ACCREDITATION: HOW CAN THE SYSTEM BETTER ENSURE
QUALITY AND ACCOUNTABILITY?
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HEARING
BEFORE THE
COMMITTEE ON HEALTH, EDUCATION,
LABOR, AND PENSIONS
UNITED STATES SENATE
ONE HUNDRED EIGHTH CONGRESS
SECOND SESSION
ON
EXAMINING THE QUALITY AND ACCOUTABILITY OF HIGHER EDUCATION
ACCREDITATION STANDARDS
__________
THURSDAY, FEBRUARY 26, 2004
__________
Printed for the use of the Committee on Health, Education, Labor, and
Pensions
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WASHINGTON : 2003
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COMMITTEE ON HEALTH, EDUCATION, LABOR, AND PENSIONS
JUDD GREGG, New Hampshire, Chairman
BILL FRIST, Tennessee EDWARD M. KENNEDY, Massachusetts
MICHAEL B. ENZI, Wyoming CHRISTOPHER J. DODD, Connecticut
LAMAR ALEXANDER, Tennessee TOM HARKIN, Iowa
CHRISTOPHER S. BOND, Missouri BARBARA A. MIKULSKI, Maryland
MIKE DeWINE, Ohio JAMES M. JEFFORDS (I), Vermont
PAT ROBERTS, Kansas JEFF BINGAMAN, New Mexico
JEFF SESSIONS, Alabama PATTY MURRAY, Washington
JOHN ENSIGN, Nevada JACK REED, Rhode Island
LINDSEY O. GRAHAM, South Carolina JOHN EDWARDS, North Carolina
JOHN W. WARNER, Virginia HILLARY RODHAM CLINTON, New York
Sharon R. Soderstrom, Staff Director
J. Michael Myers, Minority Staff Director and Chief Counsel
(ii)
C O N T E N T S
__________
STATEMENTS
THURSDAY, FEBRUARY 26, 2003
Page
Gregg, Hon. Judd, a U.S. Senator from the State of New Hampshire. 1
Sessions, Hon. Jeff, a U.S. Senator from the State of Alabama.... 2
Crow, Steven D., Executive Director, The Higher Education
Learning Commission, North Central Association of Colleges and
Schools........................................................ 6
Wallin, Jeffrey D., President, American Academy For Liberal
Education...................................................... 8
Martin, Jerry L., President, American Council of Trustees and
Alumni......................................................... 9
Potts, Robert L., President, University of North Alabama......... 11
Alexander, Hon. Lamar, a U.S. Senator from the State of Tennessee 15
Clinton, Hon. Hillary, a U.S. Senator from the State of New York. 21
ADDITIONAL MATERIAL
Statements, articles, publications, letters, etc.:
Steven D. Crow............................................... 31
Jeffrey D. Wallin............................................ 33
Jerry L. Martin.............................................. 36
Robert L. Potts.............................................. 40
Judith Eaton, M.D............................................ 42
(iii)
HIGHER EDUCATION ACCREDITATION: HOW CAN THE SYSTEM BETTER ENSURE
QUALITY AND ACCOUNTABILITY?
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THURSDAY, FEBRUARY 26, 2004
U.S. Senate,
Committee on Health, Education, Labor, and Pensions,
Washington, DC.
The committee met, pursuant to notice, at 1:57 p.m., in
room SD-430, Dirksen Senate Office Building, Senator Gregg,
chairman of the committee, presiding.
Present: Senators Gregg, Alexander, Sessions, and Clinton.
Opening Statement of Senator Gregg
The Chairman. There may be other members joining us, but
with the vote situation, I think it is important to get rolling
since we have witnesses here and I am here. That is good enough
for me. [Laughter.]
Next to access and affordability, there is perhaps no
greater issue in this reauthorization of the Higher Education
Act than accountability. The Federal Government makes over $70
billion available each year in the form of grants, student
loans, and work study to help American students pay for college
education, so it is only fair that the institutions be held
accountable for producing quality education outcomes with this
investment.
To ensure accountability, the Higher Education Act requires
that institutions wishing to participate in the Title IV
student financial aid programs be authorized to operate in
their State to meet certain Federal eligibility rules, and
maintain their accreditation with an agency recognized by the
Secretary of Education as a reliable authority concerning
educational quality.
This hearing will assess the role that accreditation plays
in the accountability process. There are several issues
involving accreditation, in my opinion. Primarily, I think we
want to make sure that the accreditation process remains a
process committed to excellence, and does not become overly and
excessively involved in asserting a political agenda or an
educational agenda which is not directed at the substance of
creating a well-balanced educational curriculum. We are also
concerned about issues like grade inflation, intellectual
diversity, and the ability of the accrediting agencies to do
their job in an honest and impartial way.
This hearing is going to address these issues. We have
several excellent witnesses joining us today who have spent a
lot of time on this issue. Let me begin by introducing all four
witnesses and then we will go to testimony.
Our first witness will be Dr. Steven Crow, the Executive
Director of the Higher Learning Commission of the North Central
Association of Colleges and Schools. Dr. Crow has been with the
Commission since 1982 and has been instrumental in making
regional institutional accreditation responsive to e-learning,
U.S. education delivered internationally, and new collaborative
arrangements created in several States. He is also Co-Chairman
of the Council of Regional Accrediting Commissions.
Along with Dr. Crow, we have Dr. Jeffrey Wallin, President
of the American Academy for Liberal Education. Under Dr.
Wallin's leadership, AALE has become a leader in liberal arts
accreditation. It has also been a strong proponent of a core
curriculum and the assessment of student learning. Dr. Wallin
is also a Winston Churchill scholar.
I also welcome Dr. Jerry Martin, Chairman of the American
Council of Trustees and Alumni, a nonprofit organization
dedicated to academic freedom and excellence in higher
education. From 1988 to 1995, Dr. Martin held senior positions
at the National Endowment for the Humanities and served as
acting Chairman in 1993. Prior to joining NEH, Dr. Martin was
the Chairman of the Philosophy Department at the University of
Colorado in Boulder.
We are also joined by Dr. Potts, who I believe is going to
be introduced by----
Senator Sessions. I would be honored.
The Chairman. --Senator Sessions. [Laughter.]
Opening Statement of Senator Sessions
Senator Sessions. Dr. Potts, it is great to have you with
us. Dr. Potts is President of the University of North Alabama
in Florence, and for 6 years prior to his appointment as
President, he served as general counsel for the University of
Alabama system. He served for 6 years on the U.S. Secretary of
Education's National Advisory Committee for Institutional
Quality and Integrity. He is a member of the commission on
Colleges for the Southern Association of Colleges and Schools
and is a frequent accreditation site visitor for both SACS and
the American Bar Association's Section on Legal Education and
Admissions to the Bar.
President Potts is a great leader in education in Alabama.
I have had the pleasure to visit his university and stay at his
guest house. They are doing a terrific job in Northwest
Alabama, and throughout the region and have had some really
terrific graduates of that university.
Thank you for that privilege, Mr. Chairman.
The Chairman. Thank you, Senator Sessions. It is always an
honor to have a member of your constituency with us.
Before we begin I have statements from Senators Gregg,
Enzi, and Kennedy.
The prepared statements of Senators Gregg, Enzi, and
Kennedy follow:]
Prepared Statement of Senator Gregg
Next to access and affordability, there is perhaps no
greater issue in this reauthorization of the Higher Education
Act than accountability.
The Federal Government makes over $70 billion available
each year in the form of grants, student loans and work-study
to help America's students pay for a college education.
Therefore, it is only reasonable that institutions be held
accountable for producing quality educational outcomes with
this investment. To ensure accountability, the Higher Education
Act requires that institutions wishing to participate in the
Title IV student financial assistance programs: are authorized
to operate in their State; meet certain Federal eligibility
rules; and are accredited by an agency that has been recognized
by the Secretary of Education as a reliable authority
concerning educational quality. This hearing will assess the
role that accreditation plays in this accountability process.
Historically, American higher education has been the envy
of the world. Yet today, there are some serious quality issues
that we must address if our nation's leadership in this area is
to continue. Most importantly, we need to make sure that our
institutions of higher education are adequately preparing
students for the workforce. There is reason to be concerned
about this issue. For example, numerous reports have documented
the poor writing skills of recent college graduates and the
problems this has created for employers.
I am also concerned about the watered-down curricula that
we see in much of higher education today. Many college students
lack a solid background in such core subjects as English,
History, Western Civilization and foreign languages because
unfortunately, good core curriculum programs are all too rare.
It concerns me that on many college campuses, core classes are
being squeezed out in favor of a balkanized curriculum that
does not provide this kind of basic, well-rounded education.
While I do not want to see the Federal Government dictate
college curricula, I do think it is important to shine a light
on this issue.
In addition to the fact that the curriculum is no longer as
robust as it once was, grade inflation has become rampant as
well at 4-year institutions. As larger and larger numbers of
students achieve A's and B's, the ability of employers to make
distinctions between students diminishes.
Addressing these and other quality issues involves more
than just accreditation. However, accreditation is part of the
picture. Through this hearing, I hope we can explore the extent
to which accreditation adds value to the accountability system,
and whether accreditation standards really focus on academic
quality as opposed to focusing on other agendas that have
little to do with quality. If students are graduating from
accredited institutions without core knowledge or the kind of
training they need to succeed in the workforce, then one has to
wonder whether accrediting agencies are as focused on student
achievement and student outcomes as they need to be.
We also need to make sure that accreditation is transparent
to the public, so that students and parents can better
understand not only the process of accreditation, but what that
process reveals about the quality of institutions.
I look forward to hearing from our panel concerning these
issues.
Prepared Statement of Senator Enzi
Mr. Chairman, thank you for holding this important hearing
on the issue of accreditation and its role in facilitating
higher education in this country. I am grateful to the
witnesses for appearing today and I am particularly pleased
that we have with us a representative of the North Central
Association of Colleges and Schools, which accredits most of
the institutions of higher education in Wyoming.
Many people don't know how important the role of
accreditors is in the higher education system. While their role
is largely not well understood, they are critical to
maintaining America's competitive edge by promoting high
quality higher education. Students will also understand the
importance of these institutions because accreditation is a
requirement of any institution that wishes to participate in
Title IV programs, which are better known as the Federal
commitment to student financial aid.
I believe there are several questions before this committee
as we begin our work on the reauthorization of the Higher
Education Act that will be answered through this hearing and
the testimony of these witnesses. Among those that I feel are
important for this committee to discuss are the role of
accreditation for online and distance learning educators,
quality assurance, and accountability. An issue that is
important to me as well is the affordability of college, how
affordability affects access, and what role accreditors might
play in helping to address the rising cost of attending
college.
Speaking specifically to the point of distance learning, I
introduced legislation last year that would permit online
education institutions and their students to participate in
Title IV aid programs. A key aspect of that legislation was
building on the role of accreditors to ensure the integrity of
these programs by creating specific criteria for these
providers. I believe, as do many of my colleagues, that
distance learning providers cannot simply be plugged into the
same process as their traditional brick and mortar counterparts
without some changes to the accreditation process. I am
grateful that Director Crow addresses that in some detail in
his testimony.
I am also concerned that the accreditation process, while
necessary for participation in Title IV programs, creates
somewhat of a financial burden for institutions. While there
are clear financial incentives for any institution to
participate in Title IV programs, accreditors are the sole
gatekeepers for institutional entry into these programs. In an
effort to meet the requirements of accreditors, institutions of
higher education must devote hundreds of hours of staff time to
providing the requisite information. Often, institutions must
also improve physical facilities or make other accommodations
in order to become accredited. As is the case with any other
business, these costs are passed along to the consumer, in this
case, students. In turn, these students will borrow funds from
the Federal Government to finance their own education and will
pay most of the cost of the institution's effort to become
accredited.
This situation reveals a relatively circular cycle of costs
that the Federal Government and students are paying. The
Federal requirement that institutions become accredited before
they are eligible to participate in Title IV programs has clear
institutional costs associated with it, which are ultimately
paid by the Federal Government through its subsidization of
student loans and grant funding to the lowest income students.
As the cost of attending college is becoming an issue of
increasing importance in the minds of my constituents, I am
hopeful that we will be able to determine how this committee,
and the Senate generally, can address some of the cost issues
associated with the accreditation process. I believe the
accreditation process effectively limits Federal participation
in an area where it is poorly equipped to fill the role of
accreditor, in addition to providing an appropriate independent
validation of institutional quality.
I look forward to the issues we will discuss in this
committee and later as we continue our work to reauthorize the
Higher Education Act. Thank you Mr. Chairman.
Prepared Statement of Senator Kennedy
I commend Chairman Gregg for convening this hearing as we
prepare to act on the many important issues we face in
reauthorizing the Higher Education Act.
I also thank each of the witnesses for being here to
discuss today's topic--the college accreditation process. It
has always been a priority for our committee to see that all
students have the opportunity for high quality post-secondary
education and are an essential part of reaching that goal.
Since 1952, when the Federal Government began to rely on
accreditation for higher education we have used these periodic
reauthorizations to improve the accrediting process and use it
to solve problems. In 1992, we asked accrediting agencies to
add numerous compliance questions to address fraud and abuse in
student aid programs. In 1998, we turned to the accreditors to
help us respond to the new and growing field of distance
education.
Now we look to the accreditors again for better ways to
reflect the many aspects of higher education. Students of all
ages rely on post-secondary education to improve their lives
through learning and to gain the skills that will give them
opportunities throughout their lives and make them better
citizens, parents and workers.
Higher education is a significant and continuing Federal
investment--$69 billion in student grants and loans in 2002. It
is also a significant and continuing investment by millions of
students and their families, who struggle to make college a
reality for themselves and their children, and then sacrifice
for years to pay back their loans. We need to do all we can to
see that our investment and their investment is reaping the
best return possible.
All of us on the committee look forward to your views on
the current accrediting process and the specific improvements
needed to give students and parents the best available
information to make informed decisions in spending their higher
education dollars. Thank you for your testimony on this major
aspect of current education policy.
The Chairman. Dr. Crow?
STATEMENT OF STEVEN D. CROW, EXECUTIVE DIRECTOR, THE HIGHER
LEARNING COMMISSION, NORTH CENTRAL ASSOCIATION OF COLLEGES AND
SCHOOLS
Mr. Crow. Mr. Chairman, my name is Steven Crow. I am the
Executive Director of the Higher Learning Commission of the
North Central Association of Colleges and Schools. My
membership consists of 895 colleges and it also includes almost
two dozen tribal colleges that are located in the sovereign
nations that are within our 19-State region.
