[Senate Hearing 114-657]
[From the U.S. Government Publishing Office]
S. Hrg. 114-657
REAUTHORIZING THE HIGHER EDUCATION ACT: EVALUATING ACCREDITATION'S ROLE
IN ENSURING QUALITY
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HEARING
OF THE
COMMITTEE ON HEALTH, EDUCATION,
LABOR, AND PENSIONS
UNITED STATES SENATE
ONE HUNDRED FOURTEENTH CONGRESS
FIRST SESSION
ON
EXAMINING REAUTHORIZING THE HIGHER EDUCATION ACT, FOCUSING ON
EVALUATING ACCREDITATION'S ROLE IN ENSURING QUALITY
__________
JUNE 17, 2015
__________
Printed for the use of the Committee on Health, Education, Labor, and
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COMMITTEE ON HEALTH, EDUCATION, LABOR, AND PENSIONS
LAMAR ALEXANDER, Tennessee, Chairman
MICHAEL B. ENZI, Wyoming PATTY MURRAY, Washington
RICHARD BURR, North Carolina BARBARA A. MIKULSKI, Maryland
JOHNNY ISAKSON, Georgia BERNARD SANDERS (I), Vermont
RAND PAUL, Kentucky ROBERT P. CASEY, JR., Pennsylvania
SUSAN COLLINS, Maine AL FRANKEN, Minnesota
LISA MURKOWSKI, Alaska MICHAEL F. BENNET, Colorado
MARK KIRK, Illinois SHELDON WHITEHOUSE, Rhode Island
TIM SCOTT, South Carolina TAMMY BALDWIN, Wisconsin
ORRIN G. HATCH, Utah CHRISTOPHER S. MURPHY, Connecticut
PAT ROBERTS, Kansas ELIZABETH WARREN, Massachusetts
BILL CASSIDY, M.D., Louisiana
David P. Cleary, Republican Staff Director
Evan Schatz, Minority Staff Director
John Righter, Minority Deputy Staff Director
(ii)
C O N T E N T S
__________
STATEMENTS
WEDNESDAY, JUNE 17, 2015
Page
Committee Members
Alexander, Hon. Lamar, Chairman, Committee on Health, Education,
Labor, and Pensions, opening statement......................... 1
Murray, Hon. Patty, a U.S. Senator from the State of Washington,
opening statement.............................................. 3
Bennet, Hon. Michael F., a U.S. Senator from the State of
Colorado....................................................... 4
Franken, Hon. Al, a U.S. Senator from the State of Minnesota..... 31
Scott, Hon. Tim, a U.S. Senator from the State of South Carolina. 33
Warren, Hon. Elizabeth, a U.S. Senator from the State of
Massachusetts.................................................. 34
Murphy, Hon. Christopher, a U.S. Senator from the State of
Connecticut.................................................... 36
Casey, Hon. Robert P., Jr., a U.S. Senator from the State of
Pennsylvania................................................... 40
Whitehouse, Hon. Sheldon, a U.S. Senator from the State of Rhode
Island......................................................... 42
Witnesses
Ewell, Peter T., Ph.D., Vice President, National Center for
Higher Education Management Systems, Boulder, CO............... 5
Prepared statement........................................... 7
Pruitt, George A., Ph.D., President, Thomas Edison State College,
Trenton, NJ.................................................... 11
Prepared statement........................................... 12
Gray, Albert C., Ph.D., President and Chief Executive Officer,
Accrediting Council for Independent Colleges and Schools,
Washington, DC................................................. 16
Prepared statement........................................... 18
Neal, Anne D., President, American Council of Trustees and
Alumni, Washington, DC......................................... 21
Prepared statement........................................... 23
ADDITIONAL MATERIAL
Statements, articles, publications, letters, etc.:
ACICS, letter................................................ 49
Response to questions of Senator Murphy by:
Peter T. Ewell, Ph.D..................................... 51
George A. Pruitt, Ph.D................................... 52
Albert C. Gray, Ph.D..................................... 53
Anne D. Neal............................................. 54
(iii)
REAUTHORIZING THE HIGHER EDUCATION ACT: EVALUATING ACCREDITATION'S ROLE
IN ENSURING QUALITY
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WEDNESDAY, JUNE 17, 2015
U.S. Senate,
Committee on Health, Education, Labor, and Pensions,
Washington, DC.
The committee met, pursuant to notice, at 10:01 a.m., in
room 430, Dirksen Senate Office Building, Hon. Lamar Alexander,
chairman of the committee, presiding.
Present: Senators Alexander, Scott, Murray, Casey, Franken,
Bennet, Whitehouse, Murphy, and Warren.
Opening Statement of Senator Alexander
The Chairman. The Senate Committee on Health, Education,
Labor, and Pensions will please come to order.
This is our fifth hearing in this Congress on the
reauthorization of the Higher Education Act. Today we're going
to focus on ensuring quality in higher education and explore
the role of accreditation in doing that.
Senator Murray and I will each have an opening statement,
then we'll introduce our panel, and after the witness testimony
Senators will have 5 minutes of questions. I'll ask the
witnesses to summarize their remarks in 5 minutes. That will
give us more time to have a conversation.
We're here today to discuss how we make sure that colleges
are offering students a quality education. That's the principal
role of accreditation. Accreditation is a self-governing
process. Colleges created it in the 1800s. The organizations
they created were intended to help colleges distinguish
themselves from high school and to credit one another.
As time went along, there was no Federal involvement in
higher education or accreditation, and right around the end of
World War II only about 5 percent of the American population
had earned a college degree.
Accreditation, however, took a new role in the 1950s after
the Korean War. Congress went looking for a way to ensure the
money spent in the GI bill to help veterans go to college was
being used at legitimate, quality institutions. Congress had
enough sense to know Congress couldn't do the job of evaluating
the diversity of our colleges and universities themselves, so
they outsourced the task to accreditors.
Accreditors became, as many say, gatekeepers to Federal
funds. The Korean War GI bill of 1952 established this new
responsibility first and said veterans could only use their
benefits at colleges that were accredited by an agency
recognized by what was then called the Commissioner of
Education. After that it was the Secretary of Education.
The Higher Education Act of 1965 used this same idea when
it created Federal financial aid for non-veteran college
students. Around this time, 1965, only about 10 percent of our
population had a college degree. However, the 1992 Higher
Education Act amendments were the first time the law said much
about what standards accreditors needed to use when assessing
quality at institutions of higher education.
Today, current law outlines 10 broad standards that
federally recognized accreditors must have when reviewing
colleges. They include, among others, student achievement,
curriculum, faculty, facilities, fiscal and administrative
capacity, et cetera. Colleges and accreditors determine the
specifics of those standards, not the Department. For the
student achievement standard, for example, colleges and
universities define how they meet that standard based on their
mission. The law specifically doesn't let the Department of
Education regulate or define student achievement. In fact, in
2007, when the Department of Education tried to do that, the
Congress stopped them.
Still, Congress spends a lot of money helping students
choose colleges and attend, $33 billion for Pell Grants each
year. Congress lends over $100 billion in taxpayer loans that
students have to pay back. We have a duty to make certain we're
spending the money wisely.
I believe there are two main concerns about accreditation.
No. 1, is it helping to ensure quality? And No. 2, is the
Federal Government guilty of getting in the way of accreditors
doing their job? The Task Force on Government Regulation of
Higher Education, which was commissioned by a bipartisan group
of Senators on this committee, told us in a detailed report
that Federal rules and regulations on accreditors have turned
the process into Federal micro-management.
In addressing these two concerns, I think we should look at
five areas, and I'm going to place my comments in the record
rather than go into detail in each of the five. They are, in
summary: No. 1, are accreditors doing enough to ensure that
students are receiving a quality education? Chief academic
officers seem to all think yes. Many business leaders aren't so
sure. No. 2, would more competition and choice among
accreditors be one way to improve quality? No. 3, do Federal
rules and regulations force accreditors to spend too much time
on issues other than quality? No. 4, do accreditors have the
right tools and flexibility to deal with many different kinds
of institutions? And No. 5, should consumers and the public
generally benefit from more information about accreditation?
It's important to find a way to make accreditation work
better. I have had a hard time thinking of another way to do
this, although Ms. Neal has some interesting thoughts in her
testimony that I'm looking forward to hearing more about; that
is, to monitor quality. If the accreditors don't do it, I can
assure you the Congress can't, and Department of Education I
don't believe has the capacity or the know-how. It could hire
1,000 bureaucrats to run around the country reviewing 6,000
colleges, but you can imagine what that would look like. They
already try to rate colleges, and no one is optimistic about
those efforts. I think they will collapse of their own weight.
I'm interested in new ideas, as all the members of our
committee are, as we move toward the reauthorization of the
Higher Education Act.
Senator Murray.
Opening Statement of Senator Murray
Senator Murray. Well, thank you very much, Chairman
Alexander.
I want to thank our witnesses for being here today to talk
about how to improve quality at our Nation's colleges and
universities.
Expanding opportunities for more Americans to further their
education is, of course, an important investment for our
students' future. It's also an important investment for our
country. It will strengthen the workforce we'll need to compete
in the 21st century global economy. It will help us grow our
economy from the middle out, not just from the top down. We
should work on ways to help more students earn their degree and
gain a foothold into the middle class.
We can't deny that higher education is out of reach for too
many aspiring students. As we continue our conversations on the
Higher Education Act, I'm going to be focused on several
priorities. I want to make college more affordable and reduce
the crushing burden of student debt, because I believe all
students should have access to that learning. I want students
to have access in a safe learning environment. Strengthening
protections for students and preventing sexual violence and
assault and bullying on campus is a priority for me, as I know
it is for families across our country.
We need to make sure students from all walks of life have
strong, clear pathways into and through higher education. Our
accreditation system plays an important role in making sure
colleges and universities are providing a quality education, so
I'm glad that we have a chance today to talk about
strengthening that quality assurance.
Without accreditation, a college or university is not
eligible for Federal student aid. Accreditors, States, and the
Federal Government have a responsibility to make sure that that
gatekeeping role is working effectively. It's also important
for both students and taxpayers who expect to get a return on
their investment in higher education.
Recently we have seen far too many examples of students and
taxpayers facing the consequences of poor oversight. There is,
without a doubt, room for improvement in the current system to
better assess an institution's quality and student outcomes.
First we need to modernize the system to make sure it is
responding to the changing landscape of higher education. A new
wave of online courses and programs can occupy a gray area for
accreditors, but online programs also present new opportunities
to evaluate quality. It's time to update the accreditation
system to respond to those needs and better protect consumers.
Second, we need to promote best practices across regions
and across accreditation systems. I also recognize accreditors
have to wear many hats. They have to assess the quality of a
school and increasingly enforce compliance for several Federal
laws and regulations. That can distract accreditors from
indicators of quality, like student learning and success.
I'm open to a conversation on refocusing accreditors' role,
but that should never come at the expense of foregoing the
enforcement of important Federal protections like student
safety on campus or ensuring a college is financially sound.
The Department of Education should receive the resources it
needs to enforce that compliance.
Accreditors also need to be thinking about how to assess
quality and educational excellence, both by developing new
tools to assess national online programs and by more rigorously
evaluating student outcomes.
Third, we need more transparency and consistency from the
peer review accreditation process. There is great value in peer
review, and we've seen it work in many sectors--medicine, law,
engineering. We need stronger protections to prevent conflicts
of interest.
And finally, I applaud the recent effort by some
accreditors to strengthen the focus on student success and to
more rigorously verify the claims made by institutions. We need
more of that. Accrediting bodies have sometimes certified
colleges where there is a pattern of extraordinarily high
student loan defaults or where colleges use false job placement
information. The collapse of Corinthian College shows that we
all need to do more for students to ensure that quality is
verified, students are protected, and taxpayer dollars are well
spent.
As I said before, we need better consumer data around
student outcomes like retention, completion, and transfer
rates. That would go a long way in helping students and their
families as they shop for college options. It would also be a
powerful tool for accreditors to assess quality at a given
institution.
I'm looking forward to hearing from all of our witnesses
today on their experience and their perspective on how we can
best strengthen the accreditation system. Students, families,
and taxpayers trust accreditors to ensure colleges and
universities in our country offer a good, quality education,
and we need to make sure the system is worthy of that trust.
Thank you, Mr. Chairman.
The Chairman. Thank you, Senator Murray.
Senator Bennet, would you like to introduce our first
witness?
Statement of Senator Bennet
Senator Bennet. Thank you, Chairman. I appreciate it.
And thank you, Ranking Member, for holding this hearing.
I'm honored this morning to introduce to the panel Dr.
Peter Ewell. Dr. Ewell is the vice president of the National
Center for Higher Education Management Systems in Boulder, CO.
The center is a research and development organization that
focuses on improving management decisionmaking in higher
education.
Dr. Ewell's work focuses on institutional effectiveness in
assessing student outcomes. He's consulted with over 475
colleges and universities and more than 30 State or national
governments. Dr. Ewell has authored several books and numerous
articles on improving undergraduate instruction.
Previously, Dr. Ewell worked at Governors State University
and was on the faculty of the University of Chicago.
Thank you, Dr. Ewell, for joining us here today, and we
look forward to your testimony.
The Chairman. Thank you, Senator Bennet.
Our next witness is Dr. George Pruitt, president of Thomas
Edison State College in Trenton, NJ. He's served in this role
since 1982. He has a distinguished background, including some
time in Nashville as professor at Tennessee State. We welcome
him here.
Our next witness is Dr. Albert Gray, president and chief
executive officer of the Accrediting Council for Independent
Colleges and Schools, over 25 years of experience directing
accreditation professional and technical membership programs.
Our final witness, Ms. Anne Neal, president of the American
Council of Trustees and Alumni. Ms. Neal co-founded this
organization which has a mission of expanding academic freedom,
excellence, and accountability at colleges. Since 2007, she's
served on the National Advisory Committee on Institutional
Quality and Integrity, which has a primary purpose of advising
the U.S. Secretary of Education on accreditation.
We look forward to your testimony. We can start and go
right down the row, and if each of you could summarize your
remarks in about 5 minutes, we would appreciate it because that
would allow more time for questions.
Mr. Ewell.
STATEMENT OF PETER T. EWELL, Ph.D., VICE PRESIDENT, NATIONAL
CENTER FOR HIGHER EDUCATION MANAGEMENT SYSTEMS, BOULDER, CO
Mr. Ewell. Thank you, Senator Bennet, for that generous
introduction.
I should mention, and I should have told Senator Bennet
this as well, I worked for all seven of the regional
accreditors as a consultant in one way or another, and I've
written about this issue since the 1992 amendments that were
referenced.
My testimony is based on 11 reform proposals that I am not
going to have time to go over, but they're in the written
testimony. They are anchored in two fundamental convictions. I,
like many, I think all of us on this panel, am very concerned
that accreditation has some severe shortfalls in measuring the
job that we're asking it to do, accountability for a good deal
of Federal funds. Senator Murray, you mentioned I think the
more important thing in some respects, although money is
important, and that is ensuring the future of the country with
regard to quality degrees. I think that there are a lot of
improvements that can be made.
The second conviction I think is equally important, that I
think fixing accreditation is a whole lot more preferable to
blowing it up, than to starting again. Like you, Senator
Alexander, I can't think of a viable alternative. I've
consulted abroad for quality assurance agencies in many
countries. I assure you, they are not cheap. They are difficult
to put together from government. I don't think Congress can do
it, either. I think that what we need to do is come to a
conclusion that a number of changes around the edges can all
add up to fundamental change is the way to go.
My specific ideas are based on these 11 proposals. For the
most part, they're not new. I and others have been advancing
them since at least 1992. I think they haven't been put
together in terms of one large, coherent reform agenda that we
can pursue consciously across the board.
The proposals are independent and they're specific,
independent meaning that action on one of them does not depend
on actions on the others. We can take them one at a time. We
can do some of them and leave others for later. They can be
undertaken without a substantial infusion of Federal funds.
They are things that are not that difficult to do. I think most
important, they can be done without disturbing accreditation's
historic role since the late 19th century of improving
institutions and allowing a platform for this to happen.
I divided in the background paper these proposals into
three tiers or levels of challenge. As I say, I don't have time
to go into all of them, but I'll give you a sampling from
either end of the continuum.
Some of the most straightforward. Senator Alexander, you
mentioned public reporting. For a long time, all you could get
of the results of an accreditation was whether or not an
institution was accredited. We've made substantial progress,
and I think the accreditors are to be commended for that, now
that we have action letters and team reports as a matter of
public record in many of the regions, and so on.
I think we need to go farther than that. We need to come up
with standard reports that summarize the challenges and
strengths of institutions that are revealed as a result of the
review. That's one of them at the most straightforward end.
Another one at the straightforward end is language.
Accreditors call things a whole lot of different terms across
accrediting organizations, and they really mean the same thing
in many cases, but the public doesn't know that. We need to
come up with a language which is reasonably standard across
accreditors. Nowhere is this more important than in describing
what students have learned as a result.
Let me, because time is limited, skip directly to a couple
of things at the high end, if you will.
One of them is what's been termed a risk-sensitive approach
to accreditation. Accreditation has historically tended to
treat all institutions the same. The idea here is based upon a
track record and statistical data to say that some institutions
deserve a lighter touch than others, and that would concentrate
review attention on those that are really in trouble.
I'm running out of time, so I will stop there. I think that
these don't have to occur in any particular order. They don't
have to be according to the actor assigned. I think that in
2025, if we pursue these ideas systematically, we'll have a
much more effective system.
[The prepared statement of Dr. Ewell follows:]
Prepared Statement of Peter T. Ewell, Ph.D.
summary
The ideas that I want to share with you this morning are anchored
in two central convictions. First, I believe that the practice of
institutional accreditation currently falls far short of the model that
we as a nation should possess for a credible and consistent guarantor
of educational quality. But second, I believe strongly that fixing
accreditation is far preferable to scrapping it in favor of an unknown,
untested, and assuredly more expensive alternative operated by the
Federal Government or the States.
The substance of my testimony is organized around 11 specific
reform proposals that involve a combination of Federal efforts achieved
through legislation and the Department of Education, and changes
enacted voluntarily on the part of accrediting organizations
themselves. They include:
Public Reporting. Accreditors should develop a standard
report on the results of their reviews that lists the strengths and
challenges of each institution determined in the course of a review.
Language. Accreditors should adopt common terminology that
describes key terms, as well as the learning outcomes that they expect
of graduates of the institutions they review.
Purpose and Focus. Accreditors should not be required to
``inspect'' institutional compliance with Federal regulations and
should focus their reviews on the quality of teaching and learning.
Standard Dashboard Measures. Accreditors should develop
and adopt a standard ``dashboard'' of commonly defined institutional
performance indicators for use in the accreditation process.''
``Disciplined'' Peer Review Processes. Peer reviews used
in accreditation should be supplemented by expert review panels to
examine such areas as assessment and fiscal condition.
Conduct of Review. Visiting teams should augment
interview-based onsite evidence-gathering with methods like mini-
surveys, focus groups, audit methods, and field observation.
Role of Students. Accreditors should explore including
students on peer review teams.
Multiple Levels of Recognition. Accreditors should
establish additional tiers of recognition for institutions that perform
at exemplary or ``above standard'' levels of performance.
A ``Risk-Sensitive'' Approach. Accreditors should adopt a
review process in which the amount of scrutiny involved is proportional
to an institution's track record of past performance.
Revised Scopes for Regional Accreditors. The scopes of
regional accreditors should be revised to better distribute the number
of institutions among them and institutions should be allowed to choose
which accreditor to use.
