A Seal We Can Trust

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1 Center or American Progress | A Seal We Can Trust

A Seal We Can Trust

How to Improve the College Accreditation System toGuarantee Quality for Students and Taxpayers

Julie Margetta Morgan June 2011

Introduction and summary

Wha makes a college a college? Tese days, anyone wih a decen compuer can designa ancy seal wih a phrase like “Ever o Excel” or “Te Way, he ruh, he Ligh” on i

in Greek or Lain and sar prining diplomas. And wih he adven o online educa-

ion, a college can ourish wihou an ivy-covered campus—or any campus a all. I

he radiional marks o legiimacy—a campus, a library, dozens o sudens wandering

around in “Universiy o” sweashirs—are no reliable, sudens need anoher symbol

o wheher an insiuion is providing a qualiy educaional experience. And he ederal

governmen needs a way o disinguish beween universiies ha will be good sewards

o nancial aid dollars and hose ha will no.

In he pas, sudens, policymakers, and insiuions relied on accrediaion o disin-guish good colleges rom bad ones. Accrediing agencies devise sandards or colleges

and employ a sysem o sel-sudy and peer review o deermine wheher educaional

insiuions are worhy o heir seal o approval. Te radiion o accrediaion was so

esablished as a measure o qualiy ha Congress adoped accrediaion as a precondi-

ion or insiuions seeking o paricipae in ederal suden aid programs.

oday, however, accrediaion is no so revered. Since he 1992 amendmens o he

Higher Educaion Ac here have been rumblings in he policy world ha accrediors are

no he cusodians o college qualiy hey were hough o be. And he recen atenion

o accredied or-pro colleges brings he weigh o evidence o ha asserion, wih

gures like a 9 percen graduaion rae or bachelor’s degree programs a Universiy o

Phoenix and a 69 percen wihdrawal rae a Kaplan colleges.1

I he accrediaion sysem is no broken hen how can such insiuions sill be

operaing wih accredied saus and he access o ederal dollars ha accompanies i?




Accrediaion is a hugely imporan issue in ederal higher educaion policy. Firs, i is

a gaeway o ederal nancial assisance. Bu i ails o proec he ederal invesmen

hrough boh overinclusiveness and underinclusiveness. Accrediors allow insiuions

wih alarmingly low graduaion raes or high suden loan deaul raes o persis in

accessing nancial aid ye hey ac as a barrier o innovaive educaion providers who do

no he sandard model o “wha a college should look like.”

And second, accrediaion is one o he primary measures o consumer proecion in

higher educaion. Ye when accrediors give heir seal o colleges ha provide litle value,

sudens are unproeced, and hey are led o believe ha hese underperorming insiu-

ions are o equal qualiy o oher colleges and universiies.

Many organizaions weighed in on he accrediaion problem in he pas several years. In

ac, he U.S. Deparmen o Educaion’s Naional Advisory Commitee on Insiuional

Qualiy and Inegriy, or NACIQI—a group charged wih approving accrediing agen-

cies and suggesing changes o he ederal requiremens placed upon hem—convened a

group o expers in February and anoher in June o discuss he uure o accrediaion andhe role o he ederal governmen. Te expers oered some suggesions ha will grealy

improve accrediaion. Bu here are some addiional seps ha should be aken o su-

cienly assess college qualiy and o ensure ha accrediors mee he governmen’s needs.

Tis brie describes wha accrediaion is and he aws inheren in he sysem. I argues

ha he bes accrediaion sysem is one ha recognizes and mees he ederal govern-

men’s needs or boh qualiy assurance and coninuous qualiy improvemen. I is also

one ha borrows rom service qualiy heory by considering how sudens inerac wih

colleges—he processes, heir expecaions, and heir percepions o qualiy—when

evaluaing he overall qualiy o an insiuion.

In he las reauhorizaion o he Higher Educaion Ac, Congress responded o con-

cerns abou he qualiy o higher educaion by charging he Deparmen o Educaion’s

NACIQI commitee wih making recommendaions on how o change he accredia-

ion sysem. We recommend ha NACIQI sugges he ollowing changes o Congress’s

requiremens or accrediing agencies o promoe beter insiuional qualiy or su-

dens and proec axpayers’ invesmens in higher educaion:

• Congress should require ha accrediors clariy he sandards hey employ or

coninuous qualiy improvemen. I should also require ha hese sandards include

measures o increase colleges’ produciviy and decrease he price o educaion o

maximize is value.