I also serve, as you mentioned, as the Co-Chair of the
Council of Regional Accrediting Commissions, or C-RAC. Those
seven regional accrediting associations accredit over 3,000
institutions enrolling approximately 16,620,000 students. All
of our commissions are recognized by the Department of
Education and by CHEA, the Council on Higher Education
Accreditation.
Most of my comments today are shaped by the legislative
recommendations created by a majority of the agencies in C-RAC
and distributed in recent weeks to education staff on the Hill.
For the past 50 years, our commissions have served a unique
quasi-public role. Their accreditation decisions on
institutions have been accepted by the Federal Government as
sufficient evidence of educational quality to fulfill part of
the DOE's institutional eligibility requirements for Title IV.
For the past 15 years in particular, we 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.
I have submitted a longer statement for the record. For the
sake of brevity, I will now address briefly the primary issues
that my regional colleagues and I understand to figure
prominently in this reauthorization.
First, institutional accountability for student learning.
The Federal call for increased accountability for educational
performance has been heard. The fact is, thanks to our
integration over the past 15 years of student learning into our
accrediting standards and processes, a surprisingly large
number of our colleges and universities have lots of outcome
data.
While concerned about a law that would require a summary of
educational performance in a few required standardized measures
applied to all types of colleges and universities, we would
support legislation that continues the expectations that
accreditation weighs student learning and that institutions
receiving Title IV provide public information about the
educational performance of their students. We would council
that an institution should be allowed to provide performance
information fitted to its own educational objectives and using
the variety of data it gathers to evaluate its own
effectiveness. As recognized accrediting agencies, we are ready
to accept within our federally defined responsibilities review
of the data itself as well as of the effectiveness of the
institutions' distribution of it.
Transparency of accreditation. While anxious to protect the
zone of privacy important to our efforts to stimulate and
support educational institutional improvement through
accreditation, we are ready to create for the public stronger
programs of disclosure about accreditation processes,
accreditation actions, and the findings related to those
actions. We strongly urge that the template for public
disclosure, however, not be defined in law, allowing important
conversations within the accrediting community to create
effective and appropriate models for that disclosure.
Student mobility and transfer of credit. We know that
transfer of credit is a matter of public concern. In recent
years, we have all endorsed the CHEA principles on transfer
adopted in November 2000. They mark a new consensus on good
practice in transfer, including an expectation that transfer
decisions not be based solely on the source of accreditation.
While my colleagues and I caution against any wording in
this reauthorization that could be used to allow the Department
to regulate this key component of institutional academic
integrity, we would support legislation that captures the
spirit of the CHEA principles and we are ready to include in
our review processes greater attention to our institutions'
transfer policies and practices than we have in the past.
I would be remiss if I did not caution against adding
significant new institutional recordkeeping and reporting
requirements on all of this.
And last, distance education and e-learning. Each regional
commission believes that it has been doing an effective job of
evaluating distance education generally and e-learning
specifically. Legislation that classifies all e-learning as
distance education and then calls for different regulation of
it will inadvertently require special evaluation of what many
institutions and their campus-based students now view to be
little more than a scheduling option.
While we take no stand on the 50-50 rule, we do not believe
that the price for its abolition should be the enhanced
scrutiny of all distance education, no matter the institutional
context.
We have been reviewed by the Department to approve e-
learning over the past 5 years and all of us have actually been
reviewing it and including it in our accreditation for many
years before that. We do stand ready to demonstrate anew how
our existing standards apply to e-learning, we stand ready to
document the training we provide to assure that our reviews of
e-learning are sound, and we stand ready to review periodically
the management capacity of institutions with rapidly expanding
online offerings and/or with rapidly growing numbers of
students served by them.
Mr. Chairman, thank you very much for the opportunity to
testify. I look forward to hearing from my fellow panelists and
then responding to whatever questions you may have.
The Chairman. Thank you, Dr. Crow, especially for those
specific thoughts.
[The prepared statement of Mr. Crow may be found in
additional material.]
The Chairman. Dr. Wallin?
STATEMENT OF JEFFREY D. WALLIN, PRESIDENT, AMERICAN ACADEMY FOR
LIBERAL EDUCATION
Mr. Wallin. Thank you very much, Senator, for having me
here today to share my thoughts on how accreditation can better
ensure quality and accountability, and for accountability and
quality I am going to speak of learning outcomes, since that
seems to be the method by which we seek to improve over the
resource discussions when it comes to accreditation.
It seems to me that we should begin with a very simple
question. Do we have a problem? And I would say, yes, we do.
Higher education in this country is on the road to becoming
ubiquitous, while not, I hope, uniform, and therein lies the
danger.
This is in large part due to the admirable efforts of many
at the State and national levels to increase access to
nontraditional student populations. However, in the last couple
of decades, serious questions have been raised about whether
the quality of higher education has kept pace with its growth
in size and expense. Report after report confirms that higher
education, even a degree in it, is no longer a guarantee of the
skills and general knowledge that Americans have come to expect
from higher education.
We seem to be reaching a point that Winston Churchill
thought had arrived a full generation ago, namely that
education is at once universal and superficial. It is our duty
and our responsibility to do what we can to preserve this
newly-won access while resisting superficiality and a reduction
in quality.
The American Academy for Liberal Education was established,
in part, to strengthen general and liberal learning by
establishing substantive academic accreditation standards, such
as foreign languages, mathematics, history, philosophy, and
science and so on. We believe in this system, but it is a
system of inputs, and, of course, at some point you have to
come to a system of judging whether it is working.
Learning assessment has grown very rapidly over the last
few years. In my opinion, it has done quite a bit of good. From
the standpoint of AALE, for example, we see that many faculties
are being forced to reconsider the issue of a core curriculum
and what has been lost by abandoning them over the last 30 or
40 years. Once you have to ask the question of what is it that
you expect out of education, quite often what you are led back
to is the proper means for supplying it, and that is all to the
good.
However, we believe that there is a significant danger in
pushing this too far, or rather, I should say more explicitly,
pushing it too far with the wrong means. We do not want
assessment to replace education. There is an old Midwestern
saying, you don't fatten the hog by weighing it.
Now, it seems to me that the problem is that regional
accreditation is doing about as much as can be done along these
lines without forcing a kind of uniformity among colleges and
universities throughout this country that none of us want. Is
that to say that it can't be done? No, not at all. We have
models of assessment of the sort I think people are interested
in.
Take a look at the specialized accreditors. I haven't heard
anybody complaining that a student with a biology degree
doesn't know any biology, or that the engineers can't build
bridges. The specialized accreditors realize what it is they
want to produce and the experts in their field are the ones who
assess the learning in it and it works pretty well. It is hard
to do, though, when you have a general education curriculum,
especially when it is no longer a specific core but it can be a
smorgasbord of courses.
I have attached a paper to my remarks from Milton
Greenberg, who argued that maybe what we need to do is one of
two things. Either hold the specialists accountable for the
fact that they require that their students take general
education but they rely upon the quality of that education to
be taken care of by the regionals and they are not set up to do
that, not with, what, just 800 institutions or so. They don't
want to impose that kind of uniformity, nor should they.
Another possibility would be to have sector-specific
accreditation. That is to say, you might have an accreditor for
regional universities, research universities, liberal arts, and
so on. Of course, that is one thing we do is the liberal arts.
But what you would do is take assessment and put it somewhere
where it has a long tradition of being successful, as it is,
say, in the arts and in music. That might be a possibility, but
it would require quite a change.
In any event, though, one might think at some point, if the
system is not built to do this, maybe we had better at least
think about building a system that is designed to do it, for
that is the only way I think we are going to get the kind of
assessment that the American public wants, one that deals with
qualitative, substantive differences between colleges and
universities.
Thank you very much.
The Chairman. Thank you.
[The prepared statement of Mr. Wallin may be found in
additional material.]
The Chairman. Dr. Martin?
STATEMENT OF JERRY L. MARTIN, PRESIDENT, AMERICAN COUNCIL OF
TRUSTEES AND ALUMNI
Mr. Martin. I think we have to begin by recognizing the
extraordinary power accreditors have. They are private
organizations, but Congress has made them the gatekeepers of
billions of dollars of Federal funds, including student loan
funds without which colleges cannot survive. The rationale, of
course, is that they are there to ensure quality. The question
is, have they been successful in that?
Unfortunately, our study shows that the answer is no. There
is considerable evidence of serious decay in quality at many
institutions despite the fact that almost every college and
university is accredited. Colleges and universities that were
allowing academic standards to slide nevertheless sailed
through their reaccreditation visits. How is that possible?
Well, the surprising fact is that the standards for
accreditation have little to do with teaching and learning. As
every expert who has looked at this notes, accrediting
standards emphasize inputs and procedures, not educational
quality and student learning. As a result, the accreditor's
guarantee is no guarantee at all.
Take grade inflation, for example. Studies show that under
the accreditors' watch, grade inflation has gotten worse, not
better. The Duke University researcher who monitors this issue
says the rise has continued unabated at virtually every school
for which data are available. And yet not a single case has
been reported of a school being sanctioned by accreditors for
runaway grade inflation.
Another of the most important quality indicators for a
college is its general education requirements. What are the
courses required for all students to graduate? One study found
that in the last 50 years, there has been a decline in general
education requirements in every subject--English, history,
math, science, foreign languages, philosophy, the arts, even
PE.
If we judge accreditors on their performance, it is a
record of persistent failure. If meat inspections were as loose
as college accreditation, we would all have ``mad cow''
disease.
So what is the solution? Well, since accreditors are not
successful in ensuring quality, their power over Federal funds
is not justified. A simpler, less costly procedure could be set
up within the U.S. Department of Education to certify quality
institutions--qualified institutions, and that should be
sufficient to weed out institutions that are colleges in name
only.
For raising educational quality, two more effective sources
of accountability are available. First, college and university
trustees are appointed to represent the public interest. They
are becoming increasingly active and expert in overseeing
quality, and if we have time in the discussion I could give you
some dramatic examples where college trustees have strengthened
core curricula and raised academic standards, none of those
changes having resulted from accreditors' recommendations.
Second, State higher education agencies are embarked on
what has been called an accountability revolution. They are
framing performance measures that look at educational results,
not just inputs. Again, I could give you some dramatic concrete
examples from States around the country.
The problem is that the accreditors function as de facto
cartels. Monopolies are not good at self-correction.
Competition is the best medicine.
Two promising alternatives can provide much-needed
competition. First, though, why not encourage more accreditors?
The American Academy for Liberal Education is a perfect example
of an accreditor dedicated to setting very high standards in
the liberal arts.
Second, Congress should consider Senator Hank Brown's
suggestion. Senator Brown became a college president after
leaving the Senate and reported that although the accreditors
did not ask what students were learning, he said one agency
did, namely the State Commission on Higher Education. Well,
Congress should consider his suggestion, which is that the
States might be allowed to accredit colleges and universities
on a purely voluntary basis if they so choose. Originally, the
Higher Education Act did allow States that option and one State
has done so in a couple of areas. But since 1991, this
opportunity has been denied to other States. We believe this is
an option worth exploring.
Thank you, Mr. Chairman.
The Chairman. Thank you, Dr. Martin.
[The prepared statement of Mr. Martin may be found in
additional material.]
The Chairman. Dr. Potts?
STATEMENT OF ROBERT L. POTTS, PRESIDENT, UNIVERSITY OF NORTH
ALABAMA
Mr. Potts. Mr. Chairman, members of the committee, ladies
and gentlemen, I want to thank you for the invitation to be
here today. I am here representing the American Association of
State Colleges and Universities, on whose board I serve. We
represent 425 public colleges and universities and university
systems around the country, about 3.5 million students, and
more than half of the students in the four-year institutions in
the country.
I personally have been on the ground with accreditation and
also spent 6 years on the committee that is set up to oversee
the accrediting agencies, and during that period of time got to
see most of the 100 or so accrediting agencies that are
certified on the Secretary's approved list, and we had hearings
twice a year, 3 days at a time, where people could come in and
make complaints, make comments as these agencies would come up.
What I just heard described does not accord with what I saw
during my service on that committee, nor what I see on the
ground as I lead accrediting teams for a couple of different
organizations. I am taking a team, for example, to Murray State
University week after next to do this. What I see is that the
present system is working quite well. The 52-year-old
partnership between the voluntary accrediting associations, be
they the regional associations, the national associations like
Dr. Wallin's association, or the specialized associations that
accredit just in a specific field. They are doing a pretty good
job under the current system.
I do not think that wholesale changes and particularly
delinking student financial aid and the accrediting system
would be a good thing. You have hundreds and thousands of
volunteers like myself out in the field every year paying
attention to issues of quality at institutions. We frequently
serve as unpaid consultants to suggest best practices. You
better believe that we will blow the whistle if we see
something that we think is not academically sound in these
institutions.
You think of the institutions, for example, in your home
State and you ask yourself--I know Senator Alexander was the
President of the University of Tennessee--if these descriptions
of the lack of quality are there. I don't think that is true,
and I think the accrediting agencies have been doing a fine
job.
Now, can a complex system like this be improved? Of course
it can. We at AASCU have a few suggestions. We basically
subscribe to the suggestions that Dr. Crow and the regional
accreditors have made with some minor changes in the Act.
But I ask you, in considering these changes, not to upset
the delicate balance that has existed for 52 years with some
slight changes between the private accrediting agencies and the
Federal Government with the States and the institutions playing
vital roles in it because it has worked well.
Our system of higher education here in this country is the
envy of the world. Our institution recently established a
relationship with a company in Japan and we are getting large
numbers of Japanese students that come and enroll in our
institution. I can tell you that all over the world, people
admire this system, and one of the great aspects of it has been
private accreditation that first began in New England in 1895
and then became a part, or partnership with the Federal
Government in 1952.
So we want to just say in summary, and I would like to
submit, of course, my written testimony, I can give you example
after example where I have been out on the campuses and
improvements have been made. I cite one example of where one
institution got 100 recommendations on a visit from a regional
accreditor because of some program problems they had. The next
time they came, they got less than ten and it was uniform
improvement because of this process.
There is more focus now on student learning and
development. The Southern Association, on whose commission I
sit, for example, has just adopted a new set of democratically
developed criteria called the principles, and one of the things
in that is we require as a part of the accreditation process a
quality enhancement plan for student learning that the
institutions submit. So you are seeing more and more outcome
assessments through institutional effectiveness and other
things that we have hard criticism such as has been made before
and we certainly strive to increase that.
But let me say last, in conclusion, that AASCU's position
on this is that there should be some targeted improvements
during reauthorization, but a wholesale change in the system
would be very detrimental and there would be nothing short of
extreme expense and some sort of ministry of education that you
could have to supplement what is being done by volunteers
today. Thank you very much.