Accreditation Governance. Congress should create a free-
standing federally chartered body like the Federal Reserve or the
Federal Trade Commission to oversee and coordinate accreditors.
These actions do not have to occur in a particular order or be
necessarily performed by the actor described. Moreover, the reforms
that they describe will most realistically occur over a long time
period, perhaps as long as 10 years. But if only a few of these
proposals are enacted, institutional accreditation for the United
States in the year 2025 will be both more efficient and more effective
in assuring quality in higher education than is currently the case.
______
Thank you Mr. Chairman and Members of the Health, Education, Labor,
and Pensions Committee for giving me the opportunity to share some of
my thoughts on how the process of institutional accreditation--our
Nation's principal quality assurance mechanism for higher education--
can be markedly improved.
I am vice president of the National Center for Higher Education
Management Systems (NCHEMS), a policy research and analysis
organization based in Boulder, CO. By way of background, I have worked
with regional accreditation for more than 30 years and have consulted
with all seven regional commissions on topics related to standards
development and the design of effective institutional review processes.
I have written numerous policy papers and monographs on accreditation
dating back to the 1992 Reauthorization of the Higher Education Act
(HEA) and served as a member of the American Council on Education's
Task Force on Accreditation in 2011-12. I most recently completed a
white paper on accreditation reform entitled Transforming Institutional
Accreditation in U.S. Higher Education that is centered on 11 specific
reforms. These reforms constitute the substance of what I want to talk
with you about today, and are directed at improving the accountability
and public information functions of institutional accreditation without
damaging its established function of improving institutional and
educational effectiveness.
The ideas that I want to share with you this morning are anchored
in two central convictions. First, I believe that the practice of
institutional accreditation currently falls far short of the model that
we as a nation should possess for a credible and consistent guarantor
of educational quality. The Federal Government, at last count, invested
$138 billion in postsecondary institutions and depends upon them to
produce graduates who have the levels of knowledge and skills needed
for the Nation to remain internationally competitive with an informed
and competent citizenry. Assuring the quality of our colleges and
universities is therefore critical. But second, I believe strongly that
fixing accreditation is far preferable to scrapping it in favor of an
unknown, untested alternative operated by the Federal Government or the
States. I have had a good deal of experience with national quality
assurance systems for higher education in other countries--principally
the United Kingdom and Australia--and I can assure you that while these
systems are of high quality, they are not cheap. Only a few of our
State oversight authorities, meanwhile, have the requisite capacity to
discharge this function; most are understaffed and undercapitalized and
would have to be beefed up considerably (again at significant public
expense) to discharge this responsibility adequately. Accreditation
currently performs the quality assurance role imperfectly, to be sure,
but at no cost to the public. It is far better to systematically
improve it than to embark upon an entirely different road.
The specific ideas that I propose are, for the most part, not new.
I, together with many others, have advanced many of them since the
Reauthorization of the HEA of 1992. But they have not, I believe, been
put forward together in the form of a concrete, long-term, action
agenda. They involve a combination of Federal efforts achieved through
legislation and the Department of Education, and changes enacted
voluntarily on the part of accrediting organizations themselves. These
proposals are independent and specific. Action or lack of action on any
one of them does not depend upon acting on any of the others. And in
each case, the proposal is quite concrete, avoiding major displacements
in the current regulatory landscape or significant changes in the roles
and responsibilities of institutions, accreditors, and Federal or State
authorities. These proposals, moreover, can be undertaken without a
huge infusion of additional resources. Finally, as I emphasized
earlier, they can be undertaken without fundamentally disturbing the
historic, and I believe largely effective, role of accreditation in
inducing quality improvement.
I have divided these reform proposals into three categories of
ascending difficulty or challenge with respect to their prospects for
enactment. Each proposal begins with a ``presenting problem''
associated with current practice that has been widely cited and needs
to be addressed. Each then consists of a series of specific actions
intended to do so.
The first set of actions is straightforward. There is widespread
agreement with them expressed through documents as diverse as the
upcoming NACIQI report on the Triad, the report of the ACE Task Force
on Accreditation, and Senator Lamar Alexander's policy paper, Higher
Education Accreditation: Concepts and Proposals. They are as follows:
Public Reporting. Until recently, accreditors did not
provide much information on the results of institutional reviews other
than whether or not the institution under review maintained its
accredited status. Such reporting has improved considerably in the past
decade and most accreditors now require institutions to report this
kind of information directly to the public. But public reporting might
be further improved through the development of standard reports listing
the strengths and challenges of each institution determined in the
course of a review, as well as through the use of standard statistical
performance indicators. Progress to date has been achieved as a result
of voluntary efforts by individual accreditors. But these efforts could
be better coordinated through collective action on the part of the
Council of Regional Accreditors (C-RAC) assisted through Federal
incentive grants for this purpose made available from the Department of
Education.
Language. There is considerable variation across
accreditors with respect to the language that they use to describe
things like the standards against which they examine institutional
condition and performance, the review processes they operate, or the
outcomes of reviews. As a result, it is difficult for outside observers
to determine whether or not different accreditors are referencing the
same things when they use different terms or are looking at different
things altogether. This problem is particularly acute with respect to
student learning outcomes. To address this, accreditors should be
encouraged by the Department of Education through NACIQI to voluntarily
adopt aligned terminology for key features of the review process and to
map or otherwise justify their learning expectations for students to
some kind of external reference point like the Essential Learning
Outcomes proposed by the Association of American Colleges and
Universities, or the Lumina Degree Qualifications Profile (DQP).
Purpose and Focus. As currently framed, accreditation is
about the quality of everything that an institution does. But this is
far too broad a set of topics for accreditors to effectively examine. A
first step here would be to cut significantly the number of items that
accreditors are currently required by regulation to ``inspect'' and
move this responsibility to the Federal Government and/or require it of
states as part of their processes of licensing institutions to operate.
Meanwhile, accreditors should place the primary focus of their quality
review processes on the effectiveness of teaching and learning. This
would mean conducting more intensive and in-depth examinations of
curricula and pedagogies, and engaging in a much more thorough look at
student learning outcomes. This renewed focus could be significantly
aided by making changes in the language of Part H, Section 496(a) (5)
(A) of the Higher Education Opportunity Act (HEOA) to emphasize
``student learning'' in addition to ``student academic achievement.'' A
final ingredient here would be to extend accreditation's reach beyond
institutions entirely to embrace the growing number of alternative
routes to earning credits and credentials such as credit by
examination, priori learning assessment, and outsourced provision in
the form of Massive Open On-line Courses (MOOCs) or StraighterLine.
Proposed actions in the second tier are more challenging, but all
four have them have been widely discussed--especially in the wake of
the Secretary's Commission on the Future of Higher Education (popularly
known as the ``Spellings Commission''). Four proposals comprise this
category:
Standard Dashboard Measures. The body of evidence
currently considered in accreditation focuses mainly on written
documents prepared by institutions and reviewed by accreditors. But
much information about institutional condition and performance can be
succinctly presented--and, more importantly, compared--in numeric form.
Accordingly, accreditors should develop and adopt a standard
``dashboard'' of 10 to 12 commonly defined statistical performance
indicators for use in the accreditation process. Because alignment is
important in such efforts, the development of these indicators should
be undertaken collectively through an organization like C-RAC. Again,
accreditors could be encouraged to develop such displays voluntarily
through incentive grants provided by the Department of Education to C-
RAC and suggestions by NACIQI.
``Disciplined'' Peer Review Processes. Peer Review is
central to the accreditation process and should certainly remain so.
But peers are good at some things and not so good at others. For
example, peer reviewers frequently lack expertise in important matters
like the assessment of student learning outcomes, the examination of
institutional financial condition, and the interpretation of complex
statistics on retention and graduation. Accordingly, peer review should
be ``disciplined'' by expert panels operating alongside the regular
accreditation process in these areas. This is largely a matter for
accreditors to undertake voluntarily, perhaps encouraged by grant
funding provided through the Department of Education. These actions can
be undertaken by accreditors individually, because alignment across
efforts is less critical than in such areas as developing a common
language or standard dashboard indicators.
Conduct of Review. Most accreditation visits rely on only
one approach to gathering evidence during their site visits to
institutions: group interviews of institutional staff by one or more
team members. But many additional evidence-gathering approaches are
available to teams, drawn from organizational consulting or the social
sciences. These include mini-surveys, focus groups, audit methods, and
field observation. Using such tools could result in a better body of
evidence on which to make accreditation decisions. As above, because
coordinated action is not necessary in this arena, such actions can be
undertaken by individual accreditors, encouraged by incentive grants
and NACIQI.
Role of Students. In contrast to quality review elsewhere
in the world, students currently play almost no role in U.S.
accreditation. Yet they sit at the heart of the teaching and learning
process at every institution. Not only could accreditation put more
focus on examining student experiences as part of a site visit,
students could also usefully be included on visiting teams and could
help accreditors develop new standards and review processes that are
focused more explicitly on the student experience. Efforts to pursue
this are best undertaken by individual accreditors, but could again be
stimulated through incentive grants and could be explicitly specified
in the language of the HEOA.
The third and final tier of proposed actions involves more basic
changes in current accreditation practices and/or the regulatory and
policy environment that surrounds them. Four proposals comprise this
category:
Multiple Levels of Recognition. Currently, accreditation
results in only one all-or-nothing outcome: an institution is either
accredited or it is not. Establishing accreditation recognition at
multiple levels would allow accreditors to recognize above-standard
performance and would provide the public with more information than the
current approach. Doing this would certainly require initiatives on the
part of individual accrediting organizations but would probably also
require language changes in the HEOA to allow institutions to be
treated differently.
A ``Risk-Sensitive'' Approach. In the name of ``equity,''
the current accreditation process treats all institutions the same.
This means that institutions with good track records get the same level
of attention from accreditors as problematic institutions. The
alternative is to adopt a ``risk sensitive'' approach in which the
amount of scrutiny directed at any given institution is proportional to
the its track record of past performance. Such an approach could render
the accreditation process far more efficient. Putting such an approach
in place, however, will require explicit changes in the language of the
HEOA to allow accreditors to treat institutions differently, as well as
voluntary adoption of such processes by accreditors themselves.
Revised Scopes for Regional Accreditors. The scopes of the
seven regional accrediting commissions vary substantially in the number
of institutions they examine. The largest has review responsibility for
more than 1,300 institutions and the smallest for fewer than 200. This
means that they are able to devote quite different amounts of attention
to any given institution in a review. An alternative way to organize
accreditation that has been proposed is by type of institution.
Unfortunately, it is hard to delineate institutional types in a way
that makes unambiguous distinctions among them. As a result, the best
proposal is probably to retain the current scopes based on geographic
region but to gradually and voluntarily redistribute the number of
institutions within each region so that there is greater balance across
commissions. This would require modifications in the scopes specified
in the HEOA to allow voluntary changes in geographic boundaries among
the regional accreditors. Additionally or alternatively, the term
``regional'' could be dropped in statute such that all accreditors have
a national scope, with institutions allowed to choose among them.
Accreditation Governance. The current governance
arrangements of accreditation make it very difficult for those involved
to speak with one voice in matters of policy. As independent membership
organizations, moreover, accreditors have a hard time--and possibly
even encounter a conflict of interest--when they must discipline their
own members. A possible reform here would be for Congress to create a
new free-standing federally chartered (but not federally owned) body to
oversee and coordinate accreditors similar to the Securities and
Exchange Commission, the Federal Trade Commission, or the Federal
Reserve Board. This could also be accomplished through Reauthorization.
These actions do not have to occur in a particular order or be
necessarily performed by the actor described. Moreover, the reforms
that they describe will most realistically happen over a long time
period, perhaps as long as 10 years. But if only a few of these
proposals are enacted, institutional accreditation for the United
States in the year 2025 will be both more efficient and more effective
in assuring quality among the Nation's colleges and universities than
is currently the case.
______
Supplemental
Thank you, Senator Alexander and members of the committee for the
opportunity to testify about accreditation reform at the Hearing last
Wednesday, June 17, and for the invitation to submit additional
testimony within 10 days. I am availing myself of that invitation today
to briefly mention a matter which I brought up at the end of my verbal
testimony. Much of the discussion during the Hearing concerned the
alleged failure of the accreditor of the troubled Corinthian Colleges--
the Accrediting Council for Independent Colleges and Schools (ACICS)--
to revoke or limit the accreditation of these institutions in the face
of what appeared to be clear evidence that they were not performing
effectively in serving their students. While it is proper for the
committee to point this out, I would like to draw your attention to a
case in which the opposite situation applies--a case in which a
recognized accreditor attempted to sanction an institution that it
found in violation of its standards, but was blocked from doing so by
threatened liability and a variety of additional legal actions. I
refer, as you may know, to the action against City College of San
Francisco by the Community and Junior College Commission of the Western
Association of Schools and Colleges.
As relatively small, free-standing membership organizations,
regional accreditors lack the resources required to sustain the kinds
of onerous lawsuits or drawn-out legal actions that can be brought
against them by the institutions that they sanction. As a result, they
can be understandably reluctant to sanction institutions in the first
place, even though they may have a good case for doing so. I am not a
lawyer, so I cannot recommend the specific actions that might be taken
to address this unfortunate condition. But I do know that it is not an
isolated situation. The answer may be indemnification of accreditors
through Federal action or a similar limitation of liability by other
actors. I merely wanted to take this opportunity to call the situation
to your attention. Accreditors might well be more willing to act as
they ought to, and as you wish them to, if mechanisms were in place to
stiffen their backbones.
The Chairman. Thank you, Dr. Ewell.
Dr. Pruitt
STATEMENT OF GEORGE A. PRUITT, Ph.D., PRESIDENT, THOMAS EDISON
STATE COLLEGE, TRENTON, NJ
Mr. Pruitt. Thank you, Mr. Chairman, members of the
committee. I serve as president of Thomas Edison State College
in New Jersey, chair of the Middle States Commission on Higher
Education, and member of the board of the Council for Higher
Education Accreditation, or CHEA. I also served for 19 years as
a member of the National Advisory Commission on Institutional
Quality and Integrity, otherwise known as NACIQI. In that
capacity, I served under five secretaries of education, under
three presidents of both parties.
I share this with you because I bring to my testimony the
perspective of someone who, as a college president, is
subjected to accreditation; as an accreditor, someone who does
accreditation; and, as the longest serving member of NACIQI,
someone who has been deeply embedded in the Federal oversight
and regulation of accreditation.
I'd like to share a series of brief summary statements I'd
be glad to elaborate on during the question and answer period.
While there are some important things to be done to make it
better, at its core reasonable accreditation is effective and
enjoys broad support from the higher education community as the
best approach for quality assurance in higher education.
Accreditation is dynamic. It is constantly changing and
evolving to respond to contemporary circumstances.
Middle States recently went through a total
reconceptualization of its accreditation standards and
processes to focus primarily on the quality of the student
learning experience and educational outcomes. This was not an
updating of the previous standards but a soup-to-nuts
rethinking of it.
At its heart, the most valuable elements of accreditation
are self-study and peer review within the context of each
institutional special mission and purpose. While metrics are
important, they are only useful when normed against peer
institutions as defined by institutional mission. Rating
systems are not indicators of institutional quality but
descriptors of student demographics. The original quality
assurance triad of State licensure, Federal oversight of
Federal programs, and quality assurance by accreditors is still
a sound model, but it has never been implemented consistently
or effectively.
The biggest impediment to the quality assurance role of
accreditation has been the accumulation of Federal regulations
that has franchised the Federal obligation to oversee Federal
programs to the accrediting bodies, thereby distorting the
quality assurance role in favor of compliance enforcement.
Educational quality assurance and compliance with
regulations governing Federal resources are two separate and
distinctive obligations and should be acknowledged as such.
Many of the complaints from institutions of higher education on
regional accreditation are, in fact, an objection to the
behaviors forced on accreditors to enforce Federal rules. As
part of the Middle State standards revisions, we have clearly
separated the quality assurance functions associated with
accreditation from the compliance work required by the Congress
and the Department of Education. We want institutions to
clearly understand the difference between the accreditation
functions we should be performing and the compliance reviews
that we are required to perform.
High-quality academic institutions can suffer periodic
lapses in their compliance obligations and academically weak
institutions can have immaculate compliance protocols. We
should not confuse the two functions. We do support a continued
link between participating in Federal programs and
accreditation simply because it is logical that participants in
Federal programs have a reasonable assurance that their
institutions meet the appropriate standards of quality and
integrity.
Accreditation occasionally gets criticized as a barrier to
innovation. There is some validity to this observation. The
impediments we faced in respect to creativity and reasonable
experimentation by our institutions is the rigidity of the
Federal regulations that do not permit us the flexibility and
the nimbleness to support innovation by our members. The
strength of American higher education lies in the diversity of
its institutions, with differential missions serving various
populations. The biggest threat to the ongoing viability of
this national treasure is the one-size-fits-all template.
Members of the triad--State licensure, Federal oversight,
and quality assurance by accreditors--can best serve our
Nation's interests by working together, cooperating,
collaborating, and communicating, but staying in our respective
lanes.
Thank you for this opportunity. I'd be glad to elaborate
further during the question and answer period.
[The prepared statement of Dr. Pruitt follows:]
Prepared Statement of George A. Pruitt, Ph.D.
summary
My testimony focuses on the role of accreditation in ensuring
quality in higher education with emphasis on what is working well.
Remarks will also identify some current issues in accreditation and
will provide suggestions for improvements that could enhance
accreditation, making it more valuable to students, the public and
policymakers.
Regional accreditation is fundamentally sound and effective, and it
enjoys broad support from the higher education community, as the best
approach for ensuring quality in higher education. It is dynamic,
evolving to meet the changing needs of contemporary circumstances. It
is focused on student learning, achievement and assessment. It provides
for regular reviews and allows for differentiation in reviews and
monitoring activities, as warranted by specific circumstances.
Signature elements of the regional accreditation process that should be
maintained include peer review, a focus on institutional improvement,
and attention to institutional mission.
While accreditation is fundamentally sound, the reauthorization
process provides a forum for considering improvements that would
increase the value of accreditation. The following accreditation issues
are identified, and suggestions for improvements are offered:
Regulations and Compliance;
Accreditation and Innovation;
Transparency/Disclosure;
``One-size-fits-all'' Templates, Metrics and Bright Lines;
The Triad; and,
The Continuum of Accreditation.
______
Mr. Chairman, members of the committee, my name is George Pruitt
and I serve as president of Thomas Edison State College in New Jersey,
chair of the Middle States Commission on Higher Education (MSCHE) and
member of the board of the Council for Higher Education Accreditation
or CHEA. I also served for 19 years as a member of the National
Advisory Commission on Institutional Quality and Integrity, otherwise
known as NACIQI. I served in that capacity under five secretaries of
education, under three presidents of both parties. I share this with
you because I bring to my testimony the perspective of someone who, as
a college president, is subjected to accreditation, as an accreditor,
someone who does accreditation, and as the longest serving member of
NACIQI, someone who has been deeply embedded in the Federal oversight
and regulation of accreditation.
This written testimony will focus on the role of accreditation in
ensuring quality in higher education with emphasis on what's working
well. My remarks will also focus on some suggestions concerning
improvements that could enhance accreditation, making it more valuable
to students, the public and policymakers.
what's working in accreditation
As noted above, I have a relatively long history of working on
accreditation for my institution and in both regional and national
organizations. I believe in it and I believe that individual
institutions and American higher education benefit from the self-study,
peer review and related processes. Further, I believe that
accreditation is a fundamentally sound system and will offer some
observations supporting this conclusion.