• Congress should also require ha accrediors ideniy benchmarks or qualiy

improvemen and measure heir progress a helping colleges improve based upon

hese benchmarks.




• Congress should require ha accrediors creae more sringen sandards or qualiy

assurance by seting sandards or suden learning oucomes wih clear cuos below

which colleges lose heir accredied saus.

• Congress should require ha accrediors incorporae measures o service qualiy ha

evaluae how sudens respond o he services oered by colleges, including measures

o suden saisacion.

• Congress should require greaer ransparency rom accrediors in he ollowing ways: – Accrediors should make he repors rom heir sie visis available o he public

so ha policymakers can assess wheher oher changes are necessary in he

accrediaion process and so ha ineresed consumers can ake a deeper look a

how colleges measure up. – Accrediors should make available o he public he merics hey use o evaluae

colleges, including suden learning measures, employmen raes, and suden

saisacion raes. Tese should be available separae rom accredior’s repors, and

he Deparmen o Educaion should ensure ha he inormaion is available in aconsumer-riendly orma.

Determinations of quality matter

Deerminaions o qualiy can be enormously helpul o consumers, especially when

hey come rom a proessional amiliar wih a produc or service. Consumers rely on

hese deerminaions when hey do no have he experise or he access necessary o

judge qualiy or hemselves.

For insance, many rely on he American Denal Associaion’s seal o approval when

buying a ube o oohpase. oohpase companies proudly display his seal and eaure

i in heir adverisemens. Consumers do no really know wha i akes o be approved.

All ha maters is ha ADA approval signals a qualiy denal produc, and by relying on

he seal, consumers can res assured ha hey are choosing a oohpase or oohbrush

ha will help and no harm hem. Tey are hen ree o make choices among a variey o

opions based on preerences like avor, whiening power, and dispenser syle.

Now imagine here are many dieren seals o approval he nex ime you buy ooh-

pase. In addiion o he ADA, here’s a CDA, he Council o American Deniss; an

NDA, he Naional Deniss Associaion; and even a CED, he Commitee or Excellen

Denisry. As a consumer, you probably jus wan o buy a ube o oohpase relaively

quickly and eel good ha a proessional approves o i.

Bu do hese organizaions all adhere o he same sandards as he ADA? Or do some use

higher or lower sandards? And should you really be expeced o know he dierence?




Le’s say you relied on he NDA seal only o nd your eeh riddled wih caviies. Bu he

NDA claims i’s no o blame because i’s no really ineresed in ceriying good ooh-

pases bu in helping he companies i works wih become beter oohpase providers.

Now, i may slightly miigae he circumsances i he NDA, CED, and ADA all le con-

sumers see he echnical repors hey wrie up when evaluaing each brand (assuming

you had he ime o read hem). Bu wha i hey won’ even do ha?

Well, hen hey’d be exacly like higher educaion accrediing agencies.

A leas 10 dieren bodies accredi higher educaion insiuions, and each uses a dier-

en se o sandards o do so. Tough he accrediors give each insiuion heir “seal o

approval,” hey claim o be mosly in he business o coninuous qualiy improvemen

raher han rubber-samping insiuions based upon heir qualiy a any given poin in

ime. And accrediors conduc largely condenial reviews o organizaions ha ocus

on he resources he insiuions possess raher han he learning is sudens achieve.2

Resources can give some indicaion o qualiy, bu hey do no ell he whole sory.

I he above example sounded like a silly sysem or approving oohpases, i’s even sil-

lier or higher educaion because consumers rely on ha sysem, and he ederal govern-

men uses i o deermine which colleges are deserving o is suden aid. Wih so much

riding on accrediaion, policymakers are wondering wheher he sysem can be xed so

ha i works beter or sudens and axpayers.

What is accreditation, anyway?

Accrediaion is a process o evaluaing possecondary insiuions based upon

dened sandards. Possecondary accrediaion’s purposes are qualiy assurance

and qualiy improvemen.

O course, here are many dieren ways o dene qualiy. According o he Council or

Higher Educaion Accrediaion, accrediing agencies base heir judgmens o qualiy

on he insiuion’s mission. For insance, he New England Associaion o Schools and

Colleges’ Commission on Insiuions o Higher Educaion saes ha successul insiu-

ions have clearly dened purposes, he resources o achieve hose purposes, and are in

ac achieving heir saed purposes.3

Tere are echnically wo disinc ypes o accrediaion: program accrediaion and

insiuional accrediaion. Insiuional accrediaion is a general seal o approval or

he enire insiuion, while program-level accrediaion is a more horough review o

he qualiy o a paricular educaional program (e.g., nursing).