The Chairman. Thank you.
[The prepared statement of Mr. Potts may be found in
additional material.]
The Chairman. I thank the panel for the excellent
presentation. I sense that there is a slight difference of
opinion--[Laughter.]--so I thought maybe I would let--Dr.
Potts, I thought you made an excellent presentation of why we
shouldn't fundamentally change the system, and Dr. Martin made
a suggestion that we should change it more fundamentally, Dr.
Wallin a little in between, and then Dr. Crow, yours was more
of an objective overview.
Could you respond, Dr. Martin, to Dr. Potts' thoughts, and
then we will give everybody a chance to respond back and forth,
because I think you got to the essence of the issue, which is
how much change is necessary in order to get better
accountability and make sure that kids are getting what they
paid for, which is an education.
Mr. Martin. Well, we seem to disagree on what should be
done, but I did not hear any counter evidence. I did not hear
the argument made that there is no problem with grade inflation
or that curricular requirements have strengthened rather than
weakened. At one point, the Association of American Colleges
did a report that summed up the situation on the college
curriculum today by citing the lyrics of Cole Porter, in which
the only thing adequate is a summary. ``Anything goes.'' I
don't hear any rebuttal.
Employers regularly report these days--you can quote one
CEO after another that even the college graduates can't write.
As one reported they can do the technicals, but they can't
write the report. These are just--you know, we talked about a
diversity of institutions, but I don't know any field or type
of institution in which a student's ability to write an English
sentence and express himself or herself is not important.
So I don't hear any challenge to the basic facts of
deterioration. The burden of proof is on the accreditors. Well,
where they are not doing the job, I think we need to find a way
to fix the system so that the job gets done.
The Chairman. Dr. Crow, Dr. Wallin, and then we will get
Dr. Potts to come back for rebuttal.
Mr. Crow. I would basically argue that I don't find
convincing what has been put forward as the evidence for
decline in quality. There is a lot of anecdotal talk. There is
also much anecdotal talk about how good the graduates are and
how well prepared they are. So I think the idea that somewhere
there is a uniform, agreed upon understanding that American
higher education has experienced a State of decline overseen by
its friendly accrediting agencies is essentially bogus. I don't
see evidence to support it. I see evidence of various reports
that are put together to do this, to try to justify this claim.
I think it is fair that there is a big discussion going on
between the Academy and the public at large about the fit
between higher education and the needs of society, and I think
that we are going to see increasingly over the next five to 10
years much more dialogue between the higher education community
and the people who use the graduates of that higher education
about what needs to be done to make sure that higher education
is relevant and is useful.
And I will say in our latest review of our own accrediting
standards, and we just adopted a new set, we, in fact, embed
that kind of dialogue and discussion within our accrediting
standards.
The Chairman. Dr. Wallin?
Mr. Wallin. Yes. Well, I think that Dr. Crow put his finger
on a fundamental difference, and that is whether--not only
whether the system of accreditation is working, but whether,
overall, the system of higher education is working. It seems to
me that when you hear a statement that broad one way or the
other, one should always ask, in what respect, and the same
should be asked of the sentiment that United States education
is the envy of the world, because it is. There is no place that
offers better education, certainly in graduate school, and very
few places that can match us when it comes to our professions
and specialized training. That is true.
The question we have been raising today, though, is what
about the fact that--and it is not just anecdotal, there are
studies showing this--that it seems to be the case that lawyers
and doctors and others keep telling us that they don't
understand why they are getting candidates for positions out of
the top schools and they can't write a paragraph well. I mean,
it is a failing. I can't see how you can get around it, and I
know that I hire plenty of young students from top-notch
liberal arts colleges and I make them take a test, not an exam,
but just make them write an article or something and it is
pretty bad. Things have gotten to the point where a high school
degree doesn't mean a great deal anymore.
Now, by the way, I am leaving aside the most elite
colleges, which you usually have to go to a private school to
get into anyway, and that is not where the problem is. The
problem is that we now have something like seven or so out of
every ten high school students going to college. If they are
going to go to college, they need to learn because they may get
their first job by having that degree, but they won't keep it
if they don't have the necessary skills. It seems to me that it
is unanswerable, the charge that not enough of them have those
skills.
Now, as to how to fix it, I am differing with Dr. Martin a
bit on this because, first of all, I think regional
accreditation does a good job of what it is intended to do. It
is essentially resource oriented. It assures the reliability of
processes, resources of educational institutions, and weeds out
diploma mills, and I have seen several instances where it does
some good in strengthening the institution.
It is just that what has happened in the last, I don't
know, ten, 20 years, is the focus has turned on learning
outcomes and that is not where the strength of these
institutions is, I mean the accrediting institutions. So I
would again suggest that we need to find a way, if you want to
have this kind of information, real, solid information, none of
which, by the way, comes out of the current assessment
approach, even though I would argue it is a good thing, nowhere
that I am aware of in any of the regions will you come out with
a specific answer to the question of whether students who are
walking out with a four-year degree actually know anything
about mathematics or history or literature or anything else.
Now, our standards are explicit about it, but other than
that, learning assessment is starting to turn into a process
whereby you have thick portfolios and all manner of other
things but you never get anything that would threaten any
faculty member or any school by saying, ``I am sorry, you are
not performing.'' That, we don't have, and we can either say we
don't need it, it is a free country, there are lots of
institutions, let them compete, or if we are going to say, let
us do something about it, I think you are going to have to
change the system.
The Chairman. Dr. Potts, we are going to have a vote here
in a minute, but if you have a couple of points.
Mr. Potts. A couple of points. These broad-based statements
about what higher education is, and I can give you specific
examples, and I don't have time here in the hearing, there is
tremendous competition among institutions of higher education.
The American system has such a great diversity of institutions,
from the two-year college to the elite Harvard Universities and
Yales and whatever, and the students----
The Chairman. But in this committee, we talk about
Dartmouth. [Laughter.]
Mr. Potts. The students vote with their feet. I think you
will find many institutions have strong programs that train and
equip students to compete in this society that we have and this
is not the place to try to fix the ills of society with this
type of reauthorization. What we have with the current higher
education law and in this area of accreditation is working
quite well.
The Chairman. Senator Alexander?
Opening Statement of Senator Alexander
Senator Alexander. I just have great sympathy for
presidents of universities, having been one. But let me thank
the chairman for having this hearing and thank each of you for
coming. This is a very useful discussion and the differences of
opinion are important to me. I am going to ask a question in a
minute about what would be the most appropriate way to
encourage more accreditors, basically take the system we have
now but have less of a monopoly. This is the decision I came to
in 1992 when I went through some things with accreditation. So
that will be my question in a minute, but first, let me make a
couple of comments, if I may.
I arrived at the United States Department of Education in
1991 as Secretary with a chip on my shoulder about accrediting
agencies and it really hasn't gone away. One, I had been a
university president and I got tired of people coming in and
telling me I had to spend $40 million on a law school when I
thought I was president of the university and I would rather
spend it on this or that or this core curriculum or that
teacher.
Second, when I got to the Department, I was really offended
by the Middle States Accrediting Agency, which had just adopted
in its bylaws, and gave itself the authority to tell trustees
and presidents what their diversity standards ought to be on
each campus. I thought it was absolutely none of their business
and told them so. And in effect, during a hearing, I tried to
see if I as the Secretary could disaccredit the accreditors for
going far beyond where I thought they ought to be. It was a
learning process for me, and maybe for them because they
dropped that a year later.
So I arrived with that sort of bias I would like to see if
there are ways that we can encourage accrediting agencies
affiliated with the Department of Education scholarships to
stick to academics and don't impose their political judgments
or politically correct judgments on different colleges. For
example, Middle States wanted to tell Westminster, which is a
Calvinist college which didn't ordain women, that they had to
have a woman on their board. Well, that is not diversity.
Diversity would be allowing Westminster to come to its own
conclusions about its religious beliefs.
And it told Baruch College that 18 percent minority faculty
wasn't enough. The United States Constitution and numerous
Federal laws establish criteria for that and the president and
the board members of Baruch College have responsibility for
that. So I start out that way, but let me go the other
direction now.
I am very wary of any proposal from the Federal Government
that restricts the autonomy of American colleges and
universities. I asked David Gardner one time, the President of
the University of California, why they were good, and he said
three things. One, autonomy. When they created the University
of California, it was a fourth branch of government. They
basically gave us the money without many restrictions. Second,
excellence. We were lucky enough when we started to have a
dedicated core of excellent faculty and we have tried to keep
it that way. And third, a lot of Federal money and some State
money that follows students to the school of their choice, and
that model has worked extraordinarily well in American higher
education and I would like to see us adopt it in K through 12
education, which is a different subject.
So we pay a price for the autonomy and the choices that we
allow in higher education. In the prices at the fringe, we get
some lousy tenured teachers, some weird courses, some things we
wouldn't do if we were sitting up here in Washington and
deciding what to do.
One other thing before I ask my question. I was in a small
group of Senators with former President Cardoso of Brazil the
other day and Senator Hutchinson of Texas asked him what of his
several months at the Library of Congress would he take back
with him to the people of Brazil? What most impressed him about
the United States of America? He said, ``The autonomy of the
modern American university,'' he said. ``I have been all over
the world. No other country has it.''
I completely agree that we have far and away the finest
system of colleges and universities. We have a market system
that attracts foreign students, local students. This is the
season when parents and students are all falling all over
themselves to get admitted to colleges and universities. Grade
inflation exists lots of places, but the cure is not with the
accrediting agencies, it is with the presidents and the board
members of those institutions. They have grade inflation at
Harvard, but that doesn't make Harvard a bad university.
The Federal law says that what we are trying to do here is
to make sure that an institution is of sufficient quality to
receive Federal aid. The Federal Government is not trying to
make Maryville College X amount. It is just trying to make sure
Maryville College is of sufficient quality to receive Federal
aid. We have latched onto the accrediting agencies because
helps preserve the autonomy of the American university.
Now, how can we make sure we are not wasting Federal money?
I think by creating some more competition, and I would like to
start with Mr. Wallin. How can we encourage there to be more
people who do what you do? I am very wary of the States. I was
Governor. I was also Chairman of the Board of the University of
Tennessee. Am I going to unaccredit the university myself?
[Laughter.]
I also appropriate money. I also appoint all the board
members. I also go to the football games. There would be lots
of questions about States taking over this role, but who else
could is my question. Who else could?
Mr. Wallin. Senator, let me approach it a slightly
different way, if I may. First of all, I would agree with you
about the States. I am a political scientist and I remember we
used to describe State legislatures as good sausage-making
institutions. You just wait outside and you see what the
product is, not the donnybrook inside. I have never been
convinced, though I am a proponent of federalism, that every
State legislature in the 50 States is always wiser than the
government.
But as to how to encourage competition, well, again, let us
ask the question of why isn't there any? There isn't any
because the system was set up not to be monopolies but because
regions have certain interests and if you have regions, then
there is going to be a monopoly simple de facto. That is what
happened.
Senator Alexander. If I may interrupt, it was set up
originally as a self-help mechanisms, colleges to help
themselves get better. No one imagined at that time that we
would be spending $17 billion in grants and $50 billion in
loans with these agencies having the hammer over them.
Mr. Wallin. Right. No, that is true, and originally they
had to deal with questions such as, is this a high school or
college? So it was a quality question.
But the problem is, when you get to a situation like we
have now where you have, say, 800 or 900 colleges and
universities covered in a region, you have to ask yourself,
what possible educational standard could you require of all of
them? What is it?
Let us take the Southern, SACS. SACS doesn't have a
requirement requiring, say, foreign languages, history,
literature, mathematics, science, not at all. How could it? I
mean, do you really think that all of the members would agree
to that?
My point about the regionals is that I think they do a
great job of certain things, but they are not constructed in
such a way as to be able to do what everybody wants them to do
now. And so as far as freeing the system up a bit, I was going
to speak about that in my prepared remarks and I ran out of
time. A couple of things.
One easy thing to do is to get rid of the restrictions on
transfer of credit which exist according to an older age, as it
were. If you look at the number of States and colleges and
universities, you will see in their requirements that they will
accept a grade or a degree only from a regionally accredited
association. The reason was that there wasn't anything else
then. Regional meant accreditation, national accreditation,
institutional. And so that is an anomaly that needs to be
changed. Schools, States, they should be able to accept
whatever they want, and if they are going to use accreditation,
a specific kind of accreditation, they can do that, too, but
they should give an argument for it and not just count on it.
Second, there is one other thing you could do, but I just
don't see any chance of it being done, and I am not sure it
would work anyway, and that is if the Secretary of Education
were to say, well, I want everybody to start out on a level
playing field, so 3 years from now, all the colleges and
universities in this country are going to be unaccredited and
we are going to give them so long to find what they want to do
and get together with research universities or liberal arts,
whatever it may want to do.
Now, my guess is that even that, and that is a pretty
extreme measure, even that wouldn't work, because after all,
part of what we are dealing with is a tradition of
associationship with the regionals. The real problem, I think,
is that you cannot ask from something that which it cannot
give. So you are really left with this choice.
First of all, there should be more accrediting agencies,
and I am all for that. But fundamentally, do we want to try to
get from the regionals the kind of information the public and I
think Congress wants, which is the kind of information that
would replace U.S. News and World Report and all of those
things, or do we want to admit that that is going up the wrong
tree because that mechanism can't do it without sacrificing one
thing that I know that every single person here wants, and that
is the autonomy of the individual institutions.
That is why I suggested trying to go to a different
mechanism, but I really do not see a way except just getting
more and more heavy-handed. Let me look at the legislation, by
the way, if I may, just read one sentence of the current
legislation----
The Chairman. Doctor, we may have to move on to another
question. I apologize. I know that Senator Sessions and Senator
Clinton both wanted to get questions in here, and we are going
to get a vote in a minute and they are going to have to leave.
So if you don't mind, maybe we could reserve that and go to
Senator Sessions for five minutes and then Senator Clinton for
five minutes and then hopefully we will still have some time to
come back to it.
Senator Sessions. Thank you, Mr. Chairman. I find this
very, very interesting. I have had several experiences that
have affected me regarding accrediting agencies. I am on the
Board of Trustees at my alma mater, Huntington College in
Montgomery. It is a small liberal arts Methodist college, and I
was on their long-range planning committee which was driven by
SACS review, which was good, I thought.
In my understanding of it, there was a clear feeling that
if they deemphasized the historical religious connection, they
would probably come out better in this review, and in fact,
proposals were made to do that and over the years that has
occurred. In fact, some of the core curriculum required the Old
and New Testament and two semesters of religion and philosophy,
12 hours. It has been eroded. I didn't like that.