As Senators, the likelihood is that you most frequently
hear about accreditation from institutions that are unhappy about some
aspect of recent interactions. That is only one side of the story. The
common criticism of accreditation is that it takes too long, costs too
much, and doesn't have enough value. However, evidence from MSCHE's
accredited institutions suggests different conclusions. Unsolicited
comment from MSCHE institutions engaged in the accreditation process
continues to emphasize that accreditation is beneficial and valuable.
In the current round of reviews, one institution wrote in its response
to the evaluation team report that:
``At a time when peer accreditation is the object of intense
government skepticism and increased public scrutiny, our
experience would argue that this process can, in fact, work
effectively to hold institutions accountable for continuous
improvement in serving our students, other relevant
constituencies, and the larger society.''
Many institutions have echoed these sentiments.
All of the regional accrediting agencies, including Middle
States, continue to develop and improve accreditation. Many of the
agencies have recently been engaged in revising accreditation
expectations and standards. Middle States has just completed a thorough
reconceptualization of its standards for accreditation to focus on the
quality of the student learning experience and educational outcomes. In
the process, we have reduced the number of accreditation standards from
14 to 7. Agencies are also reviewing accreditation processes to make
them more streamlined and to emphasize analytical, evidence-based
approaches that are driven by an institution's own stated mission.
Peer review, a focus on institutional improvement, and
attention to institutional mission are signature elements of the U.S.
accreditation system that should be maintained and that promote the
diversity found in American higher education.
Peer review works. Our corps of peer evaluators and team
chairs take their work very seriously, producing thoughtful insight on
what works and what could be improved to foster quality in our member
institutions. If ever there was a ``kinder-gentler'' time when
institutions were simply given a pass by colleague-evaluators this is
not the case now.
Accreditation is not a ``once and done'' activity. MSCHE
maintains continuing contact with member institutions not only through
decennial self-study and peer evaluation, but through followup
activities as may be warranted, annual reporting, requests for
information, and through institutional submission of applications to
have substantive changes included in the scope of the institution's
accreditation. The agency comes to know its constituency well in the
course of these contacts.
Accreditors are focused on student learning, achievement,
and assessment. NILOA (the National Institute for Learning Outcomes
Assessment) has found that accreditors are the primary driver of
assessment work.
The Senate committee's white paper on Higher Education
Accreditation Concepts and Proposals addressed the usefulness of
``risk-adjusted'' or differentiated reviews. MSCHE and other regional
accreditors already recognize the usefulness of this approach in the
way that it monitors institutions. Some institutions require special
monitoring and followup, while others do not.
Accreditation reviews and actions are arrayed along a
continuum. We can have great colleges and universities that may not be
appropriately attending to some aspects of compliance with standards
and expectations, and accrediting agencies ask for followup and
improvements in these cases. We can also have smaller, special purpose
or non-traditional institutions that are found to be in excellent
health regarding accreditation standards and expectations.
The regional accreditors are working together to better
align policies and processes. Two examples of this are the 2014 Council
of Regional Accrediting Commissions statement: Regional Accreditation:
Warning, Probation, Withdrawal of Accreditation and the very recent
2015 Council of Regional Accrediting Commissions Framework for
Competency-Based Education.
The regional structure of accrediting agencies such as
MSCHE continues to be useful and should be maintained. As noted
previously, the regional structure allows for continued, meaningful
connections and enhanced knowledge about member institutions. In
addition, the 2012 American Council on Education Task Force report
addressed the issue saying that it would be better to build on the
current structure and role of regional accreditors.
We support a continued link between accreditation and
participation in Federal programs. This link allows higher education
participants and the public to have reasonable assurance that
institutions meet appropriate standards of quality and integrity.
suggestions to improve accreditation
While accreditation is fundamentally sound, it--like most things--
could be improved, and the reauthorization process provides a forum for
considering improvements that would increase the value of
accreditation. What follows is an identification of some of the current
issues in accreditation together with suggestions for addressing those
issues. In order to be effective, some of the solutions might belong in
the legislative language. However, many of the suggested solutions do
not require that level of attention, and should be accomplished through
effective partnerships within the Triad or through other non-
legislative means.
Regulations and Compliance
One of our biggest problems is the shift in which
accrediting agencies have had to devote increasing time, attention and
resources to compliance with the accumulation of Federal regulations.
This shift has come at the expense of our original mission centered on
quality and institutional improvement. The focus should be where our
expertise lies, on quality and improvement. MSCHE and some of the other
regional accrediting agencies have begun to separate traditional
quality assurance functions from compliance aspects that are required
by Congress or the Department of Education in order to clarify the
difference in these separate roles.
There are numerous instances where accrediting agencies
have been asked to take on too much responsibility for enforcing
compliance with an ever increasing list of Federal regulations.
Substantive change provides an example. Accreditors must now devote
substantial attention to all manner of large and small substantive
changes. Most regional accrediting agencies are dealing with hundreds,
and in one or two cases thousands of substantive change requests each
year. Decisions need to be made about which substantive changes are
really related to educational quality and therefore require careful
review by accrediting agencies.
There clearly does need to be a careful approval process
for accrediting agencies. However, recognition of accrediting agencies
through NACIQI has become a burdensome and bureaucratic process. Under
the Department of Education's Guidelines for Preparing/Reviewing
Petitions and Compliance Reports, accrediting agencies are subject to a
total of approximately 100 separate requirements. We are cautiously
optimistic about recent efforts to limit reviews to the most important
of the requirements and hope that the changes will become permanent. We
also believe that there has to be a better way to determine whether an
agency is worthy of recognition--perhaps one that would emphasize self-
study and improvement rather than compliance.
Accreditation and Innovation
Accreditation occasionally is criticized as a barrier to
innovation, but the most serious impediment we face with respect to
creativity and reasonable experimentation by our institutions is the
rigidity of the Federal regulations that do not permit us to be
flexible and nimble in supporting innovation by our members.
It should be our responsibility to accommodate innovation
while assuring that appropriate levels of quality are maintained. One
way to do this might be to allow accrediting agencies some form of
waiver or authority from the Department to allow for experimental
programs/innovation outside the Department's own experimental sites
programs. This could have the benefit of speeding up the process of
finding new ``best practices.''
At this point, there does not seem to be anything even
approaching consensus about how to deal with third-party providers of
education. Institutions are increasingly turning to arrangements/
partnerships with such organizations and while regional accrediting
agencies do engage as necessary, further discussion among all
constituencies and a search for agreed-upon approaches would be
beneficial to all. We need to determine whether appropriate quality
review structures are already available (e.g., regional accrediting
agencies working with institutions that accept credit offered by third-
party providers, or via organizations that allow providers to have
their courses evaluated for recommendation as to whether academic
credit should be considered by receiving institutions), or whether new
pathways to accreditation might be best.
Transparency/Disclosure
The issue of transparency or disclosure is a thorny one in
accreditation. The prospect of full disclosure of self-study documents
probably would fundamentally change the nature of those documents.
Additionally, while public institutions are used to operating in
conditions of greater public access to information, the issue
represents a special problem for private institutions. We should focus
on the purposes of disclosure--the what, how and when--before making
decisions. Perhaps the right balance is that the work product of
accreditation should remain protected while consideration should be
given to making team reports (or summaries of those reports) public.
Full disclosure of accreditation actions has been the practice at
Middle States for many years and we believe this is essential.
``One-size-fits-all'' Templates, Metrics and Bright Lines
We must recognize that a single set of bright lines or
metrics will never replace a thorough analysis by peer reviewers of
quality in higher education. We need to answer questions about whether
our institutions are doing a good job and how we know that they are,
but these questions require thoughtful use of data rather than the
application of simple metrics. We must be concerned with making
decisions about data--What data, collected how and by whom? For what
purposes?
Rather than being satisfied with a number like a
graduation rate, wouldn't it be better to determine why students either
do or don't complete programs that they start, or to consider
available/alternative data about student success? For example, for
Thomas Edison State College, a graduation rate statistic is the wrong
metric. Graduation rate statistics assume a standard progression
through higher education programs and can be more descriptive of a
traditional demographic. Alternative information such as pass rates on
professional licensure is more meaningful for my institution and the
non-traditional student population that it serves . . . and would
reveal a high level of success!
The Triad
There should be greater collaboration among the members of
the Triad. At present, there are only informal arrangements, and at
some level these have not worked well. Improvement here will be
essential in order to accommodate innovation.
Many States have decreased funding for and the
``footprint'' of governmental agencies that authorize/license
institutions of higher education. In some cases, the States have come
to rely on the work of the accrediting agencies.
Without some system or form of incentive to collaborate,
the members of the Triad will continue to operate in individual silos.
The Continuum of Accreditation
Many see the accreditation process as binary--an
institution is either accredited or not. However, there actually are a
number of gradations in accreditation decisions. Actions range from
accreditation through followup to warning, probation, show cause and
then to withdrawal. In 2014, the Council on Regional Accrediting
Commissions worked to provide a common understanding of sanctioning
actions, and it might now be a good time to broaden this discussion.
Most of our accredited institutions are judged to meet
accreditation standards, but some are clearly out of compliance with
those standards. However, there is a middle, marginal group where we
need to focus our attention to encourage improvement and quality for
the benefit of students and the public. Accrediting agencies need
flexibility and an appropriate amount of time to work with these
institutions.
The merit of an accrediting agency should never be based
on the number of instances accreditation is withdrawn. There are times
when there is nothing more an accrediting agency can do and withdrawal
of accreditation is necessary, but each time an agency is forced to
withdraw accreditation, it represents a kind of failure.
The revocation of accreditation is an incredibly
disruptive and expensive process--for the institution and its students,
and for the accrediting agency as well. In the actual event,
institutions are likely to close, merge or be sold; the accreditor is
likely to be sued; students are displaced; and, in the most disruptive
situations, the Federal Government may have to forgive significant
amounts in student loans. Once again, the accrediting agency should
have flexibility in dealing with the situation and an appropriate
amount of time to work with institutions.
Thank you for this opportunity to testify regarding Accreditation's
Role in Ensuring Quality in higher education.
The Chairman. Thank you, Dr. Pruitt.
Dr. Gray.
STATEMENT OF ALBERT C. GRAY, Ph.D., PRESIDENT AND CHIEF
EXECUTIVE OFFICER, ACCREDITING COUNCIL FOR INDEPENDENT COLLEGES
AND SCHOOLS, WASHINGTON, DC
Mr. Gray. Thank you, Chairman Alexander and Ranking Member
Murray, for the opportunity to contribute to this important and
relevant discussion regarding the reauthorization of the Higher
Education Act and reforms to the independent, voluntary system
of accreditation.
As CEO of a large national accrediting organization of
primarily degree-granting institutions in the United States, my
remarks are in the context of the quality assurance of colleges
offering professional, technical, and occupational programs
that lead to employment.
ACICS derives its authority from the U.S. Department of
Education and the Council of Higher Education Accreditation,
CHEA. We were last reviewed by the Department and CHEA in 2011.
We will again confront that process in 2016. More than 900
institutions are accredited by ACICS, serving 800,000 students
in 47 states and a dozen international locations. ACICS has
developed standards to review new and emerging educational
modes, including online instruction, international education,
and competency-based education.
As the colleges adapt new methods of serving students,
ACICS is poised to respond with flexibility and innovation. I'd
like to offer three considerations regarding the initiative to
strengthen the system of voluntary quality assurance known as
accreditation.
First, know the students. That is, understand their unique
needs and circumstances, and use that knowledge to shape higher
education policy, as ACICS uses that knowledge to shape
requirements and expectations for assuring quality and
institutional effectiveness.
Second, inventory the depth of rigor and review that is
applied through the existing quality assurance process, and
then build on those strengths to make the outcomes of
accreditation that much more valuable.
And third, encourage the accreditation community to play a
broader role in defining the measures of value incorporated in
the price/value proposition.
First, regarding knowing your students, students enrolled
at ACICS colleges are typically working adults. They're
financially independent from their parents. Some have one or
more dependents at home. Many are the first in their families
to have attempted college. More than half of them live, work,
and attend institutions located in secondary and tertiary
markets; in other words, communities with populations less than
500,000, in many cases with populations less than 150,000.
Compared with traditional students, they tend to have lower
income levels. They are looking for enrollment opportunities
that fit their lifestyles, such as close proximity, classes at
night or on weekends, classes taught by instructors with
practical as well as academic experience. They require a level
of student services that may not be commonly available at more
traditional institutions. They're looking for terminal
credentials. In other words, they want a diploma, a
certificate, or a degree that converts to employment.
ACICS is committed to the importance of a quality
educational experience for all students, and that's our value
statement. In the sense of that value statement, we consider
student services and student needs to be a critical aspect of
accreditation of our institutions.
Second, I mentioned considering the strength of existing
programs of accreditation. ACICS must demonstrate that
strength, and it has done so through standards and a program of
applying those standards that comply with the 10 categories of
the Department's regulations, which include more than 90
individual requirements, and we've mentioned and talked about
those a little bit.
ACICS, as I mentioned, must also demonstrate that it
complies with CHEA's 12 explicit standards.
I'm running out of time here. I did want to mention, third,
that ACICS importantly acknowledges the price/value
proposition. But recognize that accreditors do not prescribe,
at least ACICS, or review the affordability or pricing levels.
We don't have the purview, the expertise to do that, or,
frankly, the authority under our accreditation authority.
However, the denominator of the price/value ratio, the
value of education, is of intense interest. ACICS accreditation
represents prominence and activism regarding value. Peer review
not only ensures that the college is meeting minimum standards
when it operates at its optimum, it pushes institutions to
attain excellence.
In summary, I'd like to say that the reforms to
accreditation accomplished in reauthorization should be based
on the strong awareness of the students served by private
independent colleges and schools. They must reflect an
understanding of the existing strengths of the accreditation
program. And finally, accreditation is capable of playing a
broader role in defining and disclosing measures of value that
are to be applied to the price/value proposition.
In closing, to the degree reauthorization emphasizes the
quest for academic quality, reduction in regulatory complexity,
and avoidance of overreach by the Federal Government, it will
advance the cause for students. Thank you.
[The prepared statement of Dr. Gray follows:]
Prepared Statement of Albert C. Gray, Ph.D.
summary
Establishes the history of ACICS (since 1912), the number and types
of institutions it serves (900+, providing programs in professional,
technical and occupational fields), the number and types of students
enrolled (more than 800,000, mostly working adults, part-time students,
and other non-traditional enrollment characteristics). Reviewed and
recognized by the United States Department of Education (since 1956)
and Council of Higher Education Accreditation (CHEA).
Describes ACICS's quality assurance of innovative and emerging
education delivery modes, including distance education, international
education and competency-based education.
Offers considerations of reforms to accreditation through the
Higher Education Act, including knowledge of the students enrolled;
complete inventory of depth and rigor of current programs of
accreditation; and emphasis on quality review as a contribution to the
price/value proposition of higher education.
Acknowledges value of strengthening accreditation through emphasis
on quest for academic quality, reduction in regulatory complexity and
avoidance of overreach by the Federal Government into academic matters.
______
On behalf of the Board of ACICS, our more than 900 colleges and
schools throughout the United States and internationally, and the more
than 800,000 students enrolled, my appreciation for the opportunity to
contribute to the Senate's sincere efforts to strengthen the system of
post-secondary education in the United States through the
reauthorization of the Higher Education Act in general, and through the
thoughtful reform of the system of accreditation in particular. As the
Nation's community of learners and employers has evolved, so have the
methods for delivering effective post-secondary education; so too must
the discipline of quality assurance evolve and reform.
Founded in 1912, ACICS is the largest national accrediting
organization of degree granting institutions. ACICS is authorized to
accredit professional, technical and occupational programs through the
master's degree level by the U.S. Department of Education and Council
of Higher Education Accreditation (CHEA). ACICS has been continuously
recognized by the U.S. Government since 1956 as a reliable authority on
institutional quality and integrity.
As a recognized national accreditor, ACICS is not constrained by
geographic boundaries or territories. Currently we assure the quality
of colleges and schools in 47 States and more than a dozen
international locations. ACICS has developed standards and the capacity
to review new and emerging education delivery modes, including on-line
instruction, international education and competency-based education. As
the colleges and schools adapt new modes of serving a dynamic student
population, ACICS is poised to respond with flexibility and innovation
in the quality assurance discipline.
Today I offer three considerations to inform the legislative task
of reauthorizing the Higher Education Act and strengthening the system
of voluntary quality assurance known as accreditation:
1. Know the students, understand their unique needs and
circumstances, and use that knowledge to shape higher education policy,
as ACICS uses that knowledge to shape requirements and expectations for
assuring quality and institutional effectiveness.
2. Inventory the depth of rigor and review that is applied through
the quality assurance process and build policy that empowers and
strengthens the value of that process.
3. Encourage the accreditation community to play a broader role in
defining the measures of value incorporated in the price/value
proposition. This role is uniquely the obligation of accreditation, and
when it is played effectively, the relationship between price and value
is kept in balance.
Regarding the consideration of knowing the students: The more than
800,000 students served by the more than 900 private, independent
colleges and schools accredited by ACICS represent an important and
growing subset of the overall population of learners who enroll in
post-secondary education across the United States. They are typically
working adults, financially independent from their parents, with one or
more dependent children at home, and many are first in their families
to have attempted a post-secondary education. More than half of them
live, work and attend institutions located in secondary and tertiary
markets: communities of population less than 500,000, and in many cases
less than 150,000. (2015 ACICS Eligibility Application to CHEA).
Compared with students enrolled in traditional higher education,
students enrolled at ACICS colleges and schools tend to have lower
income levels and come from more modest means. They typically are
looking for enrollment opportunities that are compatible with their
lifestyles: campuses in close proximity offering classes at night or
weekends taught by instructors with practical as well as academic
experience in the field. They also require a level of student
services--help with transportation, day care, social services and
educational support--that may not be commonly available at other
institutions. Many will suspend their post-secondary education due to
changes in their life circumstances, such as the demands of their
family or their workplace.
Typically students enrolled at ACICS accredited colleges and
schools are seeking terminal credentials; that is, their goal is to
complete the requirements for a diploma, certificate or degree in a
timely manner, then convert the credential into employment. Due to
aspirations for higher credentials by many students, ACICS works
closely with other institutions and accreditation agencies to maximize
the opportunities for the transfer of academic credit. The CHEA
``Framework for Transfer of Credit Responsibilities'' and the ``Joint
Statement on the Transfer and Award of Credit'' are important
declarations which provide guidance to the accreditation community and
to all accredited colleges and universities.
Students attending ACICS colleges and schools rely heavily on
relationships and first-hand knowledge to make decisions about their
lives and opportunities. Word of mouth is typically the most important
method by which they gain information for making enrollment decisions:
that is, they ask their friends or relatives or other trusted sources
to recommend a post-secondary school. (``Bridges Out of Poverty:
Strategies for Professionals and Communities,'' Ruby K. Payne, Philip
E. DeVol, aha! Process, Inc. 2006)
Of the cadre of more than 1,100 peer evaluators deployed by ACICS
to perform onsite reviews, more than 130 have extensive expertise in
the field of student services. They are diligent in applying the
requirements that express the Council's expectations for serving
students appropriately, regardless of their background or circumstance
(``ACICS Accreditation Criteria,'' Sections 3-1-410 thru 414; 3-1-441,
442). At their disposal are more than 30 discrete items of inquiry that
produce information the Council can utilize in reviewing the
sufficiency of student services.