A commitee aliaed wih he leading proessional organizaion in a paricular eld

ypically perorms program-level accrediaion. Mos colleges pursue insiuional

accrediaion and only seek program-level accrediaion when sudens in ha program

mus atend an accredied program as a prerequisie o pracice wihin a eld. For

insance, mos law schools pursue accrediaion by he American Bar Associaion’s

Accrediaion Commitee because atendance a an accredied school is necessary or

admission o he bar in many saes.

Insiuional accrediaion is he precursor or paricipaion in ederal suden loan and

gran programs (more deail on his below). Tis paper ocuses on insiuional accredia-

ion since i is primarily concerned wih he ederal policy implicaions o accrediaion.

How it works

Insiuional accrediing organizaions generally have boh a permanen sa and a

commission or oher decision-making board ha consiss o persons eleced by memberinsiuions. Te decision-making bodies are comprised primarily o academics and

adminisraors rom member insiuions, along wih a ew public represenaives. Te

organizaions se heir own sandards or accrediaion and evaluae insiuions accord-

ing o hese sandards.

Each insiuion mus undergo an iniial evaluaion and subsequen ollow-ups over he

years (ypically every 10 years). Evaluaions consis o a sel-sudy in which an insiu-

ion examines how is programs and operaions measure up o he accredior’s sandards

and a eam visi in which a group o aculy members and adminisraors designaed by

he accrediing agency perorms is own evaluaion o he insiuion hrough inerviewsand documen review.

Why do institutions pursue accreditation?

Accrediaion is a volunary process. So why do colleges and universiies voluneer or

such scruiny? Tere are a ew possible reasons.

Te accrediaion process ceries he qualiy o insiuions or academic programs

and provides guidance o hem on coninuous qualiy improvemen, according o he

Council on Higher Educaion Accrediaion, an organizaion ha promoes he use o

volunary accrediaion in he Unied Saes. Some insiuions may ge accredied o

receive echnical assisance in heir pursui o qualiy. Bu i’s likely ha mos colleges

and universiies pursue accrediaion or he accredior’s seal o approval.




Ta’s because his rubber samp o qualiy helps insiuions atrac sudens and signals

he legiimacy o an academic degree o poenial employers. A suden’s atendance a

an accredied insiuion also ofen serves as a precursor o urher graduae educaion

or enry ino cerain proessionalized elds. In addiion, accrediaion encourages he

ranser o credi rom one insiuion o anoher. In ac, he original purpose o accredi-

aion was o help colleges deermine he qualiy o he educaion received by sudens

who migraed rom oher colleges or schools.

Finally, accrediaion’s mos angible bene is likely he access i provides o ederal

unding. Accrediors ha are recognized by he U.S. Deparmen o Educaion serve

as gaekeepers o ederal nancial aid programs. Colleges and universiies who seek o

oer ederal suden loans, Pell Grans, or oher aid programs o heir sudens mus be

approved as qualiy insiuions by an accrediing agency.

Standards of accreditation

Tere are many similariies among he sandards employed or accrediaion even

hough each accrediing agency may deermine is own. As menioned earlier, accredi-

ors base heir qualiy decisions on he insiuion’s mission. o be recognized by he

Deparmen o Educaion, however, accrediing agencies mus also mainain sandards

peraining o he ollowing aspecs o possecondary insiuions:

• Success wih suden achievemen• Curricula• Faculy •

Faciliies and equipmen• Fiscal and adminisraive capaciy • Suden suppor services• Recruimen and admissions pracices, academic calendars, caalogs, publicaions,

grading, and adverising• Measures o program lengh and objecives o he degrees or credenials oered• Record o suden complains• Record o compliance wih ile IV responsibiliies4

Accrediing agencies comply wih he ederal requiremens bu say rue o he cenraliy

o he insiuional mission by evaluaing each o hese areas based upon how well he

insiuion’s progress in ha area compors wih is mission.

For insance, he New England Associaion o Schools and Colleges’ sandards or higher

educaion accrediaion include requiremens or organizaion and governance ha begin

wih: “Te insiuion has a sysem o governance ha aciliaes he accomplishmen o

is mission and purposes and suppors insiuional eeciveness and inegriy.”