I attended the University of Alabama School of Law. The
dean there had been a JAG officer, and at one point in my
career as an Army Reservist, he supervised me. I learned when I
became Attorney General that the University of Alabama's
accreditation was being threatened because the accrediting
agency said the university could not allow JAG officers to
recruit students on campus because the accrediting agency did
not agree with the Clinton administration's policy on gays in
the military, the ``don't ask, don't tell'' policy. They
considered that discriminatory, and that the military was,
therefore discriminatory, and JAG officers could not come on
campus. The faculty voted in compliance with that decision. I
offered and encouraged the State legislature to pass
legislation to say the military could recruit on campus, and
they were allowed to do so after the legislature passed a law
that said they could, so the accrediting agency backed down
from that. However, the original decision did not sit well with
me.
Auburn University, I have been a critic of their board and
how they have handled things, but they have had an aggressive
board that has shown leadership, whether you agree with it or
not. Auburn University is--this is their information, but it
is, I think, true, ``the best producer of chief executive
officers for the Nation's best small companies than any other
college or university in the South,'' according to a Forbes
survey. They are the top public education institution in the
State and among the top in the Nation for educational value,
according to Money and Kiplinger's Personal Finance. Now, Mr.
Potts wouldn't agree with that, I am sure, because he has
another great university. [Laughter.]
They are ranked in the top 50 institutions in the Nation
for providing a quality education with educational value, from
the United States News and World Report. One of the top five
universities nationally for producing NASA scientists and
astronauts. Auburn's students are accepted into medical school
at 30 percent higher than the national average, and on and on.
Well, clearly, it is one of the country's great
universities and there was a fuss over the football team and
the board of trustees getting involved in that and embarrassing
the university and the president embarrassing the university
and their magnificent alumni association and everybody is upset
about it, and lo and behold, because of that, apparently they
are on probation, a great national university. Now, we have
other universities all over this country that are not nearly as
capable in turning out students with excellence educations.
Dr. Martin, I saw you nod there. Am I missing something
here?
Mr. Martin. I think you are right on target, Senator. If
you look at--of course, these reports are secret, which
actually is one of the problems in this. Accreditation is in
some ways the dark hole of higher education, so people try to
figure out what is actually going on. But when there is a
conflict, it tends to be reported in the press and the
Chronicle of Higher Education particularly.
We looked over the last 10 years to see where there is an
issue, a school's accreditation is being threatened, is it on
grounds of educational quality, and I have to tell you, we
didn't find a single one. Usually, financial instability,
mismanagement, that type of thing, small sort of failing
colleges, colleges that, in effect, the market has already
rejected and that is why it is failing.
The others, there were just a handful of others. One was on
the University of North Dakota. The big issue was the American
Indian used in their logo. The accreditors wanted them to use
that. One that came to light, the president of Tulane said that
because of the accreditors, he was going to have to--50 percent
of all new faculty hires for the next several years would have
to be minorities, exempting the medical school from that.
In another case, the accreditors told a college to actually
alter its mission, which is a very strange thing for
accreditors to do, and here is the actual statement. The
college mission and vision and department goals and objectives
should be developed around global concepts of race, class, and
gender. Why is that what accreditors get to say?
And another was the Auburn case, where the, as the
Chronicle reported, the issue was the board's micromanagement
of the athletic program and the Chronicle said no educational
issues were involved. So you wonder, is that what Congress
intended when it gave these accreditors life or death power
over the institutions?
Senator Sessions. Dr. Potts, I would be interested in your
comments on this, also.
Mr. Potts. I am on the Commission on Colleges, as I
mentioned, for the Southern Association, so I was recused with
all the Auburn discussions and none of this is based on
anything coming from inside SACS. I want to make that clear.
But what happened, in fact, was, and all of you are
familiar with the requirements we now have in Sarbanes-Oxley
and other things, the Southern Association has a standard with
regard to how governance of an institution should be. There
were numerous complaints filed with SACS for complaining about
what was going on with Auburn, including, and these are friends
of mine, a lot of them, but that there were conflicts of
interest, that there was self-dealing and everything. Auburn
then goes and preempts the process by filing suit and literally
hundreds of thousands of dollars were spent.
Probably SACS has never been in higher esteem in the State
of Alabama than it is now. The president resigned over this, or
did resign, the existing president. The new president, who is
the former State Superintendent of Education, just had a
meeting with SACS. It went very well, it was reported in the
press. And what we have is getting back with Auburn doing the
same thing that every other institution is, and to me, that is
an example of accreditation working well.
And I think you will see that what comes from this, and
again, speaking from just the reports, that you will have an
improved governance process in Auburn University because of
this. And I agree, they are a very fine university and this
didn't involve academics. But under the current law, under the
law, finance and administrative capacity and administration and
those sorts of things have to be looked at by accrediting
agencies.
So I think that you can always find extreme examples, but
if you look at the overall situation, you are going to find it
well to get back to Senator Alexander's question. You can tweak
this if you want to about political correctness if that is an
issue. You could give the authority to the Secretary to have
hearings and go through the rulemaking and make regulations on
a specific, narrowly-targeted area. But my suggestion is,
before you react to some extreme examples, make sure you
realize that, overall, this process is working well----
Senator Sessions. I don't dispute----
Mr. Potts. --but it needs to be tweaked.
Senator Sessions. I don't dispute that. A lot of these
reviews produce good results. I think it is healthy for a
university to be required to evaluate their long-range goals
and make decisions about them, but I find it odd that one of
the great universities in America finds itself on probation
over a dispute over the football coach or how the program is
administered. I really care about Auburn. I want it to be
successful. I think Dr. Richardson, the new president, is first
rate. I have admired him for many, many years, and maybe some
good things will come out of this.
But I don't think that is the principle, Dr. Potts. It is
not the utilitarian question of whether or not this may have
made a positive difference in Auburn at the time. It is a
question of whether this university that is producing quality
students with great graduate records, whether or not they ought
to be the one in Alabama on probation.
Mr. Potts. I guess we don't know enough about the facts
underlying that. I think there was a coincidence in the timing
of the situation involving the football program and this other
has been going on for many months, so----
Senator Sessions. I don't know the details, either, and I
appreciate that. I do think that it is healthy to have the
oversight, but I think we need to focus more on academic
quality.
The Chairman. Senator Clinton?
Opening Statement of Senator Clinton
Senator Clinton. Thank you very much, Mr. Chairman, and I
thank our panelists for being here. On behalf of Senator
Kennedy, who wanted to be here, I wanted to State for the
record he is very regretful that business has kept him on the
floor of the Senate because he is deeply interested in these
issues.
I really appreciate what my colleague, Senator Alexander,
said because I think he rightly summed up the tension that this
discussion represents. I come down very strongly where he does,
which is that the autonomy and independence of our higher
education system is a precious asset for this country and the
last thing in the world we need is to be looking to set
government standards of political correctness or incorrectness,
nor do we need the government overseeing the assessment of
these institutions.
I think that any human enterprise is going to be subject to
mistakes, flaws, and aberrational examples of not having
fulfilled its highest aspirations. But having been both on the
outside and inside of accreditation processes for a number of
years, I think on balance it has not only served the
institutions well, it has served our country well, and I would
hope that we wouldn't be chasing after the aberrational and the
extreme and upsetting the general and the positive work that
has been done in what really amounts to a remarkable public-
private partnership.
I also am one who believes that there is probably a lot
more ``mad cow'' around than there are bad colleges. Less than
one-tenth of one percent of our cows are inspected for mad cow
disease. We have cows falling down. We have cows going to
slaughterhouses who shouldn't be getting into the meat supply.
And so far as I know, at least in New York, every single
college is reviewed in the accreditation process. Maybe it is
not perfect, but it gives me, frankly more personal ease than
what we are currently doing in our meat inspection system.
One of the concerns I have is that given the diversity of
our higher education system, which again I think is one of the
great benefits--I held a meeting last week in Buffalo with
public, private, and religious colleges and universities, two-
and four-year liberal arts and research institutions, to ask
them what they thought about this debate. And around that table
were very small religious colleges and very large State
universities. To a person, they expressed great concern about
what they had heard coming out of Washington about the idea
that somehow they would have to take college credits from
institutions that they thought were either not accredited
appropriately or whom they disagreed with.
I had the president of a small Catholic college tell me
that they make a special point of teaching courses from a
faith-based perspective and she did not want to be having to
grant a transfer credit for a secular history course that was
not aligned with her college's standards.
The large universities that I have spoken with in New York
are deeply concerned that somehow after developing very
thorough processes that have led to articulation agreements,
that somehow that would be abbreviated or even eliminated as
opposed to leaving it within the hands of the institutions
themselves.
So I think that there are a number of issues that certainly
have come to my attention in the last several weeks as I have
sought out opinions and reaction from the variety of colleges
and universities in New York, and New York is now the number
one State of destination for college students coming from out
of State. So we are doing something right. I think our
diversity and our extraordinary range of offerings has created
a market that attracts more students from other States than any
other place in our country and we have a layered accreditation
process.
We do have something of a variety, Senator Alexander,
because we not only rely on the regional associations, but the
Regents of New York, which is an independent body appointed by
the branches of the legislature and the governor, and for very
long-terms to remove them from political interference, also
accredit some of the institutions.
So I think that this is an area where there certainly is
room for a vigorous debate, but I don't think it should be a
place to settle old scores and agendas that have to do with the
cultural wars that we apparently are going to fight at least
for the rest of our combined lifetimes. Instead, we ought to be
looking at this issue from the perspective of, I think, great
pride in our higher education system.
I think President Cardoso hit the nail right on the head.
There isn't anyplace that has done a better job that provides
not only tremendous opportunities, but second chances for
nontraditional students who, frankly, are not going to be as
well prepared, and frankly, may not have had either the family
background or the public school or other preparation.
And I would just conclude by saying that according to the
recent statistics I have at hand, we still only have 65 percent
of our students graduating from high school. We still have less
than 40 percent of those students ever entering college. We
still have only 20 percent in that cohort earning college
degrees within 6 years.
So we have a long way to go and there are a lot of
improvements that many of us are focused on in the pipeline to
higher education. But if anybody were to look from Mars at the
education system of the United States, I think the last piece
of it that they would want to start messing with is our higher
education system. We have a lot of work to do on preschool, on
elementary and high school, and I think we ought to provide as
much support as possible where changes need to be made that are
appropriate, look into them, but otherwise, I think it is a
road we should not go down with respect to interfering with
what has produced such an extraordinary product over so many
years.
The Chairman. Thank you, Senator Clinton.
I have to go to a budget meeting, unfortunately, so I am
going to turn the meeting over, but before I turn the meeting
over to Senator Alexander, I would be interested in this whole
e-learning issue. I just see such huge potential, as everybody
does, in this opportunity to learn via the Internet, but how do
we tie it into the issue of making sure that the product is
real and the product is producing results, and what is the
accrediting agency's true role in this exercise?
Mr. Crow. I think that you will find that many of the
benchmarks on e-learning are going to be established by our
very traditional institutions who already have reputations for
high quality in what they do on ground or in the classroom and
will hold their e-learning to those same standards. In fact, it
is basically from those people that we evolve our own
understanding of what constitutes quality in e-learning.
By and large, I think most folks are not uncomfortable with
it when it is provided by a traditional institution. Their
discomfort level starts to emerge when it is the sole delivery
of a single institution, and their concern at that point is
what within that institution stands as the voice or the
indicator of quality that you normally find in a traditional
institution? There are various ways that they can recreate that
kind of internal quality assurance and I think they also look
to us, as their accrediting agency, to be the third-party
reviewer to see whether they have done it correctly.
So I am convinced, at least within the kinds of
institutions that seek regional accreditation or even the
institutions that seek accreditation from an agency recognized
by CHEA or the Department, that there are some pretty good
hallmarks of what constitute quality in e-learning
environments.
The Chairman. Does anybody else want to comment on that?
Mr. Wallin. Yes, just a moment, if I may. My organization
has just finished up with a three-year study of this funded by
the Department of Education, by FIPSE, and of course one of the
things we found out is that if it came to education quality,
that is, what is actually being learned, you cannot hold e-
learning to a higher standard than you are going to hold a
classroom. And by the way, I agree with Steve. We found that
the best systems tend to be a combination, but there is real
disagreement here.
There are those of us who feel that much of American higher
education is absolutely fabulous, but also feel that those who
complain that students are walking in illiterate and leaving
ignorant sometimes are saying the right thing, as well. So are
you holding them to a higher standard or to the same standard
or a lower standard, and I think that is part of the issue
there.
And if I might, I noticed Senator Clinton has left, but I
did want to mention one thing about her remarks on the fear of
losing the autonomy of institutions if we do anything about
transfer of credit, and I would just simply say, as far as I
know, that certainly would not happen. Everyone I have ever
spoken to about transferability of credits agrees that the
accepting institution is the one who decides the acceptability
of it. We are only talking about the interposition of other
agencies doing it.
The Chairman. Thank you.
Mr. Potts. I would just like to say, it's AASCU's position
that if there is a broadening of the eligibility for financial
aid to distance learning type institutions, there is the so-
called 50 percent rule that you are aware of. We think the
accrediting community is prepared to handle that and judge
quality as they do the regular programs. We think the content
of the programs and the learning outcomes are the things that
should be measured, not necessarily the mode of delivery.
In one of my other roles, I was a chair at one time of the
National Conference of Bar Examiners and got to work with
American College Testing on developing tests and looking at
their products, and there are any number of tests for rising
juniors or whatever that can measure these outcomes in quite a
psychometrically sound way so that if the institutions or the
accrediting agencies or whatever wish to have more outcomes
information, they can get that fairly easily.
The Chairman. I regret that I have to leave. This has been
an excellent panel. It has been extraordinary, but I have to go
to a budget meeting. Senator Alexander--you will be in his good
hands.
Senator Alexander. [presiding]. It is very dangerous for
the chairman to do this. [Laughter.]
Thank you, Mr. Chairman, and I will only keep you a few
more minutes, but I would like to pursue, if I may, the idea of
whether there are appropriate ways to create a little more, if
not competition, choices. Let me mention two or three things I
have heard from you and then give each of you a chance to say
whatever you would like to about any of this.
One possibility might be--let me ask Dr. Wallin first, if
someone is accredited by your organization, are they also
accredited by the regional organization, or must they be?
Mr. Wallin. They must--no, they don't have to be and some
of them aren't. But more and more, we are finding that a number
of colleges come to us that are accredited by their regionals
and they want our accreditation to focus on their academic----
Senator Alexander. But they don't have to be?
Mr. Wallin. No, they don't have to be.