The accrediting council reviews information on a recurring basis
derived from team reports, student complaints and adverse information
from third parties to analyze the sufficiency of its standards and
requirements regarding student services. When an analysis indicates
patterns of deficiency, Council clarifies or strengthens its written
standards and enforces the expectations through the accreditation
review process.
Recently, the Council reinforced its focus on the experience of
students, including those derived from student services. The Council's
published value statement declares: ``ACICS is committed to the
importance of a quality educational experience for all students.''
The Council declaration deliberately focuses on the experience of
students, as well as the quality of the academic content; it reinforces
an emphasis on students who are currently enrolled, including the
support they receive from the institution. This emphasis reflects a
strong awareness of the type of students enrolled at member
institutions and the unique circumstances and challenges they confront
in completing a post-secondary education.
Regarding the strength of the ACICS accreditation program: As is
true for all accrediting entities recognized by the U.S. Department of
Education through the statutory authority of the Higher Education Act,
ACICS stands for review every 5 years. The agency must demonstrate that
it has standards and a program of applying those standards that comply
with the 10 categories of section 602.16 (a) of the Department's
regulations. Those regulations are comprised of 19 discrete sections
and more than 90 individual requirements.
In addition, ACICS is recognized by the Council for Higher
Education Accreditation (CHEA), which applies its expectations through
12 explicit standards and requirements. CHEA recognizes most of the
regional accrediting bodies and more than 50 programmatic and
specialized accrediting entities. ACICS has voluntarily stood for
recognition and review by the Texas Higher Education Coordinating Board
(2009); the National League for Nursing Accrediting Commission (now the
Accrediting Commission for Education in Nursing, 2009); and the
American Registry of Radiologic Technologists (ARRT, 2015). In all
cases the independent reviews produced formal recognition of ACICS's
ability to effectively assure the quality of institutions and
professions of interest to those entities.
At the core of the ACICS program of accreditation are strong,
explicit standards; a diverse and experienced cadre of peer evaluators;
and an independent, professional Council whose composition reflects
close ties to various community interests.
The 125-page ACICS standards, evolved over more than 102 years,
tend to be more explicit and prescriptive rather than general or
aspirational. Among other characteristics, the ACICS standards
emphasize student-focused outcomes, including standards for retention,
placement, and licensure exam pass rates. Institutions also are
required to demonstrate how they engage the local community in
developing and shaping their education programs; the satisfaction of
employers with the graduates they hire; the satisfaction of graduates
with the educational experience; and other indicators of student
learning, such as cumulative grade point average, graded externships,
portfolios and other capstone projects. On average, the typical ACICS
colleges will be subject to a full team review every 3 to 5 years; the
maximum grant length is 6 years, reserved for only those institutions
that demonstrate strong compliance with all standards and requirements.
In addition, institutions are required to file every year a report on
student achievement factors and financial stability.
ACICS evaluators on average have nearly 6 years' experience serving
as a peer evaluator; more than a third are drawn from colleges and
schools unaffiliated with ACICS, including many that are accredited by
regional entities. Indeed, many perform accreditation reviews for
regional accreditors as well as ACICS. The primary tools they use to
review colleges and schools onsite are the published standards and more
than 425 discrete questions that are answered through interviews,
direct observation and review of documentation.
Finally, the ACICS Council is composed of 15 individuals with
substantial experience in post-secondary education. Four of the fifteen
have no affiliation with any ACICS college or school; four have
experience primarily in faculty roles; many have served on
accreditation review teams for other accrediting bodies. All have a
strong commitment to quality assurance that enhances the experience of
students currently enrolled; the Council understands that students who
have a strong experience today or this week or this semester stand a
greater chance of completing the program and converting their
financial, intellectual and emotional investment into economic
opportunity.
ACICS acknowledges the focus on the price/value proposition of
post-secondary education in various policy arenas, and respects the
initiative behind reducing student indebtedness and the costs of
attendance. While the Council collects and analyzes information
regarding the average tuition and fees of programs at member
institutions, ACICS has not developed standards regarding affordability
or pricing levels. The numerator of the price/value proposition is
outside of our purview, our area of expertise, and the authority
granted by the U.S. Department of Education.
However, the denominator of the ratio--the value of the education
received--is of intense interest to ACICS and the broader accreditation
community. The program of quality review carried out by ACICS
represents prominence and activism regarding the value of education
delivered at member institutions. The discipline of peer review not
only ensures that the college or school is meeting minimum standards of
eligibility for participation in Federal Student aid programs; when it
operates at its optimum, accreditation pushes institutions to pursue
and attain excellence. Accreditation collects, scrutinizes and shares
the best practices of high-performing institutions with other
institutions, empowering the education enterprise to deliver greater
value and quality, irrespective of prices charged.
ACICS's accreditation program places great emphasis on the
discipline and practice of institutional effectiveness planning and
management. The scope and robustness of the plans are subject to review
by evaluators with administrative and institutional data expertise
during the recurring accreditation cycle. Data regarding retention,
placement and licensure exam pass rates are reported and reviewed on an
annual basis by the Council to ensure institutional effectiveness is
maintained or enhanced in between accreditation reviews. The aggregate
data is disclosed through the ACICS website and published in the annual
compendium of key operating statistics, so that the public,
policymakers and students may review effectiveness on their own terms.
The outcomes of the ACICS accreditation review are not provided in
comparative terms; the institution is either granted accreditation or
it is denied. The value of the review for the student is knowledge that
the quality for their investment has been assured by an independent,
third-party organization with the expertise and authority to ascertain
deficiencies and prescribe potent, immediate remedies. Enhancing the
ability of accreditation to play that role is worthy of the Higher
Education Act during congressional reauthorization.
In summary, the reforms to accreditation accomplished through the
reauthorization of the Higher Education Act should be based in part on
a strong awareness of the students served by private, independent
colleges and schools. The reforms must reflect an understanding of the
existing strengths of the accreditation program as it is applied today
to those institutions. And finally, the accreditation community is
capable of playing a broader role in defining and disclosing measures
of value that are to be applied to the price/value proposition. The
persistent, prominent presence of accreditation on college campuses,
when coupled with the quality review process, represents a unique
opportunity to advance and strengthen the balance between price and
value.
ACICS acknowledges the daunting but important task Congress faces
in strengthening accreditation through the reauthorization of the
Higher Education Act. To the degree the effort emphasizes the quest for
academic quality, reduction in regulatory complexity and avoidance of
overreach by the Federal Government into matters that are primarily
academic in nature, it will advance the cause of students currently
enrolled, and those who enroll in coming semesters.
Thank You.
The Chairman. Thank you, Dr. Gray.
Ms. Neal.
STATEMENT OF ANNE D. NEAL, PRESIDENT, AMERICAN COUNCIL OF
TRUSTEES AND ALUMNI, WASHINGTON, DC
Ms. Neal. Thank you, Mr. Chairman and members of the
committee.
The mere mention of accreditation typically evokes a
glazing over of the eyes, so I am very, very happy to all of
you for understanding that accreditation is not just an obscure
policy issue. Accreditation is a regulatory policy whose
application is having real and negative consequences in the
lives of students and taxpayers. It is self-referential,
conflicted, burdensome, and opaque. Even as we spend nearly two
times the per-student average of any industrialized country,
our graduation rates are below OECD averages.
As you reauthorize the Higher Education Act, the quality
assurance system must be strengthened to enhance academic
quality, promote competition, and provide accountability. To do
that, I submit that you must end accreditation as a gatekeeper
for title IV.
While the accreditation system has been in place, quality
has gone down, debt has gone up to record highs, and the
quality of American higher education is being questioned more
than ever before. Accreditors have done precious little to stop
this decline because accreditors are not and cannot be reliable
authorities as to the quality of education or training offered
as required by statute.
Accreditors are membership bodies funded, operated, and
made up of the very people who benefit from title IV, faculty
and administrators. Accreditors are good at encouraging self-
improvement but not so good at quality assurance and refraining
from unwarranted regulation. I cannot think of a single college
in the last 60 years that has ever been closed down solely
because of quality concerns.
Accreditation standards are guild-like, often privileging
inputs and expenditures; for example, tenured professors or
limited online learning. They give lip service to academic
freedom and a coherent general education but have allowed the
proliferation of speech codes and diffuse curricula. They
require essentially the same thing of every institution whether
high risk or low risk.
With apologies to my fellow panelists, there is no
``there'' there. Accreditation often provides no threshold
standard, especially when it comes to the non-profit
institutions. It offers no data about individual programs or
departments, no comparability in assessment of student
learning. What we have, in the words of professor Milton
Greenberg, is a confidential process that hides an
institution's advantages and disadvantages.
Accreditors insist only that colleges and universities
devise their own means of assessing their institutional
effectiveness, and tweaking the existing system will not make a
difference because accreditation will remain largely a self-
referential, membership-driven exercise.
Accreditation is also a failure because it is an opaque
process. All students are hurt when institutions do not provide
clear information about quality and financial stability, but
the negative impact is the greatest on those students who
typically have the most limited financial means and are least
familiar with how higher education works. It isn't that they
just don't graduate. It's often that they often leave with lots
of student debt and few employment prospects. This is morally
indefensible, and the blame can be placed on colleges and
accreditors.
Finally, the process is costly. Even vastly wealthy
institutions like Princeton and Stanford are complaining. It is
worse for small colleges with limited operating budgets,
particularly in these challenging times in which our colleges
and universities find themselves. A modern system of quality
assurance would deregulate, and it would provide audited,
clear, consistent, and comparable information annually about
financial stability, price, financial aid, demographics,
success, grad rates, and student learning gains to help inform
parents and students. It would not overwhelm colleges with
counter-productive and costly red tape. It would free
accrediting agencies to focus on their original mission of
self-improvement through peer review by ending one-size-fits-
all regional monopolies. At a minimum, it would give
institutions a choice and allow experimentation with different
approaches.
The American Council of Trustees and Alumni encourage you
to consider three commonsense reforms.
No. 1, create a direct, expedited recognition for title IV
using risk-adjusted scrutiny. This is a parallel track. It is
not blowing it up. It is for low-risk schools, and it would not
end accreditation.
No. 2, end regional monopolies and return to true peer
accrediting agencies.
And No. 3, eliminate the existing blank-check provision in
the statute that encourages accreditors to intrude upon
institutional governance.
America's colleges and universities have long been the
finest in the world, and we want them to remain that way. As
they seek to meet the demands of a modern workforce and
economy, it's vital that the quality assurance process
modernize as well.
I thank you for this opportunity and I look forward to
fleshing out these ideas with you.
[The prepared statement of Ms. Neal follows:]
Prepared Statement of Anne D. Neal
summary
Accreditation is a regulatory policy whose application is having
real--and NEGATIVE--consequences--in the lives of students and
taxpayers. It is self-referential, conflicted and opaque. Even as we
spend nearly two times the per student average of any industrialized
country, our graduation rates are below the OECD average. The HEA
quality assurance system must be strengthened to enhance the quality of
colleges and universities, promote competition and innovation and
provide accountability. To do that, we must end accreditation as a
gatekeeper for title IV.
While this system has been in place, quality has gone down; debt
has gone up to record highs; and the quality of American higher
education is being questioned more than ever before. This decline is
because accreditors are not and cannot be ``reliable authorities'' as
to the quality of education or training offered, as required by
statute. Accrediting bodies are membership bodies, made up of the very
people who benefit from title IV, faculty and administrators.
Standards remain guild-like, often privileging, for example,
tenured professors or mandating a limit on online learning. They give
lip service to academic freedom, a coherent general education and
student learning, but have allowed disturbing speech codes to
proliferate, diffuse curricula to abound, and enforce no minimum
quality thresholds. They require essentially the same thing of every
institution, whether high-risk or low-risk. Tweaking the existing
system will not make a difference because accreditation will remain a
self-referential, membership-driven exercise.
Accreditation is also a failure because it is an opaque process.
Students need clear information about quality and financial stability
to have the best chance for success--yet accreditation fails to provide
that information. And the process is costly. Even vastly wealthy
institutions like Princeton and Stanford are complaining. It is worse
for small colleges with limited operating budgets.
A modern system of quality assurance would: (1) Provide clear,
consistent--and comparable--information annually about price, financial
aid, demographic success and grad rates to help parents and students
make decisions; (2) Not overwhelm colleges with counterproductive and
costly red tape; (3) Free accrediting agencies to focus on their
original mission of self improvement through peer review by ending one-
size-fits-all regional monopolies; (4) Allow high-quality, innovative
forms of higher education to emerge.
We encourage you to consider three commonsense reforms to meet the
above goals.
1. Create Direct, Expedited Recognition for Title IV using Risk-
Adjusted Scrutiny.
2. End Regional Monopolies and Return to True Peer Accrediting
Agencies.
3. Eliminate the existing ``'blank check'' provision in the
statute.
America's colleges and universities are among the finest in the
world. As they seek to meet the demands of a modern workforce and
economy, it is vital that the quality assurance process modernize as
well.
______
The mere mention of accreditation typically evokes the glazing over
of eyes and a rapid escape from the room.
That is why I am so grateful to the Chairman and members of the
committee for understanding that accreditation is not just an obscure
policy issue--important only to a few insiders. Accreditation is a
regulatory policy whose application is having real--and I will argue
NEGATIVE--consequences--in the lives of students and taxpayers. We must
redesign and reform quality assurance to strengthen the quality of
colleges and universities, promote competition and innovation and
provide accountability. To do that, we must end accreditation as a
gatekeeper for title IV.
As you all know, accreditation was initially a voluntary system
helping institutions improve. Teams of faculty paid discerning visits
to institutions--generally neighbors in the region--to offer
confidential advice. It was peer review at its finest.
In making accreditation a gatekeeper, Congress believed it was
ensuring educational value by applying the successful private peer
review process to quality assurance. Other countries have educational
ministries. With accreditation, they thought, we can keep the feds out
of higher ed by having private membership bodies determine where title
IV flows. We can have our cake and eat it too.
I would submit to you: that premise was fundamentally wrong. We
have had 60 years of experience with this. While this system has been
in place, quality has gone down; debt has gone up to record highs; and
the quality of American higher education is being questioned more than
ever before. The Department of Education conducts the National
Assessment of Adult Literacy and two surveys (1992 and 2003) have shown
that a majority of college graduates cannot compare the opinions in two
editorials or compute the cost of food items when given the price per
ounce.
The groundbreaking report, Academically Adrift, by Professors
Richard Arum and Josipa Roksa similarly shows that many students at a
range of institutions--large and small, public and private, all
accredited--are graduating with little or no cognitive gain after 4 (or
more) expensive years. All the while we are spending nearly two times
the per-student average of any industrialized nation. Put simply, the
accreditation system has been a regulatory failure that deceives
students and families.
If we want to know why academic quality has gone down, it is
because accreditors are not and cannot be ``reliable authorities'' as
to the quality of education or training offered, as required by
statute. Accrediting bodies are membership bodies, made up of the very
people who benefit from title IV, faculty and administrators.
It should come as no surprise that accrediting standards remain
guild-like,\1\ often privileging, for example, tenured professors or
mandating a limit on online learning. They give lip service to academic
freedom, but have allowed disturbing speech codes to proliferate. They
give lip service to a coherent general education, but have allowed
diffuse curricula to abound. They give lip service to student learning,
but enforce no minimum quality thresholds. They require essentially the
same thing of every institution, whether high-risk or low-risk. Harvard
which has a 97 percent (6-year) graduation rate pushes the same papers
as the University of Maine-Augusta, which has a 14 percent graduation
rate in 6 years.
---------------------------------------------------------------------------
\1\ Campbell University in North Carolina was placed on probation
because its standard faculty teaching load was 15 hours per week. The
accreditors insisted that 12 hours was the maximum acceptable load, so
the school solved the problem by consolidating class sections. Instead
of the relatively small classes students had come to expect, after
accreditation, students found themselves in classes of 60 or more.
George C. Leef and Roxana D. Burris, ``Can College Accreditation Live
Up to Its Promise? '', American Council of Trustees and Alumni, July
2002, http://www.goacta.org/images/download/
can_accreditation_live_up_to_its_promise.pdf.
---------------------------------------------------------------------------
The process is costly--in terms of direct costs and opportunity
costs--deflecting institutions from innovation and self-determination
at a time when higher education needs to be nimble. Notably, even
vastly wealthy institutions like Princeton and Stanford are complaining
about the cost, intrusiveness, and burdensome nature of accreditation.
It is yet worse for small colleges with limited operating budgets.
In their six decades of existence, one can virtually count on one
hand the number of schools accreditors have closed down--and virtually
none because of academic quality. Accreditors have often told me that
they simply cannot shut down a school because it would deprive students
of Federal financial aid. The goal has been access--not academic
success. By refusing to focus rigorously on educational value,
accreditors have allowed students to take out debt when there was
little or no likelihood of graduating. Student debt now exceeds $1
trillion. Those most likely to be heavily in debt are students from
disadvantaged backgrounds.
What does a school do if it is being abused by an accreditor?
Suffer. Under current law, the accreditors have been able to carve up
the country into regions. This effective monopoly gives virtually no
choice to institutions; they are stuck, allowing accreditors to hold a
gun to their head. There are more than a few high-profile cases of
accreditors bullying universities on matters of governance and
management, far outside the realm of traditional academic peer review.
Trustees at the University of California, the University of Virginia,
and Tiffin have found themselves spending time responding to
accreditors' second-guessing of their oversight and management, when
they might more profitably have focused on instruction and student
success.\2\
---------------------------------------------------------------------------
\2\ Administrators at the University of California system, for
example, wanted to get a handle on rising administrative costs. But
when the Regents attempted to investigate and address runaway
administrative costs, they found themselves accused by accreditors of
being ``unnecessarily harsh'' with administrators. Rather than being
allowed to focus on student needs, the trustees had to expend countless
hours responding to the accreditors who were operating as nothing more
than defenders of the status quo.
When the trustees fired and then rehired a president at the
University of Virginia, they found their institution placed on warning
by accreditors because of trustees' alleged failure to consult with the
faculty. Never mind the fact that the Virginia legislature--not to
mention Thomas Jefferson--had reserved plenary authority to the board
on matters of appointment and oversight of the president. See H. Brown,
Protecting Students and Taxpayers: The Federal Government's Failed
Regulatory Approach and Steps for Reform, PP. 5-6, Sept. 2013, http://
www.goacta.org/images/download/
protecting_students_and_taxpayers_report.pdf.
When the trustees at Tiffin University decided to improve their
bottom line by providing low-income students an affordable quality
education through an online branch, they found their decision being
second-guessed by the accreditor, and ultimately shut down. The
accreditor's action has resulted in a lawsuit for tortious interference
with contract. https://www.insidehighered
.com/sites/default/server_files/files/2015-05-14%20Complaint.pdf.
---------------------------------------------------------------------------
no there there
With all due respect to my fellow panelists, when it comes to
accreditation there is no there there. Accreditation provides no
threshold standard. It offers no ranking, no data about individual
programs or departments, no comparability in assessment of student
learning. What we have, in the words of Professor Milton Greenberg, is
a ``confidential process that hides an institution's advantages and
disadvantages.''
Accreditors do not ensure a certain level of educational quality;
instead they insist that colleges and universities devise their own
means of assessing their ``institutional effectiveness.'' The statute
and regulations require accreditors to address
``success with respect to student achievement in relation to
the institution's mission, which may include different
standards for different institutions or programs, as
established by the institution . . . ''
Given this system, it is no wonder that academic quality has
declined under accreditors' watch.
Paring back the existing regulations--even insisting that they
focus only on matters that are clearly related to educational quality--
will not make a difference because the accreditation system will remain
a self-referential, membership-driven exercise.
failure to provide transparent information
Accreditation is also a failure because it is an opaque process.