And he Wesern Associaion o Schools and Colleges’ sandard on achieving educa-

ional objecives sars wih: “Te insiuion achieves is insiuional purposes and

atains is educaional objecives hrough he core uncions o eaching and learning,

scholarship and creaive aciviy, and suppor or suden learning and success.”5

wo observaions abou he sandards accrediors use are relevan o his paper. Firs,

hough he agencies’ sandards or accrediaion do no dicae any paricular orm or acollege—aside rom he idea ha i should have a aculy and a curriculum—hey leave

much o he discreion o he sie visiors and he accrediaion commission or board.

Te wide discreion means ha accrediing agencies can have inconsisen resuls. Some

colleges nd accrediaion o be an excellen experience ha pushes hem oward

improvemen while ohers recoun sories like NACIQI commitee member Wilred

McClay’s experience in which an accredior inexplicably required his insiuion o

change is mission saemen because i was oo old.6 And colleges ha oer unique or

innovaive educaional programs ha do no look like wha we generally hink o as “col-

lege”—or example, insiuions ha oer courses based upon compeencies, no credihours, or hose ha do no have a physical campus—have diculies wih he accredia-

ion process, possibly because accrediors are more suspicious o educaional delivery

orms ha look so dieren rom he norm.

Te second observaion is ha he sandards accrediors use do no lend hemselves o

brigh-line cuos or a yes/no choice on wheher o accredi a college.

Te mehod accrediors use or deermining qualiy o an insiuion, or wheher ha

insiuion meris he gold seal o accredied saus, is more like he way proessors grade

papers han i is he way a car manuacurer deermines wheher an auomobile is sae odrive. Proessors have crieria or judging erm papers, bu sudens ofen don’ have any

indicaion o wha separaes a D rom an F. And hey may even ge he sneaking suspi-

cion ha acors like randomness or avoriism inuence he oucome. In auomobile

qualiy conrol, however, here are specic sandards a car mus mee, and ailure on a

given sandard amouns o an overall ailure o qualiy. In oher words, here are brigh-

line sandards o wha is accepable and wha is no.

Wih accrediors, we don’ have such brigh lines even when i comes o suden ou-

comes such as graduaion raes or suden learning measures. So, or example, accred-

iing sandards on suden learning say hings such as “Te organizaion provides

evidence o suden learning…ha demonsraes i is ullling is educaional mission”

no “he organizaion ensures ha a leas 60 percen o is sudens achieve prociency

on a widely recognized insrumen ha measures learning.”




Federal role and funding model

I’s worh elaboraing urher on he connecion beween accrediing agencies and he

ederal governmen because i provides insigh ino how ha connecion migh need o

change. When he ederal governmen began using public money o help low-income

sudens gain access o college, i made he decision o allow sudens o choose where

hey would use his money. Since sudens would be deciding how ederal dollars were

spen, he governmen needed a mechanism or ensuring ha hese axpayer dollars were being handled properly and ha he insiuions o which sudens brough he

money were o sucien qualiy.7

Raher han engaging in is own qualiy review—an arduous, expensive process ha

would pu he governmen in a posiion o commening on curricula—he ederal

governmen urned o accrediing agencies. Accredied saus became a precondiion o

paricipaing in he nancial aid programs conained in ile IV o he Higher Educaion

Ac, including he Pell Gran program and he ederal suden loan program.8

Congress was able o co-op his qualiy assurance sysem essenially or ree since heaccrediaion process exised beore he ederal role in higher educaion. Colleges pay

accrediors an iniial ee o become accredied as well as an annual membership ee

based on insiuional size and ofen pay inermiten ees or services such as special sie

visis.9 Te ederal governmen’s role in his nancing scheme, arguably, is o ensure a

coninual sream o cusomers or he accrediing agencies.

Tis migh sound like a win-win arrangemen. Bu here are a ew aws. Firs, since

he governmen does no conrac direcly wih he accrediors i does no have a clear

mechanism or conrolling wha accrediors do. Insead, Congress insiued a process in

which accrediors mus be approved by he Deparmen o Educaion in order o serveas gaekeepers o suden aid.

And o make maters more complicaed, i incorporaed a commitee ha advises he

deparmen on recogniion o accrediing agencies: he Naional Advisory Commitee

on Insiuional Qualiy and Inegriy. Mos members o he NACIQI commitee are

senior adminisraors a colleges or sae higher educaion sysems. So he mechanism o

conrol over qualiy is asking a group o higher educaion leaders o monior how oher

groups o higher educaion leaders monior he behavior o heir peers’ insiuions.

