[House Hearing, 113 Congress]
[From the U.S. Government Publishing Office]
KEEPING COLLEGE WITHIN REACH: DISCUSSING PROGRAM QUALITY THROUGH
ACCREDITATION
=======================================================================
HEARING
before the
SUBCOMMITTEE ON HIGHER EDUCATION
AND WORKFORCE TRAINING
COMMITTEE ON EDUCATION
AND THE WORKFORCE
U.S. House of Representatives
ONE HUNDRED THIRTEENTH CONGRESS
FIRST SESSION
__________
HEARING HELD IN WASHINGTON, DC, JUNE 13, 2013
__________
Serial No. 113-22
__________
Printed for the use of the Committee on Education and the Workforce
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
Available via the World Wide Web:
www.gpo.gov/fdsys/browse/
committee.action?chamber=house&committee=education
or
Committee address: http://edworkforce.house.gov
_____
U.S. GOVERNMENT PRINTING OFFICE
81-336 PDF WASHINGTON : 2013
-----------------------------------------------------------------------
For sale by the Superintendent of Documents, U.S. Government Printing
Office Internet: bookstore.gpo.gov Phone: toll free (866) 512-1800; DC
area (202) 512-1800 Fax: (202) 512-2104 Mail: Stop IDCC, Washington, DC
20402-0001
COMMITTEE ON EDUCATION AND THE WORKFORCE
JOHN KLINE, Minnesota, Chairman
Thomas E. Petri, Wisconsin George Miller, California,
Howard P. ``Buck'' McKeon, Senior Democratic Member
California Robert E. Andrews, New Jersey
Joe Wilson, South Carolina Robert C. ``Bobby'' Scott,
Virginia Foxx, North Carolina Virginia
Tom Price, Georgia Ruben Hinojosa, Texas
Kenny Marchant, Texas Carolyn McCarthy, New York
Duncan Hunter, California John F. Tierney, Massachusetts
David P. Roe, Tennessee Rush Holt, New Jersey
Glenn Thompson, Pennsylvania Susan A. Davis, California
Tim Walberg, Michigan Raul M. Grijalva, Arizona
Matt Salmon, Arizona Timothy H. Bishop, New York
Brett Guthrie, Kentucky David Loebsack, Iowa
Scott DesJarlais, Tennessee Joe Courtney, Connecticut
Todd Rokita, Indiana Marcia L. Fudge, Ohio
Larry Bucshon, Indiana Jared Polis, Colorado
Trey Gowdy, South Carolina Gregorio Kilili Camacho Sablan,
Lou Barletta, Pennsylvania Northern Mariana Islands
Martha Roby, Alabama John A. Yarmuth, Kentucky
Joseph J. Heck, Nevada Frederica S. Wilson, Florida
Susan W. Brooks, Indiana Suzanne Bonamici, Oregon
Richard Hudson, North Carolina
Luke Messer, Indiana
Juliane Sullivan, Staff Director
Jody Calemine, Minority Staff Director
------
SUBCOMMITTEE ON HIGHER EDUCATION AND WORKFORCE TRAINING
VIRGINIA FOXX, North Carolina, Chairwoman
Thomas E. Petri, Wisconsin Ruben Hinojosa, Texas,
Howard P. ``Buck'' McKeon, Ranking Minority Member
California John F. Tierney, Massachusetts
Glenn Thompson, Pennsylvania Timothy H. Bishop, New York
Tim Walberg, Michigan John A. Yarmuth, Kentucky
Matt Salmon, Arizona Suzanne Bonamici, Oregon
Brett Guthrie, Kentucky Carolyn McCarthy, New York
Lou Barletta, Pennsylvania Rush Holt, New Jersey
Joseph J. Heck, Nevada Susan A. Davis, California
Susan W. Brooks, Indiana David Loebsack, Iowa
Richard Hudson, North Carolina
Luke Messer, Indiana
C O N T E N T S
----------
Page
Hearing held on June 13, 2013.................................... 1
Statement of Members:
Foxx, Hon. Virginia, Chairwoman, Subcommittee on Higher
Education and Workforce Training........................... 1
Prepared statement of.................................... 3
Hinojosa, Hon. Ruben, ranking minority member, Subcommittee
on Higher Education and Workforce Training................. 4
Prepared statement of.................................... 5
Statement of Witnesses:
Carey, Kevin, director, Education Policy Program, New America
Foundation................................................. 32
Prepared statement of.................................... 34
McComis, Dr. Michale S., executive director, Accrediting
Commission of Career Schools and Colleges (ACCSC).......... 14
Prepared statement of.................................... 15
Neal, Anne D., president, American Council of Trustees and
Alumni..................................................... 18
Prepared statement of.................................... 20
Sibolski, Dr. Elizabeth H., president, Middle States
Commission on Higher Education............................. 6
Prepared statement of.................................... 8
KEEPING COLLEGE WITHIN REACH:
DISCUSSING PROGRAM QUALITY
THROUGH ACCREDITATION
----------
Thursday, June 13, 2013
U.S. House of Representatives
Subcommittee on Higher Education and Workforce Training
Committee on Education and the Workforce
Washington, DC
----------
The subcommittee met, pursuant to call, at 10:02 a.m., in
room 2175, Rayburn House Office Building, Hon. Virginia Foxx
[chairwoman of the subcommittee] presiding.