Senator Alexander. So if a liberal arts college decided
that your Good Housekeeping seal of approval was all it needed,
that would be fine, and that is a new development. That is the
last 10 years, right?
Mr. Wallin. Yes, sir.
Senator Alexander. So that is an example of how that can
work, and I gather in a sensible way. Are there other obvious
areas? You mentioned research universities. We have between 50
and 100, I guess is the number, research universities. There is
nothing like them quite in the world except in the United
States. They are very different than most other institutions.
That might be an area. Are there other areas like liberal arts
colleges? Let me just go down through the things I have heard.
That is one question, other types of--by type of institution.
No. 2, outside the region, as I understand it, the Middle
States Accrediting Association doesn't accredit schools in
California and the North Central doesn't accredit Vanderbilt.
Am I correct about that? It stays within its region?
Mr. Wallin. You are correct.
Senator Alexander. But wouldn't that be a possibility, to
allow--if an institution respected the accreditation of one
regional organization and preferred it rather than another,
would that not create some choices without terribly altering
the system?
Three, is there more power that we could give to the
Secretary without making the Secretary an overly intrusive
force? For example, the opinion of my legal counsel when I was
there 10 years ago was that while I could interrogate Middle
States about why it felt it was important to decide whether a
woman ought to be on the board of Westminster College and
whether Baruch College ought to have an 18 percent minority
admission, I couldn't tell it to do anything. I could say it
wasn't reliable as an accreditor. That was it. So is there more
power the Secretary ought to have toward this goal we are
talking about?
And another approach, would there be a possibility of
allowing the accrediting agencies to take difficult problems, I
mean, clear failures or clear institutions that are not
performing, and rather than deal with them themselves, refer
them to something else, either the Department of Education or a
board created by the Department, because my sense of it is that
all the accrediting agencies are asked to do here for the
Federal Government is a fairly minimum standard. We are not
asking you to turn every institution into Dartmouth. We are
just asking whether it is adequate as an institution to receive
students who have Federal funds. So what usually happens when
you have a marketplace and a set of choices, as we do in higher
education, you always have problems on the fringes. So should
we have a place for those issues to go other than to
accrediting agencies?
So that is four things I gleaned from what you have been
saying. I wonder if any of you would have any comment on that.
Why don't we just start there and go right down the line.
Mr. Crow. I will try to address as many of the issues as I
think I have something to say.
Senator Alexander. OK.
Mr. Crow. I think you may discover, and Dr. Wallin can
certainly be the one who testifies to this, that it is not easy
to set up an accrediting agency and it is not easy to get it
recognized as a legitimate accrediting agency. Quite often----
The Chairman. By whom? By the Secretary?
Mr. Crow. By the Secretary, because unless you are a
gatekeeper now for Title IV funds, the Secretary does not want
to evaluate you. So every new agency that seeks to have some
sort of DOE imprint on it discovers that it has to ask at least
one or two institutions or programs to take the risk of naming
this yet-to-be-recognized accrediting agency as a gatekeeper.
And so I think that is one thing right there.
I am not arguing that you change the rules of how you get
to be recognized as a gatekeeper, but once upon a time, the DOE
recognized all sorts of agencies, whether they were gatekeepers
or not, and once they decided they were only going to recognize
gatekeeping agencies, all of a sudden they no longer provided
that service of sort of legitimizing a new agency. CHEA can do
some of that, but for some kinds of institution agencies,
perhaps CHEA isn't even available to give that kind of
legitimacy.
Second, there are options. I mean, they are talked about
all the time. Selective liberal arts once upon a time thought
that they should set up their own accrediting agency. I have,
in fact, encouraged some of them to look at AALE when they were
frustrated with us, and largely it was over assessment of
student achievement that they were frustrated with us. We have
heard about the research universities frequently thinking about
setting up their own. I have offered to help tribal colleges
set up their own accrediting agency. So there is talk about it,
but when push comes to shove and really trying to get it
together, it turns out to be a much more difficult business
than a lot of folks want to step into.
Power to the Secretary--I think we learned the lesson of
1992, to be quite honest, and I think all of us are talking
about things and doing things differently than we did before
that situation, particularly about diversity and what right
does an accrediting agency have to be quite, or perceived to be
quite as prescriptive as some folks felt that Middle States was
at that time. I think the Secretary exercised through the
committee the kind of power that he needed to, and that is draw
attention to an issue and then leave it to us to try to
understand that issue and to respond to it.
The clear failures is a very interesting problem because we
do feel that the very institutions that are marginal for us,
and yet perhaps fulfilling some important need, we are not as
well equipped to actually serve them, to help them meet those
problems. We have had conversations about whether we should try
to get a program, some funding that could be done through the
Department and through their friendly accrediting agency to
actually help them. But as we are currently structured, I don't
have the funds to step into a troubled college and help it
develop the systems it may need to actually turn around and
survive.
I hope I have answered several of your issues.
Senator Alexander. That is very helpful. Thank you.
Dr. Wallin?
Mr. Wallin. Yes. Well, let me speak first of all to this
competition, because obviously I am for it. If the Secretary,
who is now a Senator, had not decided to free that system up,
my organization would not have been able to have applied to the
Secretary and receive recognition.
However, it is, I think, unrealistic to expect many more to
tread down this path. Not only is it difficult, the real
problem is how do you support such a thing? There is a catch-22
here. Accreditation is supported by membership. Well, how do
you gain enough members to have the budget paid for if you are
starting off and all 4,000 colleges in the country are already
members of an organization?
Little by little, some join you, some join both, but it is
an expensive operation to do all of this, and I can tell you,
as the person who raises the money for all that we do, it is
hard to imagine really making headway unless some other way of
funding were found. So that is almost a nonstarter, except for
getting rid of any artificial barriers, such as the transfer of
credit, things of that sort, that were never intended to be our
barriers but, in fact, have become them.
As far as accreditation, say referring nonperformers to the
Department or something of that sort, I wouldn't have any
problem with that except for one thing. On the basis of what?
Again, the difficulty is that, by and large, accreditation--we
are talking about institutional accreditation now--knows what
to do when it sees bad management. It knows what to do when it
sees financial problems.
The real difficulty is this. What if it is a wealthy
school, it doesn't have financial problems, it has a pretty
sound administration and a five-year plan, all of these things,
but the fact of the matter is the students aren't being very
well educated there? What sort of standards are required in
order to do something? Now, granted, we have them and we do
something about it, but we don't have 900 members, either.
To give you an idea of what this is like, I will not
mention the agency, but not too long ago, a new president took
over one of the regionals and had a very strong interest in
generating more of a general education program, more liberal
education, more required courses, and he tried to do that. We
had a meeting of the colleges in his region. They listened for
a little while until finally one of the representatives of a
State institution said, look, why don't you just get off it? We
are not in the business of this precious liberal education. We
are not going to do that. Boom, that was it. It is a membership
organization, and it makes sense if you think about what the
large State institutions are interested in and what the smaller
ones are.
Now, are there other groupings? Yes, there are these
natural groupings, such as liberal arts colleges and research
universities and maybe Bible colleges and other things. But
again, those natural groupings are not going to be enough to
just generate new accrediting agencies because of the problem
of funding them and maintaining them and all of that, but there
is not a built-in one.
The only new one I know, accrediting agency that has gotten
around that is the accrediting agency, the second one now for
teacher education, TEAC, and it was founded out of ACE, wasn't
it?
Mr. Potts. No, CIC.
Mr. Wallin. CIC, which is a membership organization. So
they started off with members. So it is hard to see how one is
going to improve things that way.
Give more power over accreditation to the Secretary. Now,
if what we mean by that, and I think what we mean by it is
this, that the Secretary would then hold accrediting agencies
more responsible for student learning. It is not that I
necessarily object to the power. I again see the problem is, on
what basis? On what basis is SACS, for example, which has,
what, 900 institutions, I think, or something, going to be able
to say, well, we are having a problem because the
administration is fine, the place has been here 200 years, and
gee, the presidents are good folks and everything is fine
except the real fact of the matter is if you sit in one of
those classes, they are really, really at a very low level for
what the place says it is doing.
About the only way I could think of that you could do
anything like that from a regional accreditor maybe would be to
get the school on false advertising, because as a friend who
helped me start this up once said, a man very familiar with
accreditation said, ``Do you want to know what the problem of
accreditation is in a nutshell? I will tell you. Accreditation
is and should be mission driven, but what that means is this.
If you go on a campus and the campus says, `Our mission is to
turn out chicken thieves,' the only question the accreditor is
interested in is, `Well, are they stealing the chickens all
right or not?' '' [Laughter.]
Mr. Wallin. Now, that is, of course, to be a little
flippant about a serious matter, but it is a problem that is
only solved, it seems to me, with specializing.
What I was suggesting, by the way, is something that is
evolving a little bit and that is that some institutions are
beginning to see that they want a little bit of both, that the
institutional accreditors do a very good job of what they do,
but they don't deal with specific kinds of education very well.
They don't tend to send the right kind of faculty there. It is
always large administrative teams and so on.
So right now we have before us, for example, a college that
is already accredited by Middle States and intends to stay
accredited and is going to come before my board at its June
meeting, as well. So there is a way of working together. It is
just a very slow process, trying to get that going. But it
seems to work fairly well, and I have spoken with Steve Crow
about this and we both accredit at least one institution. So I
can't define a silver bullet to do it.
Senator Alexander. I want to make sure I hear from Dr.
Martin and Dr. Potts, and then I think we have a vote in a few
minutes, so please go ahead, Dr. Martin.
Mr. Martin. I would like to try to answer Dr. Wallin's
question, on what basis might the U.S. Department of Education
play a role here. The cases of accreditation sanctions and
withholdings that Senator Clinton called extreme--let us not
focus on extreme cases, she said--I remind the committee are
the only cases reported in the last 10 years other than what
most cases are financial instability and mismanagement, which I
think goes back to your comment, Senator Alexander.
We are looking for a basic level here, and Dr. Wallin
testified that is what the regional accrediting associations
are good at. But the fact is, that could easily be done not by
a two-step process, but by a one-step process, by the U.S.
Department of Education placing reporting requirements on the
college, figuring out what are the criteria you need to be
financially stable, appropriately managed, and do you have a
coherent mission and so forth.
You could report that, with penalties for fraud, of course.
This is how the Securities and Exchange Commission and many
regulatory agencies work. You could do some spot checks like
the IRS to detect possible cases of fraud. It would be a very
clean case. As former Secretary Alexander knows, the financial
health of institutions of higher education is already done
separately by the U.S. Department of Education. It would not be
that much of a stretch to add these other qualifications to
make sure, basically, you are a legitimate college, not a
fraudulent institution.
So I would suggest--and then, that doesn't mean accrediting
disappears. Accrediting, we have to remember, existed prior to
the Federal Government stepping in and giving them life or
death power over institutions. Then it would be up to colleges
to use accreditors for whatever sort of certification they
desired, but it would be voluntary and for whatever consulting
they desired. But it would be voluntary for the purposes. I
think this would meet the needs of the Congress in ensuring the
nonfraudulence, let us say, of the student loan program.
Senator Alexander. Dr. Potts?
Mr. Potts. A couple of things. Right now, the Southern
Association just adopted new principles of accreditation to
give the on-site teams--they divided the review to off-site
teams and on-site teams. There is a clear mandate to the teams,
and I am leading 1 week after next, if you see an area of
weakness in this institution as a peer, you call that to our
attention, and there are these core requirements and these
principles, all the way from faculty qualifications to the type
of notices that are given to students and other things. And in
the law as it exists now, you have to have certain standards
with regard to curricula, faculty, facilities and equipment,
and so forth. If you want more performance data, you could ask
for that on student outcomes.
But one size does not fit all here, and you have got now
the option. It was indicated, when I was on the advisory
committee, Dr. Wallin's group came before us and was
recognized. You can choose that if you would like instead of
one of the regional associations. The nursing people adopted a
new--we now have two nursing accrediting associations. We just
heard about teacher education.
So there are ways now to address these problems that you
have raised and there is some market--there are market options.
But I think it says a lot that people are not leaving the
regionals in droves and that the 100 or so different types of
accrediting agencies all have a clientele, and over the last 10
years, there have been new ones created, as Dr. Wallin's group
is one of those.
So I think the things that you want to happen, most of them
can happen under the existing law or with very slight tweaking
of existing law.
Senator Alexander. I want to thank the four of you for a
very helpful afternoon. I think all of us, the Senators who
were here and those who haven't had a chance to come, are here
in the spirit of asking and trying to learn how this works.
Let me ask you one quick question, Dr. Potts or Dr. Crow.
When you finish your accreditation visit, your three-day visit,
say, at Murray State, which takes a lot of time, and I know
that, to whom do you make your report?
Mr. Potts. We write a report up and then we send it for
correction of factual errors back to the institution, no
substantive thing. Then we send that report to the Southern
Association office in Atlanta. They then refer that report to
something called the C and R committees of the commission,
which is a 77-member group, democratically elected, and they
measure those things that are found against the criteria that
are in place and then make a judgment as to whether that is
accepted, whether there has to be some follow-up, or whether it
is so bad that there has to be some sanctioning.
Senator Alexander. How often does the board of trustees of
an institution that you examine call the visiting team in and
say, we would like to spend the day or an afternoon with you
getting a full report on the strengths and weaknesses of this
institution?
Mr. Potts. We always have exit conferences, and the
president----
Senator Alexander. With whom?
Mr. Potts. The president sets that up as to how broad or
how narrow it is. I did one last year for Angelo State.
Chancellor Urbanovsky and board members came to that one.
Senator Alexander. Did they?
Mr. Potts. Yes. We almost always talk to individual
trustees, usually the board chair, when we are on the campus.
Senator Alexander. In the private world, often at some
point the president is asked to leave the room and the auditor
comes in and meets privately with the board and they spend a
couple of hours telling him or her whatever needs to be told.
I have a very strong bias here. I haven't been here long
enough. I mean, I have got a real concern about two things in
higher education which I have already said I think is awfully
good. One is the one-way view on so many campuses, which just
disgusts me because they are supposed to be places of real
diversity, and there are places where quality is lacking.
But I haven't been here long enough to get comfortable with
the idea of fixing it in Washington, because as Secretary, I
may have been offended by what the Middle States Association
did in terms of setting itself up as the arbiter of diversity,
but the next administration might completely disagree with me
and want to insist on that at every place. You might have
Senator Helms or Senator Kennedy. If you get up here, all of
this gets into what you are doing and it interferes with the
autonomy.