Anoher problem wih using accrediors o ensure he inegriy o he ederal nancial

aid program is ha he incenives ha guide accrediors’ acions do no align wih

having black-and-whie, high sandards or qualiy. Tere are 17 accrediing agencies

recognized by he Deparmen o Educaion o accredi insiuions.10 Since colleges

have heir choice among agencies—as well as he choice o orm a new agency—here

is litle incenive o be he accredior wih he mos sringen sandards. And accrediing

agencies have heir own ideas abou wha hey should be doing since hey predae heir

adopion as ederal qualiy insurers.




As he ederal invesmen in nancial aid or higher educaion grew, however, so did he

ederal governmen’s concern ha he accrediaion process did no guaranee qualiy. I

began o place more requiremens on accrediors o ensure ha hey ullled he qualiy

assurance role ha Congress imposed on hem.

For insance, he Deparmen o Educaion requires recognized accrediing agencies o

have a cerain number o public represenaives on heir boards and o submi copies o heir annual repors o he deparmen. Congress and he Deparmen o Educaion also

began pursuing measures o promoe qualiy in higher educaion ouside o accredia-

ion, including gran programs o boos college perormance and innovaion, as well as

more direc regulaion like he new gainul employmen measure ha promoes beter

resuls a career educaion programs.

Is accreditation broken?

I is very common hese days o poin o accrediaion as he source o—and solu-ion o—he ailings o he higher educaion sysem.11 Kevin Carey, policy direcor a

Educaion Secor, poins ou ha he Senae’s recen invesigaion ino raud and abuse a

or-pro colleges amouns o an implici criique o he accrediaion sysem. And many

problems ha arise in higher educaion can be seen as a ailure o qualiy assurance.

Te low graduaion raes a many communiy colleges and or-pro colleges, as well as

some our-year insiuions, are a signal ha he qualiy o he services oered a hose

insiuions may no be up o par. Likewise, he rising suden loan deaul rae a many

or-pro insiuions may be a sign ha sudens are no geting a sucien educaion o

pay heir deb upon graduaion. And Richard Arum and Josipa Roksa’s book Academically Adrif ha analyzes he resuls o he Collegiae Learning Assessmen suggess ha su-

dens are no learning very much a many o our naion’s our-year colleges.12

Aside rom hese indicaors, here are oher reasons o quesion he inegriy o he accred-

iing process. In recen years, i became common or or-pro companies o circumven

he long process o acquiring accrediaion and qualiying or ederal nancial aid by buy-

ing colleges ha already have accrediaion. Accrediors allowed his process o go on rela-

ively unchecked, wih companies buying colleges and increasing heir enrollmen rom

2,000 o 30,000 in a mater o years.13 And some accrediing agencies have been allowing

colleges o award credi ha is inconsisen wih he amoun o ime sudens spen on

learning, resuling in a ederal crackdown on how colleges can dene college credi.14

I’s dicul or ousiders o pinpoin where he aws lie in he accrediaion process

because i occurs largely in secrecy. Agencies believe ha he condenialiy o accredia-

ion is essenial because i encourages colleges o share inormaion abou heir qualiy

ha hey would no oherwise divulge. As a resul, colleges may make heir sel-sudy and




peer review repors available o he public, bu hey need no do so. Mos publish heir

sel-sudy repors bu do no divulge he peer review sie visi repors compleed by he

accrediing bodies, likely because he peer repors are more criical o he insiuions.

Te sandards accrediors apply when reviewing insiuions are available even hough

heir repors are no public. And hese sandards reveal wo key aws ha policymakers

and academics increasingly poin ou. Firs, he sandards o accrediaion are almosenirely based on inpus, no oucomes. Ta is, accrediaion emphasizes he resources

a college mainains or educaing is sudens wih a lesser ocus on wheher sudens

acually learn anyhing.

One oher aw in accrediaion is very clear: Accrediors do no employ minimum qual-

iy sandards. Tere are no cuos in erms o universiy perormance below which an

insiuion may no access ederal nancial assisance. Many have argued ha o mee

he qualiy assurance ha he ederal governmen requires, accrediors mus deermine

minimum perormance sandards ha a college or universiy mus mee. Tese peror-

mance measures should be sandard across all insiuions in a given secor.

Te nal problem wih accrediaion—a leas rom he ederal perspecive—is is

dual mission o qualiy assurance and coninuous qualiy improvemen. o secure he

invesmen in ederal nancial aid, he governmen needs accrediors o make absolue

decisions abou qualiy and cu o accredied saus when an insiuion alls below

minimum levels. Bu because accrediors avor he qualiy improvemen uncion, hey

end o allow insiuions o mainain heir accredied saus while rying o improve.