Students need clear information about quality and financial stability
to have the best chance for success--yet accreditation fails to provide
that information.
All students are hurt when institutions do not provide transparent
information and do not deliver good outcomes. But the negative impact
is greatest on those students who typically have the most limited
financial means and are least familiar with how higher education works.
It isn't just that they don't graduate; it is that they often leave
with lots of student debt and few employment prospects. This is morally
indefensible, and the blame should be placed squarely on colleges and
their accreditors.
As you prepare for reauthorization of the Higher Education Act, we
encourage you carefully to examine the system of quality assurance
established by Congress to protect the use of taxpayer funds. Last
significantly changed in 1965, the current gatekeeping process--
accreditation--that provides colleges and universities access to
Federal title IV higher education student loans and grants no longer
meets the needs of higher education in 2015.
A modern system of quality assurance would:
Provide clear, consistent--and comparable--information
annually about price, financial aid, demographic success and grad rates
to help parents and students make decisions.
Not overwhelm colleges with counterproductive and costly
red tape.
Free accrediting agencies to focus on their original
mission of self improvement through peer review by ending one-size-
fits-all regional monopolies and letting them once again become
organizations of peer institutions.
Allow high-quality, innovative forms of higher education
to emerge.
We encourage you to consider three commonsense reforms to the
quality assurance mechanisms in the Higher Education Act to meet the
above goals.
1. create direct, expedited recognition for title iv using risk-
adjusted scrutiny
In an effort to protect taxpayer dollars, weed-out diploma mills
and bad actors, and reduce red tape on good actors, regulatory
resources should be focused on the highest risk institutions. Congress
should create a mechanism for colleges and universities which have a
low financial risk as currently determined by the U.S. Department of
Education's Financial Responsibility Standards to register with the
Department proof of (1) learning gains using a nationally normed
assessment and/or professional certification and licensure exams, and
(2) that they measure and accurately report price, financial aid,
graduation and student learning outcomes. Independent third-party
audits of this information would need to be submitted and the
Department could impose stiff sanctions for false reporting.\3\
---------------------------------------------------------------------------
\3\ Notably, 22 top education and civic leaders raised concerns
about the immense financial burdens of accreditation and urgently
called on Congress to consider ending accreditors' gatekeeping role.
See Governance for a New Era: A Blueprint for Higher Education
Trustees. The group was chaired by former Yale University president
Benno Schmidt and included Business Roundtable president John Engler,
Maryland Regent Thomas McMillen; former U.S. Senator and University of
Colorado president Hank Brown; former Lafayette College president
Arthur Rothkopf; and former University of Northern Arizona president
Clara Lovett. http://www.goacta.org/images/download/
governance_for_a_new_era.pdf.
---------------------------------------------------------------------------
Upon registration, the Department would expeditiously certify
eligible institutions as recognized by the Secretary for purposes of
receiving title IV funding.
This Direct, Expedited Recognition process is analogous to
companies which file for an IPO with the SEC--they make public key,
audited information and then are free to conduct their business. This
would be an option only for low-risk institutions using financial
scrutiny already performed by the Department. It would require a modest
certification fee, thus needing no new taxpayer funds for the
Department to administer.
Utilizing risk-adjusted scrutiny would allow the Department and
accrediting agencies to spend more time on bad actors while placing
lighter burdens on high quality institutions which would no longer need
to go through the lengthy and cumbersome traditional accrediting
process in order to be eligible for title IV funding. This system would
NOT result in more direct Federal involvement. Accreditors would not be
second guessing mission. There would be no Federal requirements about
standardization of student learning outcomes and assessment.
In this system, schools could have different standards and
different programs. They would voluntarily provide basic information
about grad rates, retention rates, repayment rates and employment. New
institutions with limited financial resources could, in turn, provide
protection by posting a surety bond.
In this system, proof of educational value would release title IV
funds.
Would this disadvantage schools with underserved populations? No.
It would actually elevate those that are doing a good job. The
nationally normed tests like CLA, CAAP, and Proficiency Profile are
based on the cohort of students served. In other words, these tests
take the students where they find them. This would not be a one-size-
fits all solution, not a single kind of exam, like NCLB. Institutions
using other forms of nationally normed assessments (including trade
certifications) could also present those results in fulfillment of this
requirement.
Accreditation could be continued, even mandated--but not as a
gatekeeper for Federal funds.
2. end regional monopolies and return to true peer accrediting agencies
Accreditors do not sell their services in competition with other
firms. Rather, for the vast majority of colleges and universities, six
regional accreditors operate as monopolies, overseeing nearly every
school in their region--from the local design school to a top five
world-renowned research university. This creates incentives to adopt
standards and processes that focus on the lowest common denominator and
may be meaningless in many contexts. The American Council of Education
(ACE) convened a taskforce from colleges and accrediting bodies that
concluded: ``the current regional basis of accreditation is probably
not the way America would structure the system if starting from
scratch.''
Congress should eliminate any explicit or implicit anti-trust
protection from accrediting agencies that allows them to carve up the
country into monopolistic regions. Congress should explicitly direct
the Secretary of Education only to recognize for title IV gatekeeping
purposes accrediting agencies that either are very specialized--i.e.,
serving a specific type of institution such as community colleges or a
very narrow geography (such as one State like the New York Board of
Regents already does) or operate nationally. Finally, Congress should
eliminate from statute any requirement that an institution wishing to
join a new accreditation organization must first notify and/or get
approval from the Department or Secretary.
Ending regional monopolies will encourage more innovation among
accrediting agencies and free colleges and universities from being
stuck with an agency that may be ineffective, overly costly and
unresponsive.
Accreditors could develop important differentiation (i.e., liberal
arts, research) and perhaps even a highly sought-after top-level
certification for outstanding schools. Look at LEED Certification in
architecture--gold, platinum and silver--it is a perfect example of a
private system that sets a real marker of quality!
3. eliminate the existing ``blank check'' provision in the statute
The existing Higher Education Act limits the Secretary of
Education's authority to establish criteria for accreditation agencies
outside the scope of statute, but it provides that accreditors may
adopt additional standards outside the realm of the statute. This
``blank check'' provision has effectively permitted private nonprofit
entities to interfere in governance and management matters--raising
serious Constitutional concerns. The elimination of this provision
would ensure that accreditors are focused on matters of academic
quality, which are properly and historically the focus of peer review.
America's colleges and universities are among the finest in the
world. As they seek to meet the demands of a modern workforce and
economy, the sweeping changes technology is bringing to learning and
pedagogy, and changing demographics of students, it is vital that the
quality assurance process modernize with them as well.
Thank you.
The Chairman. Thank you, Ms. Neal.
Thanks to all the panelists.
We'll now begin a series of 5-minute rounds of questions.
We'll begin with Senator Murray.
Senator Murray. Thank you very much, Mr. Chairman.
Dr. Ewell, let me start with you. Accreditors play a very
critical role as the gatekeepers for $150 billion in Federal
financial aid that is distributed every year. But, as I'm sure
many of you are aware, last year a GAO analysis found that
colleges and universities with weaker student outcomes were no
more likely to have been sanctioned by accreditors than schools
with stronger student outcomes. That means that the schools
that aren't serving students as well are just as likely to be
accredited as those that are, and the GAO report said that the
Department of Education doesn't consistently use sanction
information for oversight.
It seems clear that quality assurance needs some kind of
improvement. What do you think the Federal Government's role is
in improving the accreditation process and making sure it works
for our students and our institutions and our taxpayers?
Mr. Ewell. Well, I think that the GAO report does make an
awful lot of very good points, most of which I agree with. The
things that I'm proposing are intended to tighten the system a
good deal. In fact, I agree with my colleague, Anne Neal, on a
number of the proposals that she's making of introducing more
competition among accreditors so that institutions have a bit
more choice in what they go after, a lot more in terms of
statistical reporting, as has been put forward. We know how to
measure things a lot better now than we did 50 years ago.
We need some triggers, and the accreditors are beginning to
hear that message. The HLC, the Higher Learning Commission of
the North Central Association, recently put in a number of
threshold criteria for talking to institutions. They don't say
you don't get accredited if you fall below this threshold, but
we certainly notice you, and you are going to have to answer a
whole lot more questions.
Let me also address the--I like to call it the ``blood on
the floor'' issue, that there aren't that many institutions
that don't get accredited. First of all, I think that there
should be more, and statistical criteria would help inform
that. I think what is often overlooked in accreditation is the
candidacy process, that many institutions do fail candidacy
when they come forward, and they are essentially asked not to
apply. It's essentially like saying the flunk-out rate at
Harvard is very, very low, but not very many people get in.
I think that you have to look at both sides of it.
Senator Murray. I understand, OK.
Dr. Pruitt, student success is really important to me and
to many members here. Some accreditors, like the one you chair,
recently revised their standards to place a new focus on
educational quality. Others are launching efforts to better
track student outcomes. I think those are great steps, but it
seems like we need to be doing more.
What actions are your organization planning to take in the
future to do a better job of measuring student outcomes?
Mr. Pruitt. Well, I wish the metrics were simple, and some
of the discussions imply that they are. A problem is what are
the metrics and what should the metrics be? They aren't as
simple as the public thinks they are. Something like attrition
and retention, retention assumes that there's a normative
pattern of progress, and most people assume retention means
that you enroll as a freshman, you go 4 years later and you
graduate. That's true for about 40 percent of the students in
American higher education.
How do you measure attrition and retention when you have
most of the students in America going part-time? The last time
I looked at it, the average time to graduation for a part-time
student was about 9 years.
I made a comment earlier that the data tends to reflect a
descriptor of the demographics of the student body and not
measures of quality. There are some measures of quality that
you can kind of count on. If there's a licensure exam for a
program that a student is taking, a student should assume that
if they graduate from an accredited institution, it should be
assumed that they're going to pass their State licensure exam.
If they can't, that's a problem.
Those are some fairly good indicators. Graduate school
acceptance rates, self-evaluations. Our students have very
strong consumer views. They're very good at telling us what
does work for them and what doesn't work for them. The fact of
the matter is, we have a lot of data about whether the students
feel that the money was worth it, that the experience was worth
it, and it's pretty celebratory.
I'm not trying to duck the question, but the problem is
that we need more differentiated metrics that are more focused
on the particular demographics of the students and the mission
of the institution, and there is going to be variation on that,
and we have to learn to be comfortable with that variation. It
can't be a byline indicator.
Senator Murray. I'm out of time, so I'm sorry to cut you
off. I do have additional questions I'll submit for the record,
and I really appreciate the accommodation, Mr. Chairman.
The Chairman. Thank you, Senator Murray.
Your testimonies are full of interesting ideas, so I'm just
going to ask three questions and give the four of you a chance
to answer all three and hope that we'll keep it within about 5
minutes. They come from your own recommendations.
The first is treating some of our 6,000 institutions
differently than others. Dr. Ewell, you called it a lighter
touch. Ms. Neal, I believe that's what you mean when you talk
about the direct recognition by the Department.
What's the best way to treat some institutions differently
than others?
Second, why should there be regional accrediting agencies?
Why shouldn't they all be national or specialized according to
the specific functions? That's a recommendation several of you
made.
And third, what about the Federal regulation that our
commission told us was micro-managing accreditation that, Dr.
Pruitt, you talked about and several of you mentioned, that
Congress got into the business 20 years ago of saying, do all
these things, and suddenly you're involved in a lot of things
other than quality? What about that?
When it gets to you, Ms. Neal, I hope you'll say a word
about whether your direct recognition wouldn't just give the
Department a license to start becoming what we call in K-12 a
national school board and start trying to tell Harvard what to
do about everything in exchange for. That's what it typically
does when given an opportunity.
Let's go to Dr. Ewell down to Ms. Neal.
Mr. Ewell. OK. Very briefly, the risk-based kind of
accreditation, the determination of a lighter touch can be made
basically on two criteria. The first criteria is a trouble-free
history of interaction with the Federal Government and other
regulators. Essentially, they stayed within the law, there
isn't a lot of controversy and so on.
Another one of my proposals which echoes another one of
Anne Neal's proposals is a much better set of statistical
indicators. Institutions that have very good graduation rates,
that have good graduate school placement rates, that have good
licensure passage rates, et cetera, et cetera, that would be
consideration as well.
I will mention there is a risk associated with a risk base,
and it's illustrated by the University of North Carolina's
recent scandal. You can really have a fine track record and
still go off the rails.
The Chairman. I'll have to ask you all to summarize a
little bit or we'll be way over time.
Mr. Ewell. OK. I am very intrigued by the sector-based
accreditation instead of regional. I just can't figure out how
to draw the boundaries of it. We've talked about this since
1992. The regional concept is clearly, in a certain sense, dead
because we have global and online education. I can't think of a
better way to do it because it's very, very hard to draw the
sectorial lines. If somebody can show me how to do it, I could
support that.
In terms of the Federal regulations, no contest. I
certainly believe that accreditors are not at all equipped to
inspect Federal regulations. It distracts them from their main
purpose. I think that there are other ways to get that done.
The Chairman. Dr. Pruitt.
Mr. Pruitt. Quickly, risk-based accreditation is a good
idea. We should have the flexibility to treat institutions
differently based on their strengths. We have to monitor all of
them, and there's certain kinds of baseline data we get,
particularly the financial stuff. We get audited reports;
that's easy to track. But, yes, we should have differential
accreditation based on the strength of the institution and the
aspirations of the institutions. Remember, this was created by
institutions because we wanted to be reviewed by our colleagues
and peers, so I believe in that.
The reason why we need regionals, there are real
differences in the regions. Accrediting associations, yes, they
are membership organizations, but they are also learning
communities, and most learning communities vary around the
country. Institutions like mine were all pretty much created in
the Middle States region; it's no accident. They couldn't have
existed in the southern association because at that time the
regimens and the culture of the southern associations was
different. Our kinds of institutions are throughout the
regions. Otherwise it would be too big, too. You need a size
where you can have a community and work through problems.
The final one about the regulations, I can't say enough.
They are strangling what's made this system great. We need to
simplify, deregulate, and decentralize.
The Chairman. Thank you.
Dr. Gray.
Mr. Gray. Thank you. I'll be brief.
With respect to risk-based accreditation, ACICS already has
a risk-based model in the sense that we've based the length of
our accreditation cycle on the confidence that our council has
in the institution that we're accrediting. Accreditation cycles
can vary from as little as 2 years to as much as 6 years, again
depending on the confidence that the council has during the
review process.
Second, on the issue--and also, I might add, higher-risk
institutions are visited more frequently and monitored more
closely for a number of parameters than those that we consider
to be of lower risk.
Second, no comment on the regional issue because we're a
national accreditor. We are not regional. We cover, as I
mentioned in my testimony, the entire United States, as well as
a dozen foreign countries.
With respect to Federal regulation, we have said on the
record--you have it in our written testimony--that the Federal
overreach is a problem for accreditation and maintaining
quality assurance, and we think it has to be reduced.
The Chairman. Thank you.
Ms. Neal, I'm a little over, but I want you to take time to
answer the question.
Ms. Neal. Thank you. As we look at the lower-risk approach,
this is going to be available to anyone. Essentially, any
institution that can show that it's financially stable, that
it's willing to offer various metrics in terms of demographic
success, graduation rates, retention rates, and can also show
student learning gains, this would be available to any
institution. It doesn't privilege a Princeton, it doesn't
privilege a Stanford. It actually will help elevate those
schools that are doing a good job of offering educational
value. It could be deemed a parallel track so that the existing
system could remain for those that need greater attention.
In terms of the regionals, quite frankly, I think the
regional accrediting bodies are nothing less than cartels.
We've allowed these bodies to carve up the United States and to
basically have a captive market of those schools that are in
their region. I think when we're looking at global higher
education today, it makes no sense to have regional restricted
bodies. In fact, many of them are busy accrediting
international entities and others. Even in their own
operations, they don't view themselves as regional.
Your last question in terms of would this direct approach
where institutions would provide information and ensure
financial stability mean that the Feds would become more
intrusive and more involved, I would submit to you that it
would be less. Accreditors in this regime would not be second-
guessing mission, as they do now. There would be no Federal
requirements about standardization of student learning outcomes
and assessment. In fact, what we would do is free up the
schools to have their different standards and to have their
different programs, and they would voluntarily provide basic
information about how they are doing and whether or not they
are adding value in terms of student learning gains.
I think that this actually frees up the institutions to
pursue their own interests and to reach educational quality in
their own ways, as opposed to having an external body that is
empowered by the Federal Government as a gatekeeper to push
them in ways they may or may not want to follow.
The Chairman. OK. Thank you, and thanks to my colleagues. I
thought that testimony would be interesting to all the
Senators.
I have Senator Franken next, Senator Scott, Senator Warren,
Senator Murphy, Senator Bennet.
Statement of Senator Franken
Senator Franken. Thank you, Mr. Chairman. Thank you.
Dr. Gray, ACICS, your organization, was one of the
organizations that accredited many of the Corinthian College
campuses. Corinthian recently filed for bankruptcy and closed
many of its campuses. This has left over 16,000 students
without a degree and with a ton of debt. I know there are a lot
of different factors that caused the downfall of Corinthian,
but I want to just focus on the accreditation piece here, and
I'd like to get Ms. Neal's thoughts on this as well because,
Ms. Neal, you said that in--I don't know what it was--60 years,
not one school has been closed because of quality.
Dr. Gray, in your role as an accreditor, what could you
have done to prevent the closing of the Corinthian campuses or
prevent it from putting the students in this position? Ms.
Neal, is this symptomatic of something?
Mr. Gray. Thank you, Senator Franken. As an accreditor, we
were working with Corinthian for years. You mentioned we
accredited roughly 55 Corinthian campuses, and they varied in
terms of what's been characterized as risk here, from
outstanding performers, medium performers, and in some cases we
were monitoring them because we were concerned about their
outcomes. None of those campuses, at the time that the change
occurred, was mandated by the Department--the change of
ownership, were actually out of compliance with accreditation
criteria. In fact, student satisfaction surveys were high.
Students were indicating high satisfaction with their
experience in terms of educational outcomes with the Corinthian
campuses.
In the final analysis, Corinthian had some 120,000
students. There are currently 90,000 students whose education
at Corinthian was not interrupted by the process. The process
was not really a closing down, as you know, of Corinthian. It
was a change of ownership of Corinthian from a for-profit
institution to Zenith Corporation, which is a non-profit
institution that now operates virtually all of the Corinthian
campuses without interruption to students, with the exception
of California.
Senator Franken. That is not the case, and there are
students who are being left in the lurch there. I've talked to
Zenith, and they acknowledge that, and they are going to be
trying to make sure they do everything they can to give them
some options. That's not the case----
Mr. Gray. Well, they are giving them options, options to
continue their education or to get refunds. My understanding is
that's the case.
Senator Franken [continuing]. The education may be
providing them.
Ms. Neal.
Ms. Neal. I would have to agree that, as best I could tell,
looking at the problems there, at the State level you had some
allegations of fraud. I think the fundamental issues were
financial, cash-flow issues. Actually, I believe that the
direct expedited recognition for title IV might actually more
adequately address these kinds of concerns because we need to
be looking at the financial status of these institutions and
see how they're doing. That was I think what fundamentally
occurred there.
Senator Franken. Weren't there courses that students would
take and they wouldn't be able to get a job after? It was
presented to them that they could get a job after? We've heard
testimony in this committee of people who go through these
courses and at the end of the day they were misled on what jobs
they could get and were left with debt and no job prospects.