So I am looking for ways, I guess to, put the
responsibility for quality back with the president and the
boards and to try to understand. However, at the same time we
have given this enormous power to accrediting agencies, this
enormous hammer, which maybe they didn't even ask for. We don't
pay them to do it, which is a good point, Dr. Wallin, although
if we did pay you to do it, that would raise all sorts of
questions, too. Some Congressman would come right along and
want to add about five things he wanted you to check on and
three or four cultural aspects of each campus.
Let me invite you, as you reflect on what each other has
said today and the questions you have been asked, if you can
add to the specific suggestions you have already made, which
are very helpful, on ways that we can provide more options for
accreditation, make accreditation more useful for quality while
at the same time preserving the autonomy of the American
university, we would all welcome that.
I thank you very much for joining us and the hearing is
concluded.
[Additional material follows.]
ADDITIONAL MATERIAL
Prepared Statement of Steven D. Crow
Mr. Chairman and Members of the Committee, I appreciate the
opportunity to be here today to discuss Higher Education Accreditation.
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 24 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 co-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.
Each regional institutional accreditation agency was created by the
colleges and universities it accredits. For the past 50 years these
agencies, originally established to provide self-regulation and shared
assistance in stimulating institutional and education improvement, have
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 of
Federal student financial aid and other Federal grants to those
institutions. For the past 15 years in particular, we 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.
As we have every 5 years since the passage of the first Higher
Education Act, we are engaged again in very basic discussions about how
accreditation generally, but regional institutional accreditation in
particular, effectively serves the public interest through its
gatekeeping role for Federal funds. A little over a decade ago, the
concern was whether accreditation could be an effective shield against
fraud and abuse. The last decade, I believe, has shown that it can be.
It is fair to say that most of us, although deeply concerned by the new
levels of Federal oversight established in 1992, have come to
understand, appreciate, and support the relationship we now have with
the Department of Education.
But we understand that new concerns mark this reauthorization. We
welcome the indications we have received that the link between regional
accreditation and Title IV gatekeeping will be retained and
strengthened. This is wise policy because:
Accreditation has proven to be an effective partner with
the Federal Government over the decades, responding effectively to new
Federal requirements adopted in 1992 and continued in 1998.
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.
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.
Accreditation through private, non-profit agencies
provides exceptional service at no direct cost to taxpayers.
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.
Self-regulation of the quality of higher education through
recognized accrediting agencies is an effective tool to inform the
marketplace because it relies on expert judgments of higher education
professionals; moreover, because of that expert judgment it carries
significant credibility with the institutions under review.
Without assuming to understand all of the other significant issues
that each member of this Committee might want to discuss, I will
address the primary issues that my regional colleagues and I understand
to figure most prominently in this reauthorization. I will list the
matters and provide a brief summary of how most of us in regional
accreditation understand each issue and how we would like to shape our
relationship with the Department to address it. Several regional
associations part of C-RAC have put forward to members of the House and
Senate specific legislative proposals. The following comments summarize
much of the contents of those proposals.
Institutional and 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 4 years placed achieved student learning at
the center of those new standards.
But measuring student learning for the goal of educational
improvement, no matter how well it is done, does not automatically meet
the current expectation that the findings of those measurements be
shared with current and prospective students and the public at large.
The fact is that a surprisingly large number of our colleges and
universities have lots 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. While concerned about the any law
that would summarize educational performance in a few standardized
measures applied to all types of colleges and universities, we would
support legislation that:
Continues the expectation that a federally recognized
accrediting agency has standards related to successful student
learning. We encourage legislative 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 (ED-OIG/A09-C0014, July 2003).
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
(1) 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. We highly recommend that this be stated as
an expectation for agency practice, not as a requirement for specific
learning outcomes standards that a recognized agency must adopt and
apply.
Establishes for Department recognition the creation and
implementation by an accrediting agency of a stronger program of
disclosure about accreditation processes, accreditation actions, and
the finding related to those actions. At this point, the regional
commissions have not agreed on a common template that we all might use,
but it is one of our highest priorities. We strongly urge that the
template for public disclosure not be defined in law, allowing
important conversations within accrediting community to create
effective and appropriate models.
Student Mobility and Transfer of Credit
Accrediting standards hold that the institution granting a degree
must be accountable for the integrity of that degree. Yet we appreciate
the fact that transfer of credit is a matter of public concern.
Although none of the regional accrediting associations have policies
that limit the variables an institution should consider in determining
transfer, we have come 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 caution against any wording in this
reauthorization that could be interpreted as Federal regulation of this
key component of institutional academic integrity. Yet we would support
legislation that addresses transfer of credit by:
Requiring institutions receiving Title IV to evaluate more
than the accredited status of an institution in determining
transferability of credits awarded by it.
Requiring that an institution's transfer policies and
procedures state unambiguously the criteria that will be weighed in
determining transfer of credit.
Stating that a Department-recognized accrediting agency
will have procedures through which it reviews transfer policies during
each accreditation review to ensure that they meet Federal and agency
expectations. While we also caution against adding significant new
record-keeping and reporting requirements on transfer, we are willing
to be expected to include in our accreditation reviews any public
reports on transfer that might be required by State or Federal
agencies.
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 a ``scheduling option.''
The concern about eLearning appears to be directly related to the
call to end the 50/50 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 for its abolition should be enhanced
scrutiny of distance education (eLearning) currently provided by our
member institutions. Therefore, we would recommend that this
reauthorization:
Require Department-recognized accrediting agencies to
document that their existing standards provide for effective evaluation
of the quality of distance education. We propose that in lieu of
defining special standards for eLearning, the bill rely on the standard
of comparability: namely, that student learning in eLearning programs
be comparable to that in campus-based programs. All regional
associations have already been recognized by the Department as
providing effective quality assurance for distance education. We would
propose that such recognition be honored and, therefore, that we not be
asked to review again all of the distance education and eLearning to
which we have already extended accreditation.
Recognize our offer to create and implement processes that
allow us to monitor when appropriate those institutions with
dramatically increasing student enrollments in their eLearning
programs.
Include, if found appropriate, our offer to document that
our peer reviewers are selected and/or trained to ensure their capacity
to evaluate eLearning.
Include, if found appropriate, our offer to include within
our reviews of eLearning an evaluation of how the institution documents
the integrity of the student in eLearning courses and programs.
Mr. Chairman, thank you very much for the opportunity to testify
today. I look forward to learning from my fellow panelists and
answering any questions that you and the other members of this
Committee may have.
Prepared Statement of Jeffrey D. Wallin
Thank you very much for having me here today. Higher Education in
this country is on the road to becoming ubiquitous. This is in large
part due to the efforts of many at the state and national levels to
provide access to student populations that had not previously attended
college. However, in the last two decades serious questions have been
raised about whether the quality of higher education has kept up with
its growth in access and in expense. Report after report have confirmed
what every professor privately groans to himself: the qualifications
for success in higher education cannot be reduced to mere native
intelligence and ability; almost as important are the skills that we
used to take for granted in any high school graduate, but which now are
sadly lacking in all too many entering and returning students.
I do not mean to imply that this problem has in any way come upon
us unexpectedly. Most of us are familiar with Walter Lippmann's
complaint that the modern world has ``established a system of education
where everyone must be educated, yet [where] there is nothing in
particular that an educated man--he meant men and women--should know.''
But this was preceded by many other observations of the sort, including
Winston Churchill's that ``education is at once universal and
superficial.'' It is our duty and our responsibility to do what we can
to preserve this newly won access to higher education while resisting
any increase of superficiality or lowering of quality.
Considerable pressure has been brought to bear on higher education
to account for the rising costs of higher education that have
accompanied its growth; this, coupled with repeated revelations of what
is not being learned at the undergraduate level has resulted in the
rapid spread of learning assessment in recent years. Since funding
provides one of the few levers by which one may attempt to prod higher
education, accreditation, which acts as a ``gatekeeper'' to federal
funds, has been required by law to develop or at least monitor outcomes
assessment at its member institutions.
Historically, AALE has been a proponent of educational assessment,
and while we remain a proponent, we believe that assessment has been
taken as far as it reasonably can be taken by institutional or regional
accreditation.
The American Academy for Liberal Education was established in part
to strengthen general and liberal learning by establishing substantive
academic accreditation standards, such as foreign languages,
mathematics, history, philosophy, science, and so on. While we believe
there is much to say for this approach, we are aware that it speaks
only to the input side of the learning equation, not to the output
side, and thus have spent a good deal of time in assessing student
outcomes as part of moving accreditation from an almost exclusive
concern with resources to a system also concerned with learning.
Our involvement with moving accreditation from a process or
resource based instrument to one focused on student learning began
several years ago, with major grants over several years from the Pew
Charitable Trusts and the John and James Knight Foundation.
Fortunately, considerable work already existed in this field, and
with the help of leading figures, such as Peter Ewell of NCHEMS and
others, we were able to refine and adapt some of this for use by
accreditors.
Following our initial grant, Pew then went on to make grants along
the same line to some of the regional accrediting bodies. Although our
grant was smaller than any of the others, an independent review
commissioned by Pew found the AALE grant to be the only clear success.
Learning Assessment is now, or is becoming integral to
undergraduate accreditation. While it is true that assessment is still
in its infancy, I believe that its considerable benefits are becoming
apparent. Perhaps the most significant of these, from AALE's point of
view, is that it has proven to be one of the very few instruments that
can be successfully employed to encourage faculty to reconsider just
what it is that general education is supposed to do. Answering that
question--which is necessary if one is going to assess whether the
means chosen to achieve these objectives are working--is the critical
first step in what seems to be a return to faculty responsibility for
undergraduate pre-major education.
The loss of a core curriculum at many colleges over the past few
decades requires this because that loss has of course been accompanied
by an increase in variety. But difference resists assessment, making
the assessment of such a variety of programs extremely difficult. As
much as academic fields of specialization may have their own internal
difficulties they do, by and large, agree to the course of study likely
to produce a good chemist, engineer, or lawyer. Competent assessment of
the effectiveness of such programs is widespread, which is attributable
to the common coursework taken by all. Thus we ought not to be
surprised that the most difficult comparative data to obtain is of
undergraduate student learning, particularly in the general education
portion of the curriculum. And so now we have one more argument for
restoring the core: in addition to its educative value, its ends can be
known and therefore assessed.
Success in accreditation monitored student assessment at the
undergraduate level has, as mentioned above, produced considerable
good. However, this has been accompanied by a very real cost, a cost in
lost time. Assessment has added to the erosion of faculty and
administrative time, something itself that may well be responsible for
maintaining poor learning outcomes. I believe this loss of time is
significant and that we should be careful not to increase it further.
We run the risk of reducing the amount of actual teaching taking place
on our campuses and perhaps even of creating a huge but artificial
edifice of assessment protocols and bodies of evidence whose purpose is
mainly to allow faculty and administrators to ``give the accreditors
what they want'' in the shortest and least painful way. The result
might turn out to be little more than a cluster of Potemkin villages
built of assessment tools and products, not education. Something like
this has already resulted at some institutions as the result of goal
driven administrations that seem satisfied, not so much with real
improvement as by the creation of countless departmental mission
statements, often submitted yearly; as if the mission or goals of the
Biology Department were expected to change from year to year. The
important point is that even Potemkin villages take time to construct,
and time to maintain
There is an old saying that ``Even a king should not ask for what
cannot be given.'' This, I think, is the heart of the problem we now
face. Institutional or regional accreditation was never designed for
the kind of assessment that is increasingly desired, and it cannot
succeed in producing it. The assessment system currently being
developed will not and can not provide the public with what it would
like to have: objective rankings of different colleges and departments
as an alternative to the resource-driven rankings of popular magazines.
The means necessary to obtain such information, at least through
regional accreditation, would risk destroying some of the most valuable
characteristics of American higher education, namely, faculty and
college autonomy, freedom, and judgment. To produce truly comparable
data, regional bodies would have to impose the same requirements and
therefore the same kind of education upon their entire regions, and
then throughout the country.
In short, I believe the current legal standards on this issue are
adequate as they stand. Let me remind us of what it says.
Sec. 602.16 Accreditation and preaccreditation standards
The agency must demonstrate that it has standards for
accreditation, and preaccreditation, if offered, that are sufficiently
rigorous to ensure that the agency is a reliable authority regarding
the quality of the education or training provided by the institutions
or programs it accredits. The agency meets this requirement if-
The agency's accreditation standards effectively address the
quality of the institution or program in the following areas:
(i) Success with respect to student achievement in relation to the
institution's mission, including, as appropriate, consideration of
course completion, State licensing examinations, and job placement
rates.
As will be noticed, section (i), which is most relevant to this
issue, includes these qualifiers: ``in relation to the institution's
mission'' and ``as appropriate.''
We believe that a stronger demand, such as the one proposed by C-
RAC would make things worse rather than better by further
institutionalizing assessment as the goal of education rather than as
simply one means to it.
All too often objections from the accreditation community are
treated as merely self-serving or as ways of trying to avoid legitimate
public scrutiny. I would not argue that this is never the case. But in
the case of learning assessment it is precisely those of us who were on
the forefront of demanding more of it who are now sounding the alarm
lest it overtake in importance learning itself. Perhaps is time to
recall the old Midwestern observation that ``You don't fatten a hog by
weighing it.''
I wish to make it clear that nothing in these remarks is intended
to suggest that better assessment cannot be achieved. My object has
been to show that regional or institutional accreditation is not a
proper vehicle for doing so. In my view institutional accreditation
regarding student assessment should be left exactly where it now is,
namely, ensuring that colleges and universities have procedures in
place for demonstrating that they possess adequate means of assuring
themselves that their educational purposes are being met. The range of
acceptable procedures should be very wide, so as to accommodate the
enormous variety of education offered in this country.
Are there no other ways of strengthening the link between
accreditation and learning assessment? Yes, I believe there are, at
least if one is willing to reconsider the present structure of
accreditation.
It would be possible to revamp the present accreditation system so
as to obtain the kind of answers the public seeks. Although regional
accreditation is not set up for the sort of assessment that is
apparently being asked for, other forms of accreditation are set up to
do this. In fact, the fields of specialization represented by
specialized accrediting agencies have always concerned themselves with
content assessment. We do not hear any public outrage to the effect
that students are graduating with biology degrees ignorant of biology,
or that musicians, who have for centuries had to meet high performance
standards, cannot play their instruments. Assessment works when it is
focused on a specific subject or activity and when it is judged by
experts in the field. The problem lies within the general education
portion of the curriculum, which does not present a uniform entity to
asses, and where expertise is not so easy to find.