Can it be fixed?

I he las NACIQI meeing is any indicaion, he general senimen in he higher

educaion communiy hese days is no wheher accrediaion can be xed, bu how.15

Raher han arguing or a oal overhaul o ederal qualiy assurance, he speakers sug-

gesed ha changes could be made o he accrediaion sysem o help i beter serve

ederal purposes.16 Te major proposals on he able mirror he aws idenied in he

previous secion.

Firs, many argue ha accrediors mus impose oucome-based sandards wih cuos

ha resul in rescinding accredied saus.

Nex, hey asser ha ransparency is key o improving accrediaion. I accrediors make

heir judgmens available o he public, hen boh policymakers and sudens will gain a

beter undersanding o college qualiy.




Finally, some higher educaion leaders argue ha accrediors need o separae ou he

qualiy assurance uncion rom he coninuous qualiy improvemen uncion. I is no

really clear how his would work. Bu he senimen behind i seems o be ha creaing

a clear division beween he wo uncions would help ensure ha accrediors acually

perorm he qualiy assurance ha he ederal governmen requires o hem.

Each o hese suggesions has he poenial o improve he accrediaion sysem. Buhey require elaboraion. In paricular, any suggesions o x accrediaion should ake

ino accoun wha he ederal governmen wans ou o accrediaion and wha i akes

o evaluae he qualiy o a service.

Te ollowing secions consider hese recommendaions and build upon hem

based on he governmen’s need or a balance beween qualiy assurance and qualiy

improvemen, and proven mehods o service qualiy evaluaion ha can enhance he

accrediaion process.

Protecting the federal investment requires both quality assurance and

quality improvement

I is increasingly imporan o ensure ha ederal dollars or higher educaion are well

spen wih more han $30 billion invesed in he Pell Gran program and over $100 bil-

lion in new ederal suden lending in 2010.17 Proecing he ederal invesmen includes

direcing he money oward colleges and universiies ha provide a leas a minimum

level o qualiy. And he argumen ha accrediors need o emphasize heir role as assur-

ers o minimum qualiy is aking hold.

One migh assume ha here is no need o worry abou how he accrediors are a

qualiy improvemen, as accrediors seem so conden in heir esablished role in his

space. Bu he ederal invesmen is bes proeced i accrediors are good a boh qualiy

assurance and qualiy improvemen.

Te hing is, seting minimum cuos or suden oucomes will help wih qualiy assur-

ance, bu i will no bring abou greaer produciviy or beter value in higher educaion.

In ac, i accrediors rescind accrediaion abruply—even wih some phase-ou pro-

gram—based upon ailure o mee oucomes sandards, hose colleges will lose access

o ederal nancial aid—a virual deah senence or many insiuions ha rely on aid

programs o make college aordable or heir sudens. And since he ederal govern-

men is rying o ge more people hrough college, no ewer, closing colleges is he very

opposie o produciviy.

Insead, he governmen needs accrediors o mainain minimum sandards bu also

ensure ha colleges do no all below hem. In oher words, hey should balance qualiy

assurance wih coninuous qualiy improvemen.




Accrediors sae ha qualiy improvemen is a undamenal par o heir business model

oday. Bu he sae o American higher educaion indicaes oherwise. I accrediors

were coninuously improving he qualiy o colleges and universiies hen hose insiu-

ions ha have exised or more han a ew years would be o ver y good qualiy—and

many o hem are no.18

So while he accrediaion process should coninue o emphasize qualiy improvemen,ha uncion needs o be beter dened and measured.

Te NACIQI commitee should require ha accrediors se sandards and goals or

coninuous qualiy improvemen ha emphasize increased produciviy and value.

Tey should require ha accrediors se benchmarks or produciviy and value such as

reenion raes, graduaion raes, and cos per degree and develop a plan or helping col-

leges mee hem. Te mechanism or qualiy improvemen should be more han ad hoc

judgmens by an accrediing commitee. Raher, accrediors should ideniy promising

pracices a colleges who measure up o is benchmarks and advise oher insiuions as

o how hese pracices migh be adaped.

Beter inormaion or he public can also be seen as a measure o coninuous qual-

iy improvemen. By providing public inormaion abou how colleges measure up

on suden learning oucomes, cos, suden saisacion, and employmen oucomes,

accrediors can conribue o a higher educaion marke where colleges compee on real

atribues o he services hey oer raher han on repuaion alone.

o ha end, NACIQI should sugges ha Congress require accrediors o make such

measures available o he public on he Deparmen o Educaion’s websie.