Ms. Neal. I think that's certainly the case. That may very
well be a consumer fraud issue that can be best addressed at
the State level. Certainly, students that go to for-profits are
not the only ones who get out of college and sometimes do not
get a job. I think that's why----
Senator Franken. Yes. If you're told that this is
accredited to do sonograms, and then at the end of that no one
who hires for sonogram technicians will hire you, that seems to
be a little different than someone who graduates in the liberal
arts and doesn't get a job right away because they don't
necessarily have a degree that applies to an open job. Isn't
there a different there? Isn't that a very big difference?
Ms. Neal. I think there are a number of nuances there. I
think the important thing is to be able to ensure the student,
as well as the taxpayer, that institutions are financially
sound, that they are not basically committing fraud, and in
this instance I don't believe accreditors can be expected to
catch fraud. If you have a situation of a cash-flow problem and
basically not enough money, which I think was the case here,
that can be addressed by looking more at the financial
situation than looking necessarily at the academic quality.
Mr. Gray. Senator, can I make one more comment? Because you
asked about the role of accreditation. One thing I did want to
point out is that ACICS, part of our accreditation role is to
monitor this change of ownership and see that the 90,000
students who are continuing through the Zenith process, that
that change in ownership properly assures the quality of
education and the outcomes are achieved. We have a process of
reviewing the capabilities of the new owners, as well as a 6-
month quality assurance review of every campus under the new
system to assure that what's in place is a quality educational
experience.
Senator Franken. I'm way over my time. I think that when
you're accrediting an institution, there should be some look as
to whether they're committing fraud in telling their students
what their courses are about and they are, in fact, leading to
any kind of licensure or meaningful accreditation that gets
them a job.
Mr. Gray. I believe we do that.
The Chairman. Thank you, Senator Franken.
Senator Scott.
Statement of Senator Scott
Senator Scott. Thank you, Mr. Chairman.
Dr. Ewell, I know that in South Carolina the primary
accrediting agency is SACS, the Southern Association of
Colleges and Schools, and they have as their motto ``Students
are critical to success.'' I noted that in your testimony you
mentioned several times where you are in agreement with Senator
Alexander's options for reform.
Can you speak for a few minutes on how do we reform
accreditation so that it provides students better opportunities
to succeed?
Mr. Ewell. Well, actually, one very simple idea is to
include students in the accreditation process. That's done in
Europe. It's not done here. They are the primary beneficiaries
of the process. I think they would have intelligent things to
say on review teams, and so on.
I think the transparency issue is huge there. I mean,
accreditation, whether it likes to admit it or not, does play a
very strong public information role, and I think that a lot of
the more recent moves that accreditors have made to open the
process up are important in that regard as well.
One of my ideas is also--and it's not just mine, others
have advocated it--is having multiple levels of accreditation.
You can get accreditation with distinction, or accreditation
like an A, B, C, D kind of grade. Again, that would provide
students and other members of the public with better
information with which to make a choice. I think it's a crucial
role for accreditors, and it's not being very well fulfilled
now.
Senator Scott. Yes. Thank you.
Dr. Gray, I think Senator Franken was alluding to my
question in some form or fashion. From your perspective, where
does accreditation fit into the question of how institutions
will be most able to prepare workers for the jobs of the
future? The innovations we've seen over the last two decades
have changed almost every sector of our economy, yet the
accreditation system does not seem to have the right incentives
in place to adapt. How do we harness competency-based programs
and leverage accreditation so that our future innovators,
entrepreneurs, and leaders enter the workforce with the high-
quality education they need to compete in our global
marketplace?
Mr. Gray. Well, I think that we need to be flexible and we
need to work with our institutions and the Department in
incorporating innovative educational modalities and techniques.
I see us doing that. I think competency-based education, where
we and other accreditors have recently again worked with the
Department of Education to develop standards that allow
institutions to adopt programs of competency-based education,
is a start. We need to build on that. We need to do a lot more
of that. We need to keep in mind when we're designing programs,
just as you've mentioned, that those programs that we approve
have to be programs that give employers what they need and for
the workforce to benefit from the skills that students learn in
these institutions.
The other thing that accreditors do is work closely with
employers. We research the employment world. We interview
employers directly about their satisfaction with our students,
determining where the shortcomings might be so that schools
know how to redesign their programs to meet those areas where
employers feel there needs to be greater strength.
Basically better communication with the employers, working
with the Department to get programs that are innovative
approved and approvable are really the best ways that we can be
responsive to the needs of the workforce. I think that career
education schools, schools that we accredit, are the most
responsive right now to the needs of the workforce, the most
directly responsive.
Senator Scott. Thank you.
Thank you, Mr. Chairman.
The Chairman. Thank you, Senator Scott.
Senator Warren.
Statement of Senator Warren
Senator Warren. Thank you, Mr. Chairman.
Dr. Gray, as Senator Franken noted, your agency was
responsible for accreditation for the campuses of Corinthian
College, this for-profit outfit that recently closed down.
Before it filed for bankruptcy, Corinthian was under
investigation by 20 State attorneys general. Three AG's had
filed lawsuits, as did the Consumer Financial Protection
Bureau, all alleging that Corinthian lied to its students and
defrauded them to get them to enroll. While this was all going
on, you renewed accreditation for seven campuses in 2013, and
right up to the bitter end you continued accreditation for
others, keeping them eligible for Federal money, helping them
draw in more and more students.
IIT, another for-profit college chain, is still accredited
by your agency. Currently, IIT is being sued by two Federal
agencies and one State AG for deceptive practices, and it is
currently under investigation by 18 other State attorneys
general. Yet, your outfit continues their accreditation,
keeping them eligible for Federal money and helping them draw
in more students.
So, here's my question. How many Federal and State agencies
need to file lawsuits against one of your colleges before your
organization takes a second look at whether that school should
be eligible for accreditation and, most importantly, for
Federal money?
Mr. Gray. I don't think that the number of agencies that
have an investigation or some type of action going on with one
of our institutions is the issue that determines where they
stand with us in terms of accreditation.
Senator Warren. You may not think the number is important,
but we know that you didn't do it when you had 20 attorneys
general and a Federal agency. I just want to know how much you
have to go through.
Mr. Gray. Thank you, Senator Warren. As you can imagine,
that's of great concern to us.
We have a process. We have what we call an adverse file
process. Every time any kind of an action by a State or a
Federal agency is entered against one of our schools, we track
that very carefully. Obviously, we get a response from the
institution as to where they stand with respect to that
allegation, and we track it very carefully. We have our own
methods of investigating whether or not there's compliance with
our criteria.
Senator Warren. OK. You were aware of the fact that all of
these investigations and lawsuits had been filed. You were
tracking it, and yet you continued to accredit these outfits.
Mr. Gray. We, as an accrediting agency, have an obligation
and do have our own methods of investigation.
Senator Warren. I'm sorry. Do your methods include if
students have been lied to and defrauded by one of your
colleges, that that might somehow count as a negative in the
accrediting process?
Mr. Gray. Absolutely. We have criteria covering
institutional integrity that we diligently----
Senator Warren. Then how did these institutions continue
with their accreditation? You accredited them right up to the
minute they closed.
Mr. Gray. We accredit them as long as they comply with our
accreditation criteria. Allegations----
Senator Warren. Your accreditation criteria include whether
or not they lied to their students.
Mr. Gray. All of these investigations that you've mentioned
are just that, they're investigations. Without outcomes from
the investigations, we don't have evidence to take any kind of
action. The only evidence we have is what we get from our own
investigation.
Senator Warren. Do you think there was no evidence that
Corinthian colleges lied to their students? Is that what you're
saying, that you independently investigated and you came to the
conclusion that they did not lie, that they did not defraud
their students, that the Department of Education now has this
wrong?
Mr. Gray. We consistently, not occasionally but
consistently, during the accreditation process, review
compliance with our criteria, including representation and/or
misrepresentation to students. We come to the conclusion that--
--
Senator Warren. How did you arrive at the conclusion that
they could be accredited if you say you take into account
whether or not they've lied to their students?
Mr. Gray. Well, I think you have to understand the
accreditation process.
Senator Warren. Yes, I'm trying to do that.
Mr. Gray. OK, I'll try to explain it. We hear allegations.
We investigate those allegations. If there is substance in
those allegations, we sanction the institution. If the
seriousness of the allegations is sufficient, we put the
institution on probation. If it's more serious than that, we
withdraw--and the record shows we have----
Senator Warren. I'm sorry, Dr. Gray. I'm still stuck, then,
at the point, are you telling me that you found no evidence
that Corinthian lied to its students and defrauded them?
Mr. Gray. I will say we found no evidence that they lied to
their students or defrauded them. We do have evidence, as I
mentioned, that for some campuses they were not up to our
standards, and those campuses were on monitoring, were on----
Senator Warren. But you're monitoring them----
Mr. Gray. Or sanction.
Senator Warren [continuing]. And they continue to be
eligible for Federal funds. For years, there have been concerns
about Corinthian colleges. There were exposes, investigations,
lawsuits, and yet the accrediting agencies continued to look
the other way. Corinthian enrolled more and more and more
students. It sucked down more and more and more Federal aid,
while private accrediting organizations collected more and more
fees. Students and taxpayers are stuck with the bill, while
there is no accountability for the private accrediting outfits.
I do not understand why they should be allowed to collect their
fees and just walk away.
If accrediting agencies aren't willing to stand up against
colleges that are breaking the law, colleges that are cheating
their students, then I don't know what good they do, and I sure
don't know why we would let them determine which colleges are
eligible for Federal dollars.
Mr. Gray. I can only say that our council makes its
decisions based on facts, not allegations, and all the
decisions they made, if you look at the record, where there is
sufficient information that indicates sanctions or
accreditation should be withdrawn, that action has been taken.
The integrity of the council in that respect has been beyond
reproach.
Senator Warren. Thank you, Mr. Chairman.
The Chairman. We're going to move on now. Thank you,
Senator Warren.
Senator Murphy.
Statement of Senator Murphy
Senator Murphy. Thank you very much, Mr. Chairman.
God knows that we are at the top of the list of those that
are loathe to admit mistakes, but you'd be better off to admit
that this was a mistake. There would be much more faith in the
accreditation process if you would just own up to the fact that
Corinthian failed its students by every measurement. They
failed their students financially. They are out of business
today. They failed their students on an educational basis. Many
of their campuses had 30 percent of students, if not more, that
couldn't repay their loans. The prices for their degrees were
often 10 times that of neighboring institutions. Former
employees say that, ``We were working for the biggest scam
company in the world.'' The Department of Education says that
Corinthian violated students' and taxpayers' trust.
I don't know, I just think you'd be better off to say we
missed this one. Corinthian is out of business. They're under
investigation and in active litigation with every other agency
that looks out for students' interests. This was a bad call. If
you're not willing to pull Corinthian's accreditation, or at
least admit that you should have, then it's not clear whose
accreditation you would ever pull, because I think every other
institution within the Federal higher education hierarchy has
determined that these guys were the worst of the worst.
Mr. Gray. OK. I'd be the first to admit that accreditors,
like any other organization, made mistakes. This was not one of
those mistakes.
Corinthian collapsed, if you want to use that term, because
of financial pressure, not because of non-compliance with any
regulation, OK? It was financial pressure. Corinthian's
campuses, the institutions that are educating students, all but
in California and two in New York, exist in full operation
today without interruption. Those same students in those same
campuses being taught by those same faculty under the same
administrative people at those campuses are in operation today
without interruption and are accredited.
Senator Murphy. I have great respect for what you do. I
think you're living on a different planet than everyone else
who reviews the track record of Corinthian, and we can go
through the litany of abuses that they are under investigation
for today and the Department of Education considered when they
shut them down. I think we've beaten this dead horse----
Mr. Gray. I'm not here to defend accreditation. I'm sorry
we have to talk about it this long. All I'm saying is I think
the accreditation process was not the issue with Corinthian to
the extent that, as you put it, they've gone out of business.
Senator Murphy. Ms. Neal, I just want to talk about cost
here for a second. Accreditors, I think we've heard from the
panel, are not in charge of looking at cost and looking at
affordability, and it's kind of unclear to me who is in charge
of looking at cost, because we've got this triad, and yet it
doesn't appear that either of the other two legs are looking at
the issue of cost either.
So what we've heard, and I think Dr. Gray mentioned this in
his testimony, is that accreditors just aren't charged with
looking at the issue of affordability. Should they be? If they
aren't, and if they're not going to be in the future, who else
in the regulatory system is charged with making sure that these
products are affordable for students and matched to the value
of the outcome that they're getting?
Ms. Neal. Well, accreditors certainly aren't charged with
looking at cost. In fact, what they are doing is they are
adding costs. Obviously, you have to pay. It is a membership
organization. There are immense costs in terms of the self-
studies. Stanford, MI, and others have said that they're
spending often in excess of $1 million to prepare for these
accreditation reviews. They have to hire extra people to come
in and help them pull the paper together.
The bottom line is that accreditation is certainly adding
to cost, and there is I think very little expectation of value
on the part of many institutions who are being forced to push
paper and spend money on this kind of a process which has been
outlined by many of you as not working in a way that makes no
sense.
Could I also just go back----
Senator Murphy. Sure.
Ms. Neal [continuing]. A little bit to your first question
here? Clearly, you are concerned that the accreditors missed it
when it comes to Corinthian. I would submit to you that it's
not only this accreditor. It's SACS. We can look at almost any
of these accreditors. They are telling students that they are
going to get a quality education. They have accredited them.
Many of these schools are graduating in single digits or low
double digits. While Corinthian can be accused of not doing a
good job, there are many institutions that are accredited, non-
profit and otherwise, that are not doing a good job either.
I think it basically gets back to the bottom-line issue
here, that the accreditors are not doing a good job of ensuring
educational quality. No, they don't ensure cost, but they
certainly aren't ensuring educational quality either.
Senator Murphy. I don't think any of us want to suggest
that Corinthian is the only bad actor out there or, frankly,
hold any one accreditor responsible for the sins of that
particular school. It should never get to the point that it got
to with Corinthian. There's no reason that we have this system
of accreditation if not to stop a college from getting to that
crisis point at which students are being failed, en masse, to
the point of going out of business. If we're going to fix the
accreditation process, then Corinthian should be a bright
blinking light as to an example of how this went badly wrong.
Thank you, Mr. Chairman.
The Chairman. Thank you, Senator Murphy.
Senator Bennet.
Senator Bennet. Thank you, Mr. Chairman. I'm very glad you
held this hearing because I came here wondering what the
purpose of accreditation was, and now that question is even
more fundamentally at issue, I think.
I guess I would start--and I've heard from so many of my
university presidents in Colorado who said sometimes we get
some value from the peer review part of this, and that's good,
and we do a little bit better, but overall the process is
unbelievably burdensome, unbelievably un-useful, unbelievably
unhelpful to us.
I would start by asking this very fundamental question and
ask the panelists just to answer it, if you can, in one or two
sentences, which is: what is the purpose of accreditation? I'd
start with you, Dr. Ewell, and just come down the panel.
Mr. Ewell. The original purpose was the one you mentioned,
to get better. It was a self-evaluation process that, in fact,
I would submit and have talked to the Princetons and the
Stanfords, they engage in those processes themselves, and they
do get better. Accreditation and peer review helps them to do
that.
The accountability piece was added on later, and
accreditors aren't as good at it as they could be. I'm darned
if I can figure out an alternative that isn't going to----
Senator Bennet. We'll come back to that.
Dr. Pruitt, could you, just in a sentence or two, answer
that question?
Mr. Pruitt. It's the same. It's quality improvement.
Accreditors assess how we do. We just don't accredit
institutions in the sense that we subject ourselves to the same
process.
Part of the challenge we have is dealing with the
sensational anecdotal evidence. We systematically survey our
colleges, our presidents, our faculties about what's wrong with
it, how do we fix it, and we fix the things that are broken. It
has overwhelming support. If you look at the evidence, it has
the overwhelming support of the colleges' university presidents
that make up the membership of the institutions.
Senator Bennet. Dr. Gray and Ms. Neal, do you have anything
you would like to add?
Mr. Gray. Yes. Accreditation has two basic, two fundamental
purposes. One is assuring adherence to some level of minimum
standards and judging that through a peer review process; and
second, as has already been mentioned and equally important,
it's continuous quality improvement through proper planning by
the institution.
Senator Bennet. Ms. Neal.
Ms. Neal. Yes, just quickly. I agree. It started out as a
peer review operation. It was self-improvement. It was teams
coming in in a collegial fashion to help the institution know
how it could do better.
I think the problem that we have and the reason that we're
hearing about the deficiencies is that when we then put a
quality assurance enforcement obligation onto these peer review
teams, that's when we started to have problems. It's a
schizophrenic place where they find themselves, and I think
they're not able, because they're essentially membership
organizations working with each other, to do the hard kind of
decisionmaking which actually will shut a school down.
I think it gets back also to their role as guarantors of
educational quality. What I think we've heard from everyone
today is we don't know educational quality. They don't impart
evidence of educational quality. It's a very opaque system. If
a student goes to an accredited college, whether it's Harvard
or another place, that student has no way of knowing if that
school is graduating 90 percent or 5 percent.
Senator Bennet. Right. I guess the way I would think about
that is that the customers here ultimately are not the
universities and not the university presidents. The customers
ought to be the consumers of the higher education, who are the
students and their families, who are making the determination
about whether or not the place they're going is producing
outcomes and whether they are getting the value from their
education.
Ms. Neal. Absolutely. I think the transparency is critical,
and I also think it will help free the institutions themselves
to be pursuing educational quality rather than having to listen
to these external bodies who are trying to dictate to them what
to do.
Senator Bennet. What would be wrong--and anybody who wants
to answer it, I'll start with Dr. Ewell--what would be wrong
with Dr. Ewell's suggestion and your suggestion that we
collect, whoever is the ``we'', but we ask schools to provide a
handful of statistical data that tells us that they're at a
minimum threshold, hopefully not just at a minimum threshold,
and that we actually pay attention to the track record of
universities, which the chairman was asking you? It seems like
an incredibly sensible thing to do, and give a lighter touch to
folks who seem to be performing than we do to people that
aren't so we can focus our attention on the people that aren't.
Why doesn't that get to the place we need to be without all
this burdensome compliance that we're requiring, particularly
in view of the fact that I guess the accrediting bodies haven't
closed a place in 60 years, in your testimony, Ms. Neal?
Mr. Ewell. I guess you were directing that at me.
Senator Bennet. Yes.
Mr. Ewell. Yes, I very much believe in the idea of having
open, transparent pieces of information as part of the
accreditation process. We are making some progress in that, but
not nearly enough. They should be standard pieces of
information. I think one of the difficulties is that people
count things differently, and there are different ways of
reporting things. We need a set of performance indicators as a
dashboard, essentially, in all accreditation processes.
Senator Bennet. Thank you, Mr. Chairman. I'm out of time. I
appreciate the hearing.
The Chairman. Thank you, Senator Bennet.
Senator Casey.
Statement of Senator Casey
Senator Casey. Thank you, Mr. Chairman. Thanks for the
hearing. I appreciate our witnesses being here.
Dr. Ewell, I was going to start with you on two questions.
One is public reporting, and the other would involve students.
I noted in your testimony on page 2, under the section
headed ``Public Reporting,'' you say, ``Accreditors do not
provide much information,'' or I should say, ``Until recently,
accreditors did not provide much information on the results of
institutional reviews,'' and then you go on later in the
paragraph to say,
``Public reporting might be further improved through
the development of standard reports, listing the
strengths and challenges of each institution determined
in the course of a review,''
and you go on from there.