This is why Milton Greenburg has argued (``It's Time to Require
Liberal Arts Accreditation,'' in the AAHE Bulletin, April, 2002) that
the only way to solve the assessment problem as it applies to the
academic skills so many claim are not being taught or not being taught
well, is to move in the direction of specialized assessment of general
education and liberal education even though the latter is often defined
as the opposite of specialized education.
One possibility would be to hold the specialized accreditors
responsible for general education. As it now stands, almost all of them
require students to enroll in such programs, but the quality of the
programs are assumed to have been assured by regional accreditation.
Since we know that this is a false assumption, perhaps the subject
specific accreditors should demand directly from the institutions
themselves evidence of the skills and knowledge they claim their
students are acquiring. Another way would be for most or all of the
specialized accreditors to come to some sort of agreement as to just
precisely what it is they expect from such programs and then design
means of testing for them just as they now test for accomplishment in
their fields through exams, performances, exhibitions, and so on. While
I believe this might work, I must point out what I consider to be a
very real objection to this suggestion, at least from the standpoint of
AALE. Given that liberal education is already under assault from those
who believe that only concrete skills and specialized knowledge is
useful, I would be very cautious about any solution that would lead to
more specialization, since it is hard to believe that it would not be
detrimental to the wider hopes and ambitions of liberal education.
Another possibility suggested by Greenburg would be to reorient
undergraduate accreditation away from the present geographically based
system (an historical remnant of the past rather than a well designed
tool for the current century?) to a subject or institution based
system. That is, there could be a number of institutional accrediting
agencies that focus on separate kinds of institutions or forms of
education, regardless of where they may be located. Thus we might have
an accrediting agency for research universities, one for liberal arts
colleges, one for community colleges, and so on, bringing a new form of
expertise to bear on specific forms of educational institutions. (AALE,
of course, is just such an agency, one that deals with the liberal arts
exclusively.) This would, in effect, turn undergraduate student
assessment over to scholars in the fields being assessed, thus bringing
the strengths of subject mastery to assessment. Even in the case of
liberal education we have people who, while not being degreed
explicitly in liberal education, understand the liberal arts and more
importantly, understand the relation between them and the goals that
lie beyond them. Regional accreditation might then be allowed to
concentrate on what it does best, assuring the reliability of the
processes and resources of educational institutions, and weeding
diploma mills out of the system. (Of course, not all specialized
accreditation performs so well, which is a good reason for encouraging
competition in all fields of accreditation. If, for example, NCATE is
thought by many not to contribute to strengthening teacher education,
then by all means start up an alternative, such as TEAC.)
I'm sure one could come up with other ways to improve content
assessment, but the point here is that demanding it from the regionals
is only likely to increase the problems faced by higher education, not
reduce them. They were never intended to do this and pushing them in
this direction is likely to be unproductive as well as unfair.
Before closing, let me bring up a few other issues. I have
mentioned above the virtues of competition. Unfortunately, however, the
accreditation market has not been competitive for some time now. One of
the reasons is that the transferability of student credits has been
held up by organizations that at one time had no need to draw
distinctions between institutional and regional accreditation. Thus, to
adopt a policy that course credits can only be transferred from one
regionally based accrediting agency to another, a policy that made some
sense long ago when they were written, has the effect today of placing
artificial barriers between good students and good educators. C-RAC
addresses this problem but does not go as far perhaps as it should. If
a school's course credits are accepted because it is accredited by a
regional agency, why is this superior to a school accredited by a non-
regional agency with strong academic standards so long as it is also
recognized by the Secretary? This is to place altogether arbitrary
restrictions on a publicly funded system in a country in which
geography matters less and less. AALE believes that the final decision
to accept or not accept course credits from another college is the
individual institution's prerogative, but to be defensible, that
prerogative must not be artificially skewed to favor a system designed
prior to present realities. Until such artificial barriers to transfers
of credit are lifted, the illusion of a fair playing field will remain
just that, an illusion.
Prepared Statement of Jerry L. Martin
By federal law, college accreditors have a loaded gun pointed at
the head of every college. They have the power to close the door to
federal funding, including access for their students to the federal
student loan program--access without which colleges today cannot
survive. This is an extraordinary power for a private entity. It
requires a strong burden of proof to show that this power is warranted.
The rationale for giving this power to accreditors is to ensure
quality. That is what surveys show the public wants and that is what
Congress thought it was getting when it authorized the accrediting
system.
In theory, accreditors guarantee quality. Does the reality match
the theory? College accreditation became a mandatory feature of the
federal student loan program in 1952. Have they been successful in
ensuring academic quality since that time? What is the evidence? Those
are questions asked by the American Council of Trustees and Alumni in
its recent study, Can College Accreditation Live Up to Its Promise? My
comments today will focus on three areas: grade inflation, the
curriculum, and academic freedom.
1. Grade Inflation. Grade inflation has been increasing over the
last 40 years, not decreasing. Nothing is more essential to upholding
quality and motivating academic achievement than giving honest grades.
Another report by the American Council of Trustees and Alumni, 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 reported last
week 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 that 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.
2. Curriculum. 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.
A 1996 study conducted by the National Association of Scholars
concluded that:
``[During] the last thirty years the general education programs of
most of our best institutions have ceased to demand that students
become familiar with the basic facts of their country's history,
political and economic systems, philosophical traditions, and literary
and artistic legacies that were once conveyed through mandated and
preferred survey courses. Nor do they, as thoroughly as they did for
most of the earlier part of the century, require that students
familiarize themselves with the natural sciences and mathematics.''
Ten years ago, a comprehensive study by a University of California
at Los Angeles team headed by Alexander W. Astin found that, although
almost all colleges claim to have a core curriculum in their brochures,
only 2 percent have a ``true core curriculum.''
According to the National Association of Scholars study, courses on
English composition, which used to be an almost universal requirement,
have eroded by one-third since 1914. Needless to say, the universities
studied are all accredited.
When the American Council of Trustees and Alumni surveyed college
seniors' knowledge of American history, it found that only one in four
could correctly identify James Madison or George Washington or the
Gettysburg Address. The study also found that, of the 50 colleges
studied, not a single one required a course in American history and
only five of them required any history at all. Needless to say, these
schools are all 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.''
In light of these courses, it is hardly surprising that the
Association of American College's study, Integrity in the Curriculum,
concluded that, as for what passes as a college curriculum, Cole
Porter's lyrics sum up the situation: ``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.'' In short, if meat
inspections were as loose as college accreditation, most of us would
have mad cow disease.
3. Academic Freedom and Intellectual Diversity. Freedom of inquiry
is essential to the life of the mind. A robust ``marketplace of
ideas,'' as Oliver Wendell Holmes, Jr., called it, is the essential
incubator of thought and learning. Professors must be free to pursue
truth wherever evidence and reasoning lead. Students must be exposed to
opposing points of view, be given the knowledge and skills necessary to
make up their own minds, and be free from intimidation.
Yet it has been over ten years since Harvard president Derek Bok
and Yale president Benno Schmidt sounded the alarm and warned the
public that the major threat to academic freedom in our time is
political intimidation on campus--which has come to be known as
``political correctness.''
A 1994 study by Vanderbilt University's First Amendment Freedom
Forum found that more than 384 colleges had adopted speech codes or
sensitivity requirements that threaten academic freedom. Currently, the
Foundation for Individual Rights in Education has a database,
accessible at its website that contains hundreds of current policies
restricting free speech.
And the Student Press Law Center finds that, since 1997, more than
370,827 student newspapers were stolen and destroyed by students who
disagreed with their point of view. We are not aware of a single
instance of accreditors raising a concern over this issue although it
clearly diminishes the intellectual debate that is so essential to
education.
A recent Smith College study showed a disturbing one-sidedness in
the partisan affiliation of faculty members in the humanities and
social sciences--a pattern so marked that, if race or gender were
involved, it would be regarded as clear evidence of discrimination.
Diversity of ideas could be provided by outside speakers. But
students and some professors regularly complain that panels on
controversial public issues are almost always one-sided. Sometimes
dissenting speakers are not even permitted to speak. Speakers as
distinguished as Henry Kissinger and Jeane Kirkpatrick have been
prevented from speaking because some students or faculty objected to
their views. Former Assistant Secretary of Education Chester E. Finn
has summed up the situation by describing universities as ``islands of
repression in a sea of freedom.''
These restrictions on free and open debate are intolerable and
clearly diminish students' educational experience. And yet accreditors
have failed to address these issues effectively.
If the accreditors are lax when it comes to enforcing standards of
educational quality, what demands are they placing on universities? It
is hard to find cases of a denial of accreditation where the financial
solvency of the institution is not at issue. Yet, in this area,
accreditors are largely redundant. 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.
Meanwhile, Auburn University's accreditation is currently
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 this is
what Congress envisioned when it gave accreditors the power to cut off
a university's federal funds.
Accreditors have also had a pattern of imposing their own social
philosophy on the colleges. As a result, some educational leaders have
even had to face the prospect of incompatibility between accrediting
standards and the very nature of their institutions. In the best-
publicized instance of such conflict, Thomas Aquinas College was
threatened in 1992 with a loss of accreditation due to the fact that
its avowedly Catholic, traditional orientation had no room for the
multicultural courses that its accreditor was prescribing. The Great
Books curriculum at Thomas Aquinas was the very key to the school's
mission--so much so that there were no elective courses at all. As the
college's president, Thomas Dillon, said at the time: ``In the name of
advancing diversity and multicultural standards within each
institution, [proponents of diversity] are imposing their own version
of conformity and threatening true diversity among institutions.''
That same year, the accrediting association was denounced by
President Gerhard Casper of Stanford for ``attempting to insert itself
in an area in which it has no legitimate standing.''
Similarly, accreditors threatened to sanction Baruch College on the
grounds that 18 percent minority representation on the faculty was not
enough and Westminster Seminary because composition of the governing
board was not gender-balanced.
At the time, Education Secretary Lamar Alexander wrote, ``I did not
know that it was the job of an accrediting agency to define for a
university what its diversity ought to be.''
Secretary Alexander took decisive steps to correct the problem--at
least with regard to formal criteria. Since that time, the problem has
gone underground. Each accrediting team has enormous latitude to apply
its own particular brand of social philosophy and can do so with
relative impunity since rarely is the accrediting process made public.
At Tulane, for example, the president announced in 1995 that, to comply
with accreditors' demands, 50 percent of all faculty hires outside the
Medical School would have to go to minorities--a quota of precisely the
sort the Supreme Court has consistently ruled unconstitutional.
A heavy-handed insistence on demographic quotas is not as
dangerous, however, as dictation of what intellectual approach faculty
should present to their students. At an urban public university, to
cite one 1999 case, the accrediting team actually had the gall to tell
the institution to alter its mission along ideological lines: ``The
College mission and vision and department goals and objectives, as well
as the assessments, should be developed around global concepts of race,
class, and gender''--the three code words for a politically correct
agenda.
If we judge accreditors on their performance, it is a record of
persistent failure. On their watch, colleges have experienced runaway
grade inflation, curricular disintegration, and the closing of the
``marketplace of ideas.''
Our original question was: Is the life-or-death power over colleges
and universities that federal law gives accreditors warranted? Since
the rationale for the power is to ensure quality, the question becomes:
Do accreditors ensure educational quality? The answer must be a
resounding, ``No.'' They do not ensure educational quality. In some
respects, they make it worse. Their power is not warranted.
What is the solution?
The ideal solution is to de-link the federal student loan program
from accreditation. A much simpler procedure--and one infinitely less
costly and inefficient--could be set up within the U.S. Department of
Education to certify qualified institutions. It could be similar to
required reports and penalties for fraud used by the Securities and
Exchange Commission. This should be sufficient to identify the
institutions that are ``colleges'' in name only.
In addition, for public universities, there are already two sources
of accountability.
First, 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.
Second, state higher education agencies--such as the Colorado
Commission on Higher Education and the State Council of Higher
Education for Virginia--are embarked on what has been called an
``accountability revolution.'' They are framing performance measures
that look at educational results and not just inputs. Former U.S.
Senator Hank Brown, a former college president, 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. If Stanford, Baruch and Thomas Aquinas had had an
alternative in 1991, the accreditors would never have become so high-
handed. If current accreditors are so reluctant to apply meaningful
standards of quality, why not allow alternatives that will?
There are two promising alternatives that can provide much-needed
competition.
First, the American Academy for Liberal Education was founded
explicitly to set a high academic standard in the liberal arts and
provides an alternative to the regional accrediting associations. Less
than ten years old, it has been approved by the U.S. Department of
Education and accredits a number of colleges and academic programs,
such as honors colleges. These colleges take pride in being able to
meet the high standards upheld by AALE--it is like a Good Housekeeping
Seal of Approval--and thereby assure potential students and their
parents that this is a school of unusually high quality.
Second, Congress should consider Senator Brown's suggestion that
perhaps the states could accredit institutions--on a purely voluntary
basis--if they so chose. Originally, the Higher Education Act did allow
states this option. New York has done so in nursing and vocational
education without problems but, since the early 1990s, this opportunity
has been denied to other states. 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 American Council of Trustees and Alumni hopes that Congress
will address these important issues of educational quality and
accountability and encourage competition among accreditors.
Prepared Statement of Robert L. Potts
Chairman Gregg, Members of the Committee, Ladies and Gentlemen:
Good afternoon. I am Robert Potts, President of the University of North
Alabama. I also serve on the Board of Directors of the American
Association of State Colleges and Universities, and have worked
extensively in the accreditation field for more than twelve years. I
offer my testimony today on behalf of the American Association of State
Colleges and Universities (``AASCU'') which represents more than 425
public colleges, universities, and university systems located
throughout the United States and its territories. These institutions
enroll nearly 3.5 million students--more than half of all students
enrolled in the nation's public four-year institutions. On behalf of
our member institutions, I am grateful for your invitation and pleased
to be with you today.
The central issue before your Committee today appears to be how can
the existing accrediting and federal financial aid systems assure
better quality and accountability for higher education students and the
public? Ladies and gentlemen, based on my perspective as a university
president and a long-term accrediting volunteer, the short answer is
that a fair review of the evidence throughout this country will show
that the present system that exists under the Higher Education Act--
with the Department of Education working in partnership with the
regional, national, and specialized accrediting agencies that are
recognized by the Secretary of Education--does an excellent job in most
cases for students and the public. Certainly, de-linking accrediting
and eligibility for federal financial assistance would damage
irreparably the system for quality assurance that exists in this
country today. To do this would leave no effective way, short of
massive expenditures for federal inspectors and regulators, to replace
thousands of accrediting volunteers throughout the country who work
tirelessly year-in and year-out to assure that quality standards are
met by higher education institutions to protect students and the
public.