Service quality is more than output measures

Te suggesion ha accrediors begin ocusing more on oupu measures is a good sep

in moving away rom viewing higher educaion as a good o be produced and oward

hinking o i as a service.

In manuacuring goods, he resources and processes ha go ino producion can be a

good indicaion o he qualiy o he nal produc. Bu in service indusries, he service

providers’ inpus canno be he primary measure o qualiy. Services are co-consruced

by he provider and he cusomer. Ta is, he cusomer’s inpu ino he process also

deermines he overall qualiy o he oupu. Te cusomer’s (suden’s) inpus include

his or her capabiliies and moivaions as well as his or her expecaions or wha he

nal resul o he service will be.




Measuring he qualiy o services has always been a ricky business. Bu here are some

general principles. Since boh he cusomer and he service provider co-creae he service,

boh o heir expecaions and percepions o he experience are relevan when measuring

service qualiy. Sel-sudy by he insiuions helps accrediors undersand he college’s

expecaions and is evaluaion o how i measures up. Bu here is no similar expression

o how sudens perceive he qualiy o a college. Accrediors can make more circumspec

judgmens abou he qualiy o he services he college provides by incorporaing bohhe sudens’ and he colleges’ percepions ino he accrediaion evaluaion.

Incorporaing conceps rom he measuremen o service qualiy ino he accredia-

ion process recognizes he ac ha he producion and consumpion o a service are

inseparable. One canno evaluae he services colleges provide wihou considering he

conac beween he college and he suden.

Harvard, or example, is only a high-qualiy educaional insiuion because he services

i oers work well or he majoriy o he sudens i admis. I he suden body o he

local communiy college suddenly supplaned he suden body a Harvard we mighhave very dieren judgmens abou is qualiy because he services i oers would no

work well or is new suden body.

Conclusion and recommendations

Tis paper idenies some undamenal aws in using he accrediing process as a

gaekeeper o ederal nancial aid, including he lack o ransparency, he ocus on

inpus bu no oucomes, and he emphasis on coninuous qualiy improvemen

raher han qualiy assurance.

Te simple xes or hese problems are o increase ransparency, ocus on oucomes, and

emphasize qualiy assurance. Bu simply doing so would no mee he ederal govern-

men’s undamenal need o assure ha i is invesing is nancial aid dollars in qualiy

educaional programs while also producing an increasing number o possecondary

compleers a relaively low cos.

Insead, he paper argues ha accrediaion should be xed by nding a balance beween

qualiy improvemen and qualiy assurance and by incorporaing conceps o service

qualiy ino he assessmen o college qualiy.

Congress asked he Deparmen o Educaion’s NACIQI commitee wih making

recommendaions on how o improve he higher educaion accrediaion process. We

sugges ha NACIQI recommend he ollowing based on our analysis in his brie:




• Congress should require ha accrediors clariy he sandards hey employ or

coninuous qualiy improvemen. I should also require ha hese sandards include

measures o increase colleges’ produciviy and decrease he price o educaion o

maximize is value.

• Congress should also require ha accrediors ideniy benchmarks or qualiy

improvemen and measure heir progress a helping colleges improve based uponhese benchmarks.

• Congress should require ha accrediors creae more sringen sandards or qualiy

assurance by seting sandards or suden learning oucomes wih clear cuos below

which colleges lose heir accredied saus.

• Congress should require ha accrediors incorporae measures o service qualiy ha

evaluae how sudens respond o he services oered by colleges, including measures

o suden saisacion.

• Congress should require greaer ransparency rom accrediors in he ollowing ways: – Accrediors should make he repors rom heir sie visis available o he public so

ha policymakers can assess wheher oher changes are necessary in he accredia-

ion process, and so ha ineresed consumers can ake a deeper look a how col-

leges measure up. – Accrediors should make available o he public he merics hey use o evaluae

colleges, including suden learning measures, employmen raes, and suden

saisacion raes. Tese should be available separae rom accredior’s repors, and

he Deparmen o Educaion should ensure ha he inormaion is available in a

consumer-riendly orma.



Endnotes

1 United States Senate Health Education Labor and Pensions Committee, “The Return on the Federal Investment in For-ProtEducation: Debt Without a Diploma” (2010); The Education Trust, “Subprime Opportunity ” (2010).

2 Accreditors are required to make public the reasons or denying or rescinding accreditation rom an institution.

3 New England Association o Schools and Colleges Commission on Institutions o Higher Education, “Standards or Accreditation”(2006), available at http://cihe.neasc.org/downloads/Standards/Standards_or_Accreditation__2006.pd .