Just on this issue of public reporting and transparency,
what do you think is most needed?
Mr. Ewell. As I say, the most important thing about the
proposal that I'm making, which is not just mine--it's one that
accreditors have, in fact, considered but just haven't gotten
around to doing--is to say that as a result of a review, after
an institution has engaged in a review, there should be a few
bullet points that say basically this place is really good at
this, and a few bullet points that say this place is not very
good at this. It would be all backed up in terms of the
qualitative findings of peer review, as well as quantitative
indicators.
You had another question?
Senator Casey. I was going to followup on that one, as
well. How about the additional question as to what's the best
way to release the accreditation information? What do you think
is the best format or----
Mr. Ewell. I think there needs to be a fairly standard
format so that people can compare across institutions in terms
of a set of standard headings. A number have been proposed. One
is that it would follow the standards of accreditation that the
accreditor has put forward, so a standard of student learning,
for example. I wish they all had them. If they did, it would be
around that. The difficulty with that is that not all
accreditors use the same headings to report things.
The other alternative would be to develop a standard set of
headings that everybody would be very much interested in, if
people graduate from this place, do they get jobs, do they go
on for further education, what are things like student/faculty
ratios, and the quality of the student experience, et cetera.
Senator Casey. I'll come back to you in a moment. Dr.
Pruitt, anything on this that you want to add?
Mr. Pruitt. Yes. I am a little bit disturbed that we ignore
the current realities here. If you go on the website of any
accredited college or university in the country, certainly ones
accredited by the regionals, there are reams of pages of
information about the institution, and performance data, and
financial data. I believe that accreditation decisions made by
an agency should be made public, and in many cases they are
made public. Certainly in public higher education, they are all
made public.
I believe there should be common language used so that you
can understand what they mean. The Council of Regional
Accreditation came in and has done that. They are implementing
that.
There are many things that you've heard before this panel
that just factually are not true. It is not true that
accrediting bodies have not revoked accreditation from colleges
and universities. You have to excuse me if I have some
frustration about that because I think we need to start with
what the objective realities are that are actually taking place
in the field before we can formulate rational responses to
them.
Senator Casey. I wanted to go back to the second broad
question about students and their involvement, or maybe it's
their lack of involvement. What's your opinion on the role that
students can play in this process?
Mr. Ewell. Is that directed at me?
Senator Casey. Yes.
Mr. Ewell. OK. As I say, I think that students could be
useful included on teams, or at least review the materials. One
of the things that I talk about in my testimony is increasing
use of expert panels that really know something about what it
is that we're dealing with. Students know something. They know
something about what the student experience is, and one could
constitute the students as a separate review panel that would
interview other students. There are a number of ways in which
it's done.
As I say, in Europe, where of course there are student
unions and political involvement and so on, it's a very strong
presence of students.
Mr. Gray. I'd like to add that I know in the ACICS
accreditation process, students play an integral part. Students
are surveyed. There's a great deal of information derived from
the students during the field team's visit, and we use student
information to a great extent in doing the evaluation of the
effectiveness of the educational process.
Senator Casey. I'm out of time. Ms. Neal----
Ms. Neal. If I could just add, I think that rather than
putting students on these visiting teams and making them a part
of accreditation, let's give them real information. Let's let
them know what these schools are doing. Let's look at the
graduation rates. It may be an imperfect metric, but it will
tell them something which they cannot get from accreditation
now. Let's use some of the data that schools are already
putting on College Navigator, and let's pull it together and
have them put it on their website so that families and
consumers can actually find out how schools are doing. Let's
rely on metrics that show student learning gains.
When it comes to the accreditation, they are to be
guarantors of educational quality. As I think we've heard, they
have not guaranteed that. If we allow institutions to show that
they are taking students and they are graduating them at or
above predicted learning gains, then we can see actual quality,
and then a student will be informed and will be able to know
this is where I want to put my money as opposed to this
institution. That's how I would propose to help students.
Senator Casey. Thanks very much.
The Chairman. Thank you, Senator Casey.
Senator Whitehouse.
Statement of Senator Whitehouse
Senator Whitehouse. Thank you, Chairman.
I had another hearing this morning. This topic may have
been raised already, so forgive me if I'm re-plowing plowed
ground. I note that accrediting agencies receive their funding
from fees that are paid by the colleges that they monitor, and
that seems to set up a pretty significant potential conflict of
interest.
I'm interested in how that arrangement is different than
the relationship between the Wall Street banks and the credit
rating agencies which they paid to evaluate their products and
which the credit rating agencies then gave wildly exaggerated
ratings to that led to the financial collapse. It seems to me
that where a regulatory body is being funded by the regulated
entity, that creates a significant risk, and we've just had
that experience in the banking sector. Can you explain why that
should be a concern to us in this sector?
Mr. Gray. In the world of accreditation--and my experience
is well beyond education. In public health, for example, public
health departments are accredited, and the sustaining of that
accreditation comes from fees derived from the public health
departments. Many other endeavors which are accredited are
funded by the entities that they accredit. That's not uncommon.
In fact, that's the normal model by which accreditation
agencies operate and are funded. They're normally not funded by
governmental resources. That's a different type of conflict of
interest, which they don't want to have.
Also, all the decisions that an accreditation body makes
are made by its council. The council is scrutinized very, very
thoroughly to make sure there is no possibility of a conflict
of interest, and the processes that the council uses in terms
of excluding certain members from discussions or decisions
regarding certain institutions are very thorough and carefully
documented.
You go to great lengths to avoid conflicts of interest, or
even the appearance of conflict of interest, and there's no
preferential treatment given to any institution because they
are paying fees.
Senator Whitehouse. Ms. Neal.
Ms. Neal. I couldn't agree more. It is a highly conflicted
situation, and I think it's largely because peer review, which
is colleague to colleague in a voluntary set-up, is fine,
there's no conflict. When you make accreditors the gatekeepers,
when they then basically become agents of the Federal
Government and are responsible for deciding where $170 billion
goes, it does become a serious conflict, which is why I think a
direct expedited recognition process more analogous to
companies which file for an IPO with the SEC would be a better
way. It will take the burden away from institutions, it will
provide information for students, and it will get ultimately to
what we're trying to find out, whether or not colleges and
universities are actually adding educational value, something
that we really have difficulty finding out now.
Senator Whitehouse. Let me get to that question. It strikes
me that the accreditation has a role to serve as a proxy for
direct student information, direct customer information, in the
same way that when I look at the underwriter laboratory's label
on a toaster, I don't have to be an electrician, I can have
some assurance that it's not going to burn up or it gets the
Good Housekeeping Seal of Approval, whatever that's worth.
Let's hypothesize that we could create a dashboard of
student information that completely replaced the proxy function
of the accreditation, hypothetically, so that that function was
no longer necessary. Are there other uses of this accreditation
process that would still have value, assuming just the badging
of it was fully adjusted for by having a really robust,
accessible, clear dashboard of outcome measures that many of
you have mentioned? Is that really the sole purpose of what the
accreditation process is, to provide that proxy seal of
approval?
Mr. Pruitt. The confusion you're hearing and one of the
things I think we all agree on, although we have very different
points of view, is that part of the challenge we have is that
there is a conflicted expectation of what accreditation is. You
referred to it as a regulator. We are charged to do certain
kinds of compliance reviews.
We view our role as an assessor. An assessor behaves
differently than a regulator. A regulator prescribes the
behaviors of the institution. Accreditation does not prescribe
the behaviors of the institution. You indicated a banking
regulator----
Senator Whitehouse. By threatening to not give
accreditation unless the behavior is changed.
Mr. Pruitt. No. Not the behavior, Senator, not the
behavior, the outcomes that we produce, and there is a
difference.
Senator Whitehouse. Well, the behavior----
Mr. Pruitt. There is a difference between the outcomes that
we produce and the behaviors that we go to produce those.
Regulators in banks prescribe the things that bankers can do
and cannot do. Accreditors cannot prescribe what academics can
do and not do, as long as the results are such that we can
demonstrate that they have value to the people that support us
and the students who----
Senator Whitehouse. I guess my question was, outside of the
proxy function of being a badge that its underwriter
laboratories can say this is good, this is a good place for you
to go to school, you'll get a good education, outside of that,
what's the value of the accreditation process, Ms. Neal?
Ms. Neal. Well, I think fundamentally the accreditation
Good Housekeeping Seal of Approval has been proven not to be a
Good Housekeeping Seal of Approval. It does deceive consumers.
Is there a role for accreditation? Yes, I think there is a
role for accreditation, to return to its voluntary self-
improvement role.
I like to look at the lead certification program in
architecture. It's an entirely private certification, and it
has revolutionized the way we think about green buildings. This
is an example of how a marketplace of accreditors who were no
longer burdened by the gatekeeping role could actually create
wonderful reviews that would tell consumers something. Right
now, it's the lowest common denominator. All we know is that an
entity is either accredited or not. If we set them free and we
take away this enforcement gatekeeping role, they then can
create sector-based. They could have gold, silver, platinum
vis-a-vis higher education. They could do ones for research
institutions, they could do those for comprehensive. They
really could come up with a range of differentiated programs
that would actually allow us to understand whether a school was
doing a good job at something or was better at another thing.
I think if we took the gatekeeping role away from them, we
would end up having a very rich marketplace of signifiers to
consumers as to what schools could do and not do.
Senator Whitehouse. Thank you, Mr. Chairman. I've gone over
my time. I appreciate your indulgence.
The Chairman. Thank you, Senator Whitehouse.
And thank you to the witnesses. This has been a lively and
wide-ranging discussion of many options having to do with
accreditation.
What I'm going to do to conclude the hearing is make an
observation or two, and then I'm going to ask each of you if
you have any last word that you'd like to make for a couple of
minutes, because you've heard a lot and you may have something
that you'd like to say, and I'd like to encourage you, if you
have more to say. I'd welcome, and so would other committee
members, your further written testimony. I think the Senators'
participation has been interesting, and your testimony has been
interesting.
As I've listened to my colleagues talk, I'm in about the
same position as Dr. Ewell is. When we say ``we would do this''
or ``let's do this,'' great. But who is the ``we'' and who is
the ``let us?'' I think the reason we've ended up with the
accreditors as the gatekeepers for title IV is because we were
pretty sure Congress didn't have the capacity to do it. We know
ourselves well enough to know that. Many of us are very
skeptical of the ability of the U.S. Department of Education to
take on an assignment like that because it's one of the
smallest departments. It doesn't have much capacity for this
kind of thing. Whenever it has tried to do it--for example, in
defining student achievement a few years ago--there was a huge
rebellion throughout the campuses.
It's hard for me to see the alternative to a properly
functioning system of accreditation to a validation of whether
a university or college should receive title IV funds. Just
speaking for myself, there are a number of suggestions here
that I think we ought to think more seriously about, and we
intend to reauthorize the Higher Education Act later this year.
Senator Murray and I hope to have a bipartisan proposal for the
committee to begin considering in September, and we'd welcome
your specific suggestions, whether they're the 3 of Dr. Neal or
the 11 of Dr. Ewell or some version of the improvements of Dr.
Gray and Dr. Pruitt.
The ones that seem to me that I think we hear more
consensus about is to the extent the accreditors continue the
gatekeeper role, their focus should be on quality and not all
these other things that Congress has imposed on the
accreditors. I think that has turned out to be a mistake and
interferes with what we would hope accreditors would do, and
we're going to address that directly and I hope successfully.
The second idea I hope we will consider, and I know, Dr.
Pruitt, you and your colleagues may not agree with this, and
Dr. Ewell hasn't figured out how to draw the lines, but it
seems to me there's a lot less validity today for regional
accrediting agencies exclusively. When I was president of the
University of Tennessee, I looked at the University of
Illinois, the University of Michigan, universities outside our
region as peers. I wonder if there's not some room there for
discussion.
There also seems to be a good deal of agreement that a
lighter touch for some institutions as opposed to others is a
good idea, and we're going to look at ways to do that. That
just makes common sense, and I think there's a focus on that.
Maybe in your final remarks, Ms. Neal, you'll explain to me how
we can trust the U.S. Department of Education to just recognize
a college or university without getting enthusiastically into
the business of defining what student achievement is at Harvard
and whether the Department of Education is really competent to
be the one to decide whether you learned more after 4 years at
Harvard than you knew when you arrived.
Maybe that's true. Maybe there needs to be a pilot program
that tries that and creates a parallel way for people to get
recognition for title IV, see what happens with it.
Those are some of the areas that I think are promising, and
this is a chance to improve what we're doing or change what
we're doing.
Let me thank the witnesses, invite your later comments.
We'd like to have them in 10 days if you make them. We'll have
another hearing on the reauthorization of the Higher Education
Act in the July 4th recess, and one of our future hearings will
have to do with innovation and all of the new things in our
lives today, are there any adjustments we need to make in the
Higher Education Act to permit colleges and universities and
students to take advantage of the new ways of learning.
That will conclude the hearing after your final comments.
Let me start with you, Dr. Ewell, go down the line. Thank
you for being here. I'd ask if each of you would like to take a
couple of minutes and offer a last word.
Mr. Ewell. Very, very briefly, because I've gone over my
time on many occasions. Let me agree with the idea of pilots. I
think that a good deal of experimentation in some of these
uncharted areas which are not institutionally based, the kinds
of things like badges, MOOCs, other kinds of providers, they're
providing a good deal of education at this point. Accreditation
should have picked them up but hasn't done so. I'm a little
disappointed with that. I think that's something that needs to
be done.
Then one other very specific thing. We spent a lot of time
on Corinthian. We haven't mentioned one other thing that's
being played out right now, and that's the conflict between San
Francisco City College and the WASC Junior Commission, who is
trying to sanction a very bad institution, the difficulties
that an accreditor gets into when they try to actually sanction
due to contrary legal action and all kinds of things like that.
I think there needs to be some things that stiffen their
backbone a little bit in terms of limitations of liability and
things of that sort. That's not in my testimony but it's
something that occurred to me.
The Chairman. Thank you, Dr. Ewell.
Dr. Pruitt.
Mr. Pruitt. Very briefly, Mr. Chairman, you've been part of
a continuum of activities in terms of the Task Force on
Regulation, so this hearing has context. I think, for the sake
of time, I pretty much agree with you, where you've come out in
terms of your processing of all of this.
The only comment I would have about the issue about the
regionals, there's no sanctity in any particular one structure.
I would say, though, that regionals do allow institutions to
peer reference, and they peer reference to institutions
wherever in the world those peers may be. They are not limited.
There is nothing in the world that I'm aware of that would have
kept the University of Tennessee from referencing and measuring
itself against either Illinois, Michigan, Stanford, or
Cambridge for that matter. There is that flexibility built into
the system.
My final comment is, and as I said earlier, there's a lot
of anecdotal stuff flying around that defines the realities
that conflict with what the evidence says the realities are. I
would hope at the end of the day, as we consider policy, we go
back to what the evidence says and give that more weight than
some of the anecdotal stories that would otherwise influence
it. Thank you.
The Chairman. Thanks, Dr. Pruitt.
Dr. Gray.
Mr. Gray. Thank you, Senator Alexander. I would just say
that I would hope, as the reauthorization of the Higher
Education Act moves forward, that we continue to consider with
respect to accreditation refocusing on the academic quality
aspect of accreditation; also, looking for ways, as I
mentioned, to reduce regulatory overreach and the regulations
related to accreditation.
I would also say, on the subject that I've heard discussed
this morning regarding delinking the gatekeeping role from the
accreditation role, I disagree. I think what was described by
Ms. Neal was kind of a utopian accreditation endeavor that
would happen if, in fact, that linking was deactivated. In
fact, what I see would happen would be, first of all, a
decrease in the motivation to be accredited. That's a bad
thing. Second, fewer accredited schools. That's not a good
thing for the students, and the students are the benefactors,
the customers that we're most concerned about here. Frankly,
there would be no good quality assurance resource available to
the Department of Education in making their decisions.
Finally, it's perplexing, but I'd like to see a mechanism
somehow to better educate policymakers and the public about the
role of accreditation. Some of the comments I've heard this
morning about Corinthian say to me that there's a lot of
misunderstanding about accreditation, in particular with
respect to Corinthian, but accreditation in general with
respect to its role in the sustainability of educational
institutions.
The Chairman. Thank you.
Ms. Neal.
Ms. Neal. I want to thank you, and I know I'm the last
between you and departure, so I'll try to be brief.
I certainly think we've heard that the system is not
functioning well and that it desperately needs improvement and
deregulation. I think it's interesting that often, when schools
are asked if the accreditation was delinked what would you do,
many of them say, ``well, I would not want to continue''
because they find no value with the existing accreditation
process, and I think that's more of a testimony to the way it
operates now than necessarily to the value of a good,
functioning peer review self-improvement process.
In terms of the direct expedited recognition, lighter touch
approach, I submit that it does not necessitate a larger
Department of Ed involvement. In fact, the DOE should have a
very limited role. It would retain its existing oversight in
terms of financial responsibility, but in terms of other
actions it could take against institutions, because the
institution would be submitting audited data, the ability of
the DOE to act would be largely in response to finding that
that data was false and acting against an institution that had
supplied erroneous information.
I think in terms of the data about student learning, again
that would not be the role of the Department of Education. That
would be offered by nationally normed tests such as the
Collegiate Learning Assessment, the Proficiency Profile. These
are tests which I think offer a special opportunity for schools
that may not be famous like Harvard to show that they are
offering student learning gains because they take the students
where they are and they assess whether or not they are at or
above predicted learning gains. Not all institutions would be
expected to be operating at the same level, but they would
actually adapt to the particular population.
I think it offers a wonderful opportunity for schools with
varying populations to show whether or not they're doing a good
job and to give the institutions the autonomy they need.
The Chairman. Thank you, Ms. Neal. Thanks to each of you
for coming today and for interesting testimony.
The committee hearing is adjourned.
[Additional Material follows.]
ADDITIONAL MATERIAL
ACICS,
Washington, DC 20002-4223,
June 30, 2015.
Hon. Lamar Alexander, Chairman,
Committee on Health, Education, Labor, and Pensions,
U.S. Senate,
428 Senate Dirksen Office Building,
Washington, DC 20510.
Hon. Patty Murray, Ranking Member,
Committee on Health, Education, Labor, and Pensions,
U.S. Senate,
428 Senate Dirksen Office Building,
Washington, DC 20510.
Dear Chairman Alexander and Ranking Member Murray: ACICS
appreciates the opportunity to appear before the Senate HELP Committee
on June 17, 2015. We hope the information provided will help the Senate
clarify and strengthen the role of accreditation in the Higher
Education Act. As a supplement to the information provided in writing
and in person, ACICS offers additional perspective below for the
record.
ACICS acknowledges the intense interest of Congress in the current
state of post-secondary education, and the discipline of quality
assurance that is intended to protect students and taxpayers. The
demise of a post-secondary institution is always a source of great
distress and displacement, particularly for the students. To the degree
the accrediting community, the U.S. Department of Education and
appropriate State authorities can collaborate on reducing the incidence
of student displacement, ACICS welcomes all constructive ideas. The
Council takes its responsibility very seriously, and is committed to
improving its effectiveness on behalf of students.
Questions were raised at the hearing regarding the bankruptcy and
closure of Corinthian Colleges Inc. (CCi). The limited time and
constrained format did not allow ACICS sufficient opportunity to fully
answer all of those questions. The information below is offered in that
spirit.