Present: Representatives Foxx, Petri, Walberg, Salmon,
Guthrie, Brooks, Hudson, Hinojosa, Tierney, Bonamici, and
Davis.
Also present: Representative Kline.
Staff present: Katherine Bathgate, Deputy Press Secretary;
James Bergeron, Director of Education and Human Services
Policy; Casey Buboltz, Coalitions and Member Services
Coordinator; Heather Couri, Deputy Director of Education and
Human Services Policy; Amy Raaf Jones, Education Policy Counsel
and Senior Advisor; Nancy Locke, Chief Clerk; Brian Melnyk,
Professional Staff Member; Krisann Pearce, General Counsel;
Nicole Sizemore, Deputy Press Secretary; Emily Slack,
Legislative Assistant; Alex Sollberger, Communications
Director; Alissa Strawcutter, Deputy Clerk; Tylease Alli,
Minority Clerk/Intern and Fellow Coordinator; Kelly Broughan,
Minority Education Policy Associate; Jody Calemine, Minority
Staff Director; Jamie Fasteau, Minority Director of Education
Policy; Rich Williams, Minority Education Policy Advisor; and
Michael Zola, Minority Deputy Staff Director.
Chairwoman Foxx. Good morning, everyone.
A quorum being present the subcommittee will come to order.
Welcome to today's hearing. I would like to start by
thanking our panel of witnesses for joining us to discuss the
accreditation process and its role in our nation's higher
education system.
Based on an idea of self-regulation, accreditation was
originally developed to assure and improve excellence in higher
education programs When the federal government began putting
money into higher education, accreditation took on another role
by ensuring that the gate to federal funds is open only to
qualified academic institutions.
Today, the federal government, states, and accrediting
agencies, known collectively as ``the triad,'' work together to
determine which institutions are eligible to participate in
federal student aid programs
Accrediting agencies are given a great amount of authority
in the process, establishing standards and conducting peer
review evaluations of postsecondary institutions.
By design, assessing program quality meant to be a non-
governmental process. Entrusting independent bodies, not the
Department of Education or Congress, with this responsibility
has preserved institutional autonomy and academic freedom
within our higher education system. This framework has helped
to maintain a crucial balance between flexibility for
institutions and accountability for students and taxpayers.
However, as our higher education system adapts to embrace
21st century technologies and changing student demographics, we
must now explore whether the accreditation system is also due
for reforms.
Advances in technology have introduced new programs,
platforms, and environments for learning into the higher
education community. Massive, open, online courses have
modernized instructional delivery by providing a wide variety
of postsecondary courses and degree opportunities to students
nationwide. New competency-based programs award credentials
based on experience and knowledge, instead of how much time
students have spent in a classroom.
These innovative methods of learning stem from the social
and demographic changes that have fundamentally changed what it
means to be a quote--``traditional student.'' Institutions are
actively seeking opportunities to better serve a growing
population of students who don't fit the usual quote--``first
time, full time'' mold, including students who are veterans,
parents who are returning to school, and students who work
full-time while earning a degree.
If standards to measure quality continue to be based on so-
called traditional programs and students of the past, those
institutions working diligently to innovate and serve the needs
of today's students, while also seeking opportunities to offer
more cost effective degree programs, could be at an
accreditation disadvantage.