Based on my years of experience in the field, and also from my
service on the National Advisory Committee on Institutional Quality and
Integrity for six years, I can point to example after example where the
current system has resulted in significant improvement of quality on
campuses throughout the country. The system that exists whereby: (1) an
institution studies itself as measured against democratically developed
quality criteria; (2) the institution then is visited by a team of
peers from other institutions who write a report; (3) that report is
critiqued by another group; and (4) finally, advice is given to the
institution as to where improvements need to be made, results on most
occasions in significant improvement to the academic programs and
institutions in question.
For example, I know of one institution that had a number of
overseas and distance learning programs that had developed rather
quickly. That institution received over 100 recommendations for
improvement from its accreditor. These recommendations were taken
seriously, and when the next accreditation visit occurred a decade
later, the institution had greatly improved its quality and received
less than ten recommendations following the reaffirmation of
accreditation process. Frequently, accrediting teams that visit
institutions are viewed and serve as unpaid consultants to suggest best
practices to help improve the institution or program.
The highly regarded Council for Higher Education Accreditation
(CHEA) has identified nine characteristics of American higher education
accreditation that make it unique and effective:
Involves judgments of quality and effectiveness of an institution/
program against a set of expectations (standards, criteria).
Is a form of non-governmental self-regulation as contrasted to
compliance with state and/or federal rules, regulations, and codes.
Is grounded in the institution's or program's mission, history, and
sense of purpose.
Acknowledges and respects the autonomy and diversity of
institutions and programs.
Provides assurance to the public that accredited institutions and
programs meet or exceed established public expectations (standards) of
quality.
Is the responsibility of an external commission.
Requires faculty involvement to be valid.
Is conducted on a cyclical basis, usually 5-10 years. (Shorter
cycles are used when serious problems are noted.)
Recently has emphasized student learning and development as an
important criterion of effectiveness and quality.
More and more, accreditors are focusing their standards on outcomes
to a greater degree than inputs. Additionally, they require sound
planning, sound financial information, basic good governance
procedures, and quality academic programs. The experience following the
1992 reauthorization of the Higher Education Act showed that with the
cooperation of accrediting agencies and the Department of Education,
student loan default rates could be lowered significantly.
However, any complex arrangement of this type has areas where
improvements can be made, and I commend this Committee for looking for
those areas with this hearing. AASCU is pleased to offer some
constructive suggestions concerning the existing Higher Education Act
and regulations.
I. AREAS FOR POSSIBLE CONSTRUCTIVE CHANGE OF THE HIGHER EDUCATION ACT
Student achievement
If the statutory standard for student achievement in the HEA is
amended, it should take into account the differing missions of
institutions and the respective natures of their student bodies.
Institutions should maintain the authority to determine which measures
are appropriate for assessing student achievement in their academic
programs. One size does not fit all.
Transparency and Disclosure
AASCU supports greater transparency and disclosure in the
accreditation process. I suggest that there must be a balance struck
between the damage that could occur to institutions by disclosure of
raw accrediting reports and the public's right to know of the quality
deficiencies of institutions of higher education. The HEA could be
amended to require accreditors to prepare and make available a brief
summary of the results of any comprehensive review or significant
interim reports that led to sanctions, or could require that mandated
educational reforms required by the accreditor be made public at the
conclusion of the process. Interim accreditation reports that are
progress based should not be required to be released, since they
frequently contain inadvertent errors that may irreparably damage
institutions if made public before they are properly vetted through the
process.
Distance Education
Should Congress determine to expand eligibility for Title IV
financial aid in distance education, it should utilize accreditation to
assure quality in new programs or participants. Congress should not
mandate separate and additional standards for accreditation of such
programs, since it is the content of programs--and not the delivery
system--that is important in making judgments about such programs. In
addition, accreditors should ensure safeguards on the integrity of
degree programs and the evaluation process used.
Transfer of Credit
AASCU firmly opposes the direct involvement of the federal
government in regulating inter-institutional academic practices such as
the transfer of credit. Such issues are most appropriately handled
through the collaborative efforts of accreditors and institutions. The
attached letter from the American Association of Collegiate Registrars
and Admissions Officers to the Honorable Howard P. ``Buck'' McKeon,
Chair of the House Subcommittee on 21st Century Competitiveness, dated
December 15, 2003, accurately reflects the position of AASCU on these
issues.
II. CONCLUSION
Thus, the American Association of State Colleges and Universities
supports the current model of federal financial assistance linked to
accreditation. The current system works quite well in assuring academic
quality, loan repayment, and accountability. However, AASCU supports
targeted and specific improvements to the HEA that maintain the
appropriate balance between federal, state, and institutional
responsibilities for quality assurance. AASCU continues to believe that
voluntary regional accreditation:
Plays a crucial role in maintaining public trust and assuring
quality, but must become more transparent if it is to remain relevant
in an environment that emphasizes outcomes and seamlessness;
Is the best means to avoid governmental intervention into the
academic affairs of colleges and universities;
Has a track record of commitment to accountability;
Has enjoyed considerable success in quality assurance and
improvement; and
Assists students, employers, government, and the public by
providing reliable baseline information about the quality of
institutions and programs.
I invite you to work with us in our efforts to improve voluntary
regional accreditation. I commend you for re-examining these important
issues and allowing me the opportunity to express our views on them
today.
Prepared Statement of Judith Eaton, M.D.
Chairman Judd Gregg and Members of the Committee: On behalf of the
Council for Higher Education Accreditation (CHEA), we submit for your
written record the following testimony on accreditation and Federal
policy. We respectfully request that it be added to the printed record
for the Senate Committee on Health, Education, Labor and Pensions
(HELP) hearing held on February 26, 2004: ``Higher Education
Accreditation: How Can the System Better Ensure Quality and
Accountability?''
SUMMARY
There are four major elements to our submission:
a framework, stated in the CHEA Reauthorization Agenda,
comments on witness testimony,
responses to questions and observations from Senators, and
CHEA conclusions about the hearing.
First we provide a general framework for the committee to consider
accreditation issues in the Higher Education Act (HEA), building on a
sound system and making minor improvements to enhance accountability.
We then comment on the many observations and suggestions made by your
hearing witnesses, concurring with most and explaining our differences
with others. We comment on the observations and reply to the questions
raised by the Senators at the hearing.
We conclude by noting that the important accreditation issues were
raised and vital principles were laid on the hearing record. Minor
adjustments in HEA can improve the accreditation by further
strengthening its accountability. CHEA has proposed and supports such
changes, based on the diversity of institutional missions and the
student bodies served by our highly competitive system of higher
education. We urge that any HEA amendments on accreditation be narrowly
drawn and thoroughly vetted to avoid unintended consequences.
THE CHEA REAUTHORIZATION AGENDA
In May 2003, the CHEA Board of Directors approved a document, the
CHEA Reauthorization Agenda, with general principles to guide the
Congress as it considers revised HEA legislation. A copy of this two-
page document is enclosed. The Agenda states that voluntary peer-based
quality assurance by higher education is a sound system that serves the
public interest well, but that reforms of certain means of
accreditation could improve the accountability of the overall process.
It encourages Congress to build upon the strengths of the present
Federal relationship with accreditation and to reaffirm it as the basis
of Federal law to assure the quality of higher education institutions
and programs that receive Federal funding. It proposes expanded
commitment to accreditation in student learning outcomes, distance
education, and, additional information to the public the findings of
accreditation review, as well as a clarification of institutional
transfer of credit policies. These suggestions are made in the context
that institutions retain decision-making responsibility for their
academic policies, based on their varied missions and the diverse
student bodies they serve. We commend the CHEA Agenda to your
committee.
COMMENTS ON WITNESS TESTIMONY
The four witnesses before your committee on February 26 provided a
wide range of ideas and suggestions on HEA and accreditation. In
general, we concur with most of these views and proposals, with the
notable exceptions that we oppose the ``delinkage'' of accreditation
from Federal eligibility and we respectfully disagree with the
statement that accreditation is failing to carry out its assigned role
under HEA law.
Dr. Crow laid out the positive developments in accreditation over
the last decade and addressed specific accreditation issues under
active consideration in the Congress: learning outcomes, distance
education, disclosure and credit transfer. As Dr. Crow noted, his
suggestions address the same issues as the CHEA Agenda cited above.
However, we do not endorse his specific statutory language, believing
that additional discussion with the committee is needed to assure the
best approach on these issues.
Dr. Wallin observed that regional accreditation did a good job at
assuring basic quality, but that other efforts were needed to improve
assessment in order to address the decline of standards in liberal
learning. We, of course, associate ourselves with the statement that
accreditation is doing its job, but believe that recent and ongoing
efforts by institutions and accreditors are addressing the improved
assessment needs where appropriate. Dr. Wallin's own American Academy
for Liberal Education provides a telling example that accreditation can
address these issues in a better way where institutions seek another
approach. Like three of your witnesses, we do not encourage the Federal
Government to add greater controls on the academic work of institutions
and accreditors.
We respectfully disagree with the policy direction and specific
content of Dr. Martin's testimony, as did your other three witnesses.
We believe that he failed to provide useful and credible evidence to
support his many claims of systemic failure of accreditation. And we
oppose the idea that State and Federal regulators could replace the
thousands of peer-volunteers presently serving to improve quality at
our colleges and universities in the current accreditation system. The
unworkable idea of State controls was placed in the HEA in 1992. It was
known as ``SPRE,'' the State Postsecondary Review Entities. SPRE was
never implemented, totally discredited, and repealed by the Congress in
1998.
Dr. Potts presented a sound rationale for reaffirming the current
system and making modest adjustments to improve the accountability of
accreditation in recognition of increased public expectations. Potts
urged specific proposals put forward by AASCU, the American Association
of State Colleges and Universities. We agree with Dr. Potts' strong
statement that the attacks made by Dr. Martin do not conform to his
personal observations and experience with the National Advisory
Committee on Institutional Quality and Integrity, the Federal advisory
body on accreditation, and in the field leading accreditation visiting
teams. Our own experience and observations support these conclusions of
Dr. Potts.
RESPONSES TO SENATORS QUESTIONS AND OBSERVATIONS
The questions and comments by the Committee Members indicate a
strong interest in accreditation issues, which we welcome. In our view,
the hearing served the committee well by illuminating important
principles in the relationship of the Federal Government with
accreditation and how the present relationship established under the
HEA serves the public interest. Your hearing also focused on possible
areas of improvements in the HEA reauthorization.
Our comments begin with two points raised at the hearing by Senator
Gregg, who first observed that the question before the committee was
whether to change accreditation law in HEA a little or a lot. We
respectfully suggest that the preponderant balance of evidence from
both the witnesses and the indications of the views of Senators at the
hearing should lead your committee to conclude that small changes are
needed and that massive changes would be counterproductive. We note
that CHEA and three of the four witnesses are firmly in this camp.
Concrete suggestions have been brought to the Congress on the best ways
to do so.
The second point from Chairman Gregg regarded distance education.
Several witnesses replied that the law does not and should not add new
and separate education standards for institutions and their
accreditors. We concur. While accreditors and institutions have
developed new techniques and processes to usefully assess distance
education, the basic premise should be that standards are the same for
all delivery systems. Should the Congress choose to expand Federal
eligibility to new distance education programs, accreditation
organizations have already demonstrated their ability to provide
quality assurance.
Senator Alexander made several important statements essential to a
sound reauthorization of the HEA. We applaud his expressed wariness
toward any proposal to restrict the autonomy of institutions, because
autonomy is a key to their success. We likewise applaud his emphasis
that Federal law does and should direct accreditation to determine
``sufficient quality'' as the correctly minimal standard, in order to
receive Federal support. This understanding is vital to sustaining the
proper balance of government and voluntary activity. It allows
accreditors to do their work well and keeps them and the government out
of other areas best left to academic officials on campuses. Also, he
observed the role of the marketplace of student choices in United
States higher education and the need to sustain freedom of choice.
These are foundations of sound accountability in HEA programs.
We also agree with two other principles Senator Alexander voiced at
the hearing as very useful guidance for his Senate colleagues. He cited
grade inflation as a problem, but noted that it should be solved by
campus presidents, and not by accreditors or the government. And he
properly rejected the proposed role of States replacing accreditors as
a useful determinant of minimum quality because ``no State would
unaccredit itself.''
Senator Alexander challenged the higher education community to
offer additional ideas to improve voluntary accreditation while
maintaining its significant advantages for students, their institutions
and the public interest. We especially would like to explore the means
and the implications of his question, also raised by Senator Sessions.
How can the new HEA law encourage more choices and less monopoly in
accreditation while sustaining institutional autonomy? Several
witnesses cited some examples of competition in the present system.
CHEA hopes that we may be able to provide some ideas to the committee
that might be helpful.
In direct reply to two of Senator Alexander's questions, we share
the views expressed by the several witnesses that it would be difficult
to improve the Federal interests by expanding the Secretary's authority
over accreditation or utilizing some special Federal panel for
accreditation disputes. Either of these two approaches would likely
upset the balance among Federal and State Government authorities,
institutions and voluntary, private accreditation organizations. It
would be especially difficult to establish in law and regulation any
sound and objective criteria whereby either such authority might be
invoked.
Finally, we appreciate the observations made by Senator Clinton on
the valuable contributions and high quality of our higher education
institutions and our voluntary system of accreditation. We note
especially her agreement with Senator Alexander in her statement that
``the autonomy and independence of the higher-education system is a
precious asset.'' Senator Clinton's view that higher education and its
quality assurance serves our country well and should not be upended
sounds to us like a very useful basis for the HEA deliberations.
CONCLUSIONS
Your February 26 hearing placed on the record the important higher
education quality assurance issues facing our country. The hearing
provided a variety of views and offered numerous proposals. With one
strong exception, the hearing record urges the Congress to reaffirm the
half-century partnership of voluntary accreditation with the Federal
Government to assure that higher education institutions and programs
receiving Federal funds provide a quality education. Two Senators
stressed that autonomy in academic decisions is a key strength and a
reason for the success of higher education in our country.
Minor adjustments can improve the system to address newly-manifest
public expectations for clear accountability. CHEA has proposed and
supports such changes, so long as they are rooted in the primacy of
institutional missions and the different students served by our diverse
and highly competitive system of higher education. Given the complexity
and fragility of the vast matrix of colleges, universities and schools
supported by the HEA, we urge caution that any amendments be narrowly
drawn and thoroughly vetted to avoid unintended consequences. We repeat
our offer to serve as technical advisors to the committee in drafting
amendments, as we have the expertise and contacts with the field to
understand fully how any change in the HEA law might work in practice.
Thank you for the opportunity to provide this submission to your
hearing record.
[Whereupon, at 3:28 p.m., the committee was adjourned.]