Four CCi campuses accredited by ACICS (three in California, one in
New York) before revocation on April27, 2015, served approximately
4,000 students. More importantly, more than 90,000 students enrolled at
37 campuses sold to Zenith Education Group (ZEG) and accredited by
ACICS continue today in their studies under a valid grant of
accreditation and the approval of State and Federal authorities.
To re-emphasize the oral testimony, all of the 59 campuses owned
and operated by Corinthian and accredited by ACICS had their
accreditation intact up until the campuses were either sold or ceased
operations. All had been subject to at least one full site review
between 2012 and 2014. The site reviews found most of the campuses to
have few if any quality issues; some had several quality issues and
were subject to deferrals and other sanctions pending their
demonstration of full compliance with Council standards. In addition,
ACICS 's review of student satisfaction data indicated satisfactory
performance by most, if not all, of the campuses.
Students currently enrolled at campuses operated by ZEG have been
given the opportunity to continue with their current program, transfer
to a different program without financial hardship, or terminate their
enrollment and receive a refund. As is the case for every change in
ownership of an ACICS-accredited college or school, a team of senior
officials from ACICS will review the administrative and academic
capacity of ZEG's corporate headquarters this summer. This requirement
is applied consistently within 6 months of any change of ownership. In
addition, every ZEG campus will be visited in 2015 for quality
assurance by experts in post-secondary education.
In acknowledgement of expressed sentiments, ACICS standards,
policies, and program of quality review are based on expectations of
honesty and integrity in relations with students, education quality
that enables completers to pass required licensure exams, and
institutional effectiveness that leads to employment. More than 25
explicit standards in the ``ACICS Accreditation Criteria'' address
these dimensions of integrity, and the requirements are tested through
more than 50 discrete questions that must be answered and supported
through interviews, observations and documents at each campus during
each full team review.
ACICS has not concluded its thorough review of the validity of the
allegations of misrepresentation contained in numerous investigations
by State attorneys general. The evidence available has been general and
broad, lacking specificity regarding time, place, individuals and
circumstances. Evidence of that specificity is necessary in order for
ACICS to reach an informed and considered decision regarding the
institutions' compliance with standards of integrity; relations with
students including recruitment; advertising and misrepresentation; and
public disclosures. In total, ACICS applies more than 91 standard
questions regarding those topics at each campus during each full team
review.
Inquiries and investigations by State attorneys general regarding
the relations with students at CCi campuses began in December 2012.
During the next 2\1/2\ years, ACICS was notified of, tracked and
analyzed open inquiries by State attorneys general in 15 States. In
every case, ACICS required CCi to provide written evidence of their
cooperation with the inquiries and any final determination. In all
cases, those inquiries were in the discovery phase as of April 27,
2015.
ACICS was meticulously tracking and analyzing student complaints
and adverse third party information before, during and after the U.S.
Department of Education applied conditions to the company's Federal
student aid disbursements beginning in June 2014. The pattern of
student complaints has substantial weight with the Council, because
accreditation actions that enhance the student experience are a high
priority. An analysis of those complaints indicated that for the 4-
years preceding the demise of CCi, ACICS received less than one student
complaint per campus per year. The analysis also shows that those
complaints primarily focused on three issues: financial aid (disputes
about account balances), faculty issues, and lack of externship sites.
About two-thirds of the complaints concerned the first category. Most
of the complaints did not merit action by ACICS because they did not
relate to a specific quality assurance standard, or the school was able
to demonstrate compliance with ACICS accreditation criteria. Direct
surveys of students indicated general satisfaction with the education
provided, and a willingness to recommend the institution to others.
Determinations of institutional quality and integrity by Council
are based on material information sources and methods of inquiry. Those
sources are augmented by information provided by students, faculty,
staff, and third parties, including the news media, plaintiff 's
attorneys and State consumer authorities, such as attorneys general.
None of those sources of information are necessarily decisive by
themselves in making a thoughtful and comprehensive evaluation of the
institution. Rather, the Council takes all of those into consideration,
applies its own judgment and experience, follows the required due
process protections and makes a final determination.
Schools are required to include in their Institutional
Effectiveness Plan goals for employer satisfaction and mechanisms to
survey employers periodically. Expert evaluators scrutinize the plan,
as well as data collected and analyzed by the institution to make sure
that information from the employer community is shaping educational
programming. In addition, each program is required to establish a
community outreach mechanism, such as a program advisory committee,
that solicits from the workforce community its emerging needs and
requirements.
One of the conclusions expressed was that CCi ``failed its
students'' in terms of financial stability, in terms of educational
quality, as measured by Cohort Default Rate (CDR), and price of
attendance. ACICS had diligently reviewed audited financial statements
from CCi for each of the preceding 4 years and found no evidence of
systemwide financial instability. CCi was subject to additional
monitoring and reporting at the corporate level by the Council in part
due to the conditional participation in title IV programs imposed by
the Department.
Under the financial monitoring requirement, CCi developed and
submitted for ACICS's review a teach-out plan to protect the interests
of currently enrolled students. When 37 campuses were sold to another
organization, the requirement of teach-out plans to serve those
students was rendered moot. However, CCi did not fulfill the teach-out
requirements for the four Everest campuses which closed in late April;
the Council will review at its August 2015 meeting the degree to which
students were displaced by the sudden cessation of operations and
decide appropriate sanctions to apply to members of the Corinthian
leadership team.
Regarding the repayment of loans by students, none of the Everest
Colleges had student 3-year CDRs (2014) in excess of 30 percent, the
rate at which schools are in jeopardy of losing their title IV
eligibility. This CDR information is provided independently to ACICS by
the U.S. Department of Education.
ACICS's standard process regarding loan repayment performance is to
review the CDR rates of all institutions every year. Schools with a
default rate above the Department's threshold are required to submit an
improvement plan subject to Council review. The type of students that
member institutions serve--many come from disadvantaged socio-economic
backgrounds or households--contributes to higher rates of loan default.
ACICS is unaware of any evidence that institutions with higher CDRs are
necessarily of lower quality than institutions with lower CDRs; ACICS
is aware of numerous studies that show CDR and demographics of the
student population to be directly correlated.
Finally, ACICS has developed no standards regarding the prices
charged to students by member institutions. Nor has ACICS imposed
maximum tuition rates at member institutions. Regulating the cost of
attendance is clearly beyond the authority of accreditation and outside
the purpose of quality assurance. However, as offered in ACICS's
written testimony, the Council has a direct interest in evaluating the
value component of the price/value proposition through its program of
quality assurance. The Council will continue to refine and enhance its
methods of review to ensure that students attending member institutions
realize the greatest possible benefit for their emotional, spiritual,
intellectual, temporal and financial investment.
To summarize, the primary role of ACICS is to assure quality and
promote excellence. A secondary role is to ensure institutions adhere
to minimum standards of quality and integrity. When an institution
falls below standards, it is subject to sanctions, including deferrals,
additional reporting, show-cause directives, probation and ultimately
loss of accreditation. The chart below reflects how frequently ACICS
accredited institutions have faced sanctions and penalties:
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
In conclusion, more than 90,000 students enrolled at ZEG campuses
accredited by ACICS continue in their studies under a valid grant of
accreditation and the approval of State and Federal authorities.
Whatever deficiencies of accreditation have been enumerated, the facts
indicate that while ACICS continues its efforts to improve,
accreditation is working and performing the job it was assigned by the
Higher Education Act. ACICS welcomes the opportunity to respond to any
additional questions or inquiries you may have.
Sincerely,
Albert C. Gray, Ph.D.,
President and CEO.
______
Response to Questions of Senator Murphy by Peter T. Ewell, Ph.D.
Question 1. When institutional performance and student achievement
information is self-reported by institutions, how do accreditors verify
its accuracy?
Answer 1. This varies a lot by accreditor, and even by
accreditation team. The most rigorous position is probably in teacher
education where the Teacher Education Accreditation Council (TEAC)--now
merged with the Council for Accrediting Education Programs (CAEP)--
performs ``audits'' of all supplied data to verify the reported
results. But this is much more rigorous than practiced by most
institutional accreditors. Most ask institutions to supply details of
the reported results--what methods were used, how the results were
analyzed, etc.--and use the interviews during site visit(s) to try to
explore or verify the results reported, but this is not very
systematic. Some are exploring audit methods as above (e.g., WASC
Senior Commission) and some use explicit ``rubrics'' or scoring guides
to rate the quality (and presumed veracity) of institution-reported
results. But this is a very good question and it should probably be
asked systematically during NACIQI's consideration of each accreditor's
gatekeeping status.
Question 2. In a recent SEC filing, ITT Tech informed investors
that 69 ITT locations were not meeting the ACICS threshold for student
outcomes and 25 locations were not meeting student placement
thresholds. If shareholders need to know this information, should
students be made aware of this as well? What role can accreditors play
in increasing disclosure of institutional problems?
Answer 2. I believe that all relevant information about
institutional performance should be disclosed as part of the
accreditation process. This includes information about student academic
achievement, student success (retention, graduation and job placement),
and key student experiences. There may be cases where information about
finances (bond ratings reported confidentially by an external rating
agent, for example) might appropriately be reported to shareholders not
the public. But, in my view, these should be exceptions.
Response to Questions of Senator Murphy by George A. Pruitt, Ph.D.
Question 1. When institutional performance and student achievement
information is self-reported by institutions, how do accreditors verify
its accuracy?
Answer 1. In answer to your question, I am speaking from my
perspective as chair of the Middle States Commission on Higher
Education (MSCHE).
The Middle States Commission is concerned about appropriate
institutional generation and use of both student achievement and
student learning outcomes information. Our peer evaluators are charged
with responsibility for reviewing institutional self-studies that
address topics related to academic performance, including the
assessment of student learning; student admissions and retention; and,
institutional integrity, including the provision of information on
institution-wide assessments available to prospective students,
including graduation, retention, certification and licensing pass
rates, and other outcomes as appropriate to the programs offered. When
reviewers find an institution out of compliance or in danger of non-
compliance, those situations are publicly recorded in Commission
actions that are listed by institution on the Commission's website. As
warranted, institutions may be asked for further followup in specific
areas.
Institutions are also asked to annually submit institutional
profile data that is reviewed by Commission staff. Information on
graduation and enrollment is included. Staff review the data submitted
and will contact the institution if there appears to be any
inconsistency in the data or if analysis reveals any concern. Staff may
informally request additional information or may request a formal
supplemental information report if the situation warrants.
MSCHE also annually reviews institutional Web sites of member
institutions to determine whether required consumer information is
available. Followup is initiated with the institution if data is not
accessible or if there are questions or concerns.
Over the past several years, MSCHE has engaged in an effort to
separate and clarify Commission responsibilities related to compliance
with Federal regulations. In order to accomplish this, we have
developed a separate process addressing Verification of Compliance with
Accreditation-Relevant Federal Regulations in which a peer evaluator
specifically reviews institutional submissions and provides results for
further consideration by review teams and the Commission. Among the
data required in the upcoming 2015-16 year, institutions must provide
information about graduation and completion, and (as appropriate)
licensure pass rates. The peer reviewer assigned is asked to determine:
Whether the institution appropriately documents and
publishes required information and whether it is reasonably accessible
to the public; and,
Whether the methods, policies, and procedures documented
by the institution are reasonable for their purpose.
Question 2. In a recent SEC filing, ITT Tech informed investors
that 69 ITT locations were not meeting the ACICS threshold for student
outcomes and 25 locations were not meeting student placement
thresholds. If shareholders need to know this information, should
students be made aware of this as well? What role can accreditors play
in increasing disclosure of institutional problems?
Answer 2. My answer to this question is informed by my experience
as president of Thomas Edison State College, an institution serving
non-traditional students as well as my experience as chair of the
Middle States Commission on Higher Education. MSCHE is not the
accreditor of ITT Tech, and I cannot address the specifics of that
case.
MSCHE is fully committed to disclosure of important information
about the status of accreditation for each member institution. Toward
that end, the Commission has for years published on our website a
Statement of Accreditation Status (SAS) for each institution. The SAS
shows general institutional information as well as details about
accreditation actions taken by the Commission, including specific
references to standards where non-compliance has been found or followup
is required. Further, where non-compliance actions (warning through
show cause and withdrawal of accreditation) are taken, a public
disclosure statement is posted to further explain the actions taken and
the next steps required of the institution.
In my testimony before the committee, I touched on two areas that
are relevant to this discussion. Let me first address the concept of
one-size-fits-all templates, metrics, and bright lines. I do not know
what the thresholds were for ACICS student outcomes or placement and
therefore cannot comment specifically about them, but I am thoroughly
convinced that it is never a good idea to mindlessly apply a set of
bright line indicators without understanding the context, and that it
is not a good solution to allow metrics to replace thorough analysis by
qualified peer evaluators. For example, I noted that graduation rate
statistics are not a good measure of success for Thomas Edison's non-
traditional students who do not move through college in the assumed
progression. Alternative information such as pass rates on professional
licensure examinations is more meaningful for the student population
served. The point is that the context is essential and should not be
lost in a search for a single, simple measure.
It is also important to touch on the concept of full transparency/
disclosure in the accreditation process. As indicated above, MSCHE
fully discloses accreditation actions for each member institution.
However, the Commission currently does not allow full transparency with
regard to all accreditation documents. It is my opinion that doing so
would change the nature of the interaction between accrediting agency
and institution. Looking toward the future, however, I offered the
opinion that the work product of accreditation might remain protected
while some consideration could be given to disclosure of team reports
or summaries of those reports. I would hope that disclosure of reports/
summaries might allow for consideration of all-important contextual
information
Response to Questions of Senator Murphy by Albert C. Gray, Ph.D.
Question 1. When institutional performance and student achievement
information is self-reported by institutions, how do accreditors verify
its accuracy?
Answer 1. An ethic of trust in self-reported data is made stronger
when its accuracy, timeliness and completeness are subject to
verification through a series of recurring tests and reviews. During
the in-person accreditation review of member institutions, ACICS
examines the back-up data and documents that are the basis for annual
accountability data reports. Typically, a random sample of student
achievement outcomes--such as placements or success on licensure
examinations--is reviewed in depth by program specialists. They examine
the completeness of the required back-up documentation and interview
administrative personnel regarding the manner in which the information
was collected, aggregated and reported. Further, the program
specialists place calls to employers and graduates to verify the
information captured in the institutional records. If a pattern of
incongruence manifests, the institution will be required to submit its
data to additional tests of veracity and could be subject to sanctions
by the Council, including probation or loss of accreditation.
ACICS is piloting a Placement Verification system where at random
every claimed placement is directly verified by ACICS through
communications with the student and/or employer. The verifications
would be applied to data received by ACICS in between recurring in-
person accreditation reviews.
As is the case for all institutional data reported by all colleges
and universities in the United States, the integrity of institutional
data, utilized by ACICS and its accrediting Council to make
accreditation decisions, is assumed to be sound. A trust relationship
between the quality assurance authority and educational institution is
paramount to the effectiveness of the self-governed discipline of
voluntary accreditation.
Question 2. In a recent SEC filing, ITT Tech informed investors
that 69 ITT locations were not meeting the ACICS threshold for student
outcomes and 25 locations were not meeting student placement
thresholds. If shareholders need to know this information, should
students be made aware of this as well? What role can accreditors play
in increasing disclosure of institutional problems?
Answer 2. ACICS requires all institutions to disclose student
achievement information on a regular basis. Most fulfill that standard
by posting on their Web sites institutional performance data as
reported to ACICS, including retention, placement and licensure exam
pass rate data. ACICS is developing enhancements to this standard to
strengthen the quality and value of student achievement information
that is shared with the public.
Disclosures of compliance risk by publicly traded education
enterprises are required by Federal securities law, and fulfill
expectations of transparency by the investment community. In this
particular case, the institution--not ACICS--determines which findings
of its latest accreditation review rise to the level of mandatory
disclosure. The principle applies to all publicly traded higher
education companies, not just those accredited by ACICS.
The thresholds in question are self-improvement points of reference
established by ACICS to encourage an institution to improve performance
in certain discrete areas well in advance of its performance falling
below minimum quality standards. Disclosing all of those ``early
warning'' indicators to the public or students for every program each
year would also require the conveyance of substantial narrative
explaining the significance and weight associated with each indicator.
The Council uses the ``early warning'' information to focus its quality
assurance conversation with the institution on issues that are most
salient and current. In no event would an institution that fell below
the improvement threshold for placement or retention, absent any other
information, be deemed to be of low quality by the Council or subject
to negative or adverse actions. If the sub-standard performance
persists, and the institution demonstrates a fundamental inability to
meet Council standards, ACICS would impose formal sanctions that would
be disclosed publicly, to the U.S. Department of Education and State-
approval authorities.
ACICS is always open to considering alternative ways to make
available to interested parties the quality findings of its
accreditation reviews. As long as the institution has the opportunity
to respond to those findings, and the Council's final decision takes
into consideration that response, the final action complies with
statutory and regulatory requirements. Disclosures that are not based
on the full accreditation process are unfair to the institution,
misleading for consumers, and contrary to Department regulations and
Federal statute: the accrediting agency is required to provide
appropriate opportunities for response to preliminary findings before a
negative action is taken or published.
Response to Questions of Senator Murphy by Anne D. Neal
Question 1. When institutional performance and student achievement
information is self-reported by institutions, how do accreditors verify
its accuracy?
Answer 1. Accreditors require institutions to write an extensive
self-study and to assemble a veritable room full of documentation for
the visiting team to examine. These preparations typically require
several faculty and staff members dedicated to the task for many months
prior to the visit, which is one of the reasons that institutions find
the accreditation process highly burdensome and expensive.
Unfortunately all of this work demanded of institutions does not
protect students or taxpayers from malfeasance. It took the Southern
Association of Colleges and Schools (SACS) 19 years to become aware of
University of North Carolina's fraudulent grades, given in large
measure to athletes. Claremont McKenna College inflated its SAT scores
and class rank for 6 years. These are hardly unique scandals and
underscore the inability of accreditors to monitor the information they
receive effectively.
Moreover, the decennial nature of the accreditation process makes
the information outdated even if it is accurate The alternative system
proposed by ACTA in our testimony http://www.help.senate.gov/imo/media/
doc/Neal1.pdf would insist that institutions provide key consumer
information annually and have it already audited by an independent
third party when it is provided, making the institution then subject to
sanctions for misrepresentation. This would be far more effective than
the ``data dump'' of largely unverified information that is the current
accreditation process.
Question 2. In a recent SEC filing, ITT Tech informed investors
that 69 ITT locations were not meeting the ACICS threshold for student
outcomes and 25 locations were not meeting student placement
thresholds. If shareholders need to know this information, should
students be made aware of this as well? What role can accreditors play
in increasing disclosure of institutional problems?
Answer 2. Yes, students, taxpayers, and policymakers need this
information to be clearly and unambiguously reported. And for this
reason, in testimony from the American Council of Trustees and Alumni
http://www.help.senate.gov/imo/media/doc/Neal1.pdf and in the NACIQI
report of April 2012 to the Secretary of Education, https://
www2.ed.gov/about/bdscomm/list/naciqi-dir/2012-spring/telecon-
ference-2012/naciqi-final-report.pdf, an alternative recommendation is
offered (see page 13) that emphasizes a new set of transparency
protocols.
Accreditors, who currently serve as both gatekeepers to title IV
funds and as peer-reviewers, have failed to demonstrate any commitment
or expertise in collecting and clearly disseminating such information.
Access to title IV funds should depend upon meeting Federal disclosure
requirements and such thresholds as Congress may deem appropriate.
Accreditors can then focus on their traditional role of peer review,
self-improvement, and the dissemination of best practices.
[Whereupon, at 11:44 a.m., the hearing was adjourned.]
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