4 U.S. Department o Education, “Accreditation in the United States, Subpart B: The Criteria or Recognition,” available at http://

www2.ed.gov/admins/naid/accred/accreditation_pg13.html#RecognitionCriteria.

5 Western Association o Schools and Colleges Accrediting Commission or Senior Colleges and Universities, “Handbook o Accredi-tation” (2008), available at http://www.wascsenior.org/ndit/les/orms/Handbook_o_Accreditation_2008_with_hyperlinks.pd.

6 National Advisory Committee on Institutional Quality and Integrity, Meeting on the Challenges and Perspectives on Quality inHigher Education, 2011, http://www2.ed.gov/about/bdscomm/list/naciqi-dir/appdx-a-naciqieb2011.pd

7 Testimony o Eduardo Ochoa at NACIQI meeting, February 2011.

8 Judith Eaton, “Accreditation and the Federal Future o Higher Education,” available at http://www.aaup.org/AAUP/pubsres/aca-deme/2010/SO/eat/eato.htm

9 Higher Learning Commission, “Dues and Fees Schedule or 2009-2010” (2009); Western Association o Schools and Colleges Ac-crediting Commission or Senior Coll eges and Universities, “Schedule o Dues and Fees 2010-2011” (2010).

10 U.S. Department o Education, “Accreditation in the United States” (2011), available at http://ww w2.ed.gov/admins/naid/accred/accreditation_pg6.html.

11 Kevin Carey, “Asleep at the Seal,”Washington Monthly, March/April 2010, available at http://www.washingtonmonthly.com/ea-

tures/2010/1003.carey.html; Andrew Gillen, Daniel Bennett and Richard Vedder, “The Inmates Running the Asylum?” (2010), avail-able at http://centerorcollegeaordability.org/research/studies/the-inmates-running-the-asylum; Senator Tom Harkin, “HarkinQuestions Accreditation and Oversight o For-Prot Colleges,” Press Release, March 10, 2011, available at http://harkin.senate.gov/press/release.cm?i=331821.

12 Richard Arum and Josipa Roksa, Academically Adrift (Chicago: University o Chicago Press, 2011).

13 Daniel Golden, “How Colleges Are Buying Respect,”Bloomberg Businessweek , March 4, 2010, available at http://www.businessweek.com/magazine/content/10_11/b4170050344129_page_2.htm.

14 Derek Quizon, “College Ofcials Ask Congress to Roll Back New Education Department Rules,” Chronicle of Higher Education, March11, 2011, available at http://chronicle.com/article/Administrators-Ask-Congress-to/126722/.

15 National Advisory Committee on Institutional Quality and Integrity, “Meeting on the Challenges and Perspectives on Quality inHigher Education” (2011).

16 Doug Lederman, “Mend It, Don’t End It,”Inside Higher Ed , February 4, 2011, available at http://www.insidehighered.com/news/2011/02/04/education_department_panel_hears_ideas_about_improving_higher_education_accreditation.

17 U.S. Department o Education, “Student Loans Overview, Fiscal Year 2012 Budget Request” (2011), available at www2.ed.gov/

about/overview/budget/budget12/.../s-loansoverview.pdf; Equal Justice Works, “Pell Grants Survive Federal Budget Process,” US Newsand World Report, April 20, 2011, available at http://www.usnews.com/education/blogs/student-loan-ranger/2011/04/20/pell-grants-survive-federal-budget-process.

18 Arum and Roksa, 2011.

http://cihe.neasc.org/downloads/Standards/Standards_for_Accreditation__2006.pdf

http://www2.ed.gov/about/bdscomm/list/naciqi-dir/appdx-a-naciqifeb2011.pdf

http://www.aaup.org/AAUP/pubsres/academe/2010/SO/feat/eato.htm


http://www.washingtonmonthly.com/features/2010/1003.carey.html


http://centerforcollegeaffordability.org/research/studies/the-inmates-running-the-asylum

http://harkin.senate.gov/press/release.cfm?i=331821


http://www.insidehighered.com/news/2011/02/04/education_department_panel_hears_ideas_about_improving_higher_education_accreditation






http://centerforcollegeaffordability.org/research/studies/the-inmates-running-the-asylum





http://www2.ed.gov/about/bdscomm/list/naciqi-dir/appdx-a-naciqifeb2011.pdf

http://cihe.neasc.org/downloads/Standards/Standards_for_Accreditation__2006.pdf

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