Some higher education leaders have proposed changes to the
accreditation metrics to ensure institutions that are
experimenting with new education models such as competency-
based programs or online learning initiatives aren't unfairly
penalized. The Obama administration jumped into this debate
earlier this year, suggesting changes to the criteria of
accrediting agencies use to evaluate colleges and universities
and setting benchmarks for affordability and student outcomes
in the 2013 State of the Union blueprint.
Other experts have proposed larger reforms, including
taking accreditors out of the process of determining an
institution's eligibility for federal financial aid, believing
that accrediting agencies, which are largely made up of the
institutions they accredit, have an inherent conflict of
interest in determining the quality standards institutions must
meet.
In the Higher Education Opportunity Act of 2008,
Republicans authored provisions to make the accreditation
process and its results public to help students and families
better evaluate their postsecondary education choices. With the
upcoming reauthorization of the Higher Education Act, we have
another chance to explore additional reforms that will
strengthen the accreditation system while also supporting
institutional innovation. I look forward to beginning that
conversation in today's hearing.
Again I would like to thank our panel for being here today.
And I now recognize Mr. Hinojosa, the senior Democratic member
of the subcommittee, for his opening remarks.
[The statement of Chairwoman Foxx follows:]
Prepared Statement of Hon. Virginia Foxx, Chairwoman,
Subcommittee on Higher Education and Workforce Training
Good morning and welcome to today's hearing. I'd like to start by
thanking our panel of witnesses for joining us to discuss the
accreditation process and its role in our nation's higher education
system.
Based on an idea of self-regulation, accreditation was originally
developed to assure and improve excellence in higher education
programs. When the federal government began investing in higher
education, accreditation took on another role by ensuring that the gate
to federal funds is open only to quality academic institutions.
Today the federal government, states, and accrediting agencies--
known collectively as ``the triad''--work together to determine which
institutions are eligible to participate in federal student aid
programs. Accrediting agencies are given a great amount of authority in
the process, establishing standards and conducting peer review
evaluations of postsecondary institutions.
By design, assessing program quality is meant to be a non-
governmental process. Entrusting independent bodies--not the Department
of Education or Congress--with this responsibility has preserved
institutional autonomy and academic freedom within our higher education
system. This framework has helped to maintain a crucial balance between
flexibility for institutions and accountability for students and
taxpayers.
However, as our higher education system adapts to embrace 21st
century technologies and changing student demographics, we must now
explore whether the accreditation system is also due for reforms.
Advances in technology have introduced new programs, platforms, and
environments for learning into the higher education community. Massive
open online courses have modernized instructional delivery by providing
a wide variety of postsecondary courses and degree opportunities to
students nationwide. New competency-based programs award credentials
based on experience and knowledge, instead of how much time students
have spent in a classroom.
These innovative methods of learning stem from the social and
demographic changes that have fundamentally changed what it means to be
a ``traditional student.'' Institutions are actively seeking
opportunities to better serve a growing population of students who
don't fit the usual ``first time, full time'' mold, including students
who are veterans, parents who are returning to school, and students who
work full-time while earning a degree.
If standards to measure quality continue to be based on so-called
``traditional'' programs and students of the past, those institutions
working diligently to innovate and serve the needs of today's
students--while also seeking opportunities to offer more cost-effective
degree programs--could be at an accreditation disadvantage.
Some higher education leaders have proposed changes to the
accreditation metrics to ensure institutions that are experimenting
with new education models such as competency-based programs or online
learning initiatives aren't unfairly penalized. The Obama
administration jumped into this debate earlier this year, suggesting
changes to the criteria accrediting agencies use to evaluate colleges
and universities and setting benchmarks for affordability and student
outcomes in the 2013 State of the Union blueprint.
Other experts have proposed larger reforms, including taking
accreditors out of the process of determining an institution's
eligibility for federal financial aid, believing that accrediting
agencies--which are largely made up of the institutions they accredit--
have an inherent conflict of interest in determining the quality
standards institutions must meet.
In the Higher Education Opportunity Act of 2008, Republicans
authored provisions to make the accreditation process and its results
public to help students and families better evaluate their
postsecondary education choices. With the upcoming reauthorization of
the Higher Education Act, we have another chance to explore additional
reforms that will strengthen the accreditation system while also
supporting institutional innovation. I look forward to beginning that
conversation in today's hearing.
Again, I'd like to thank our panel for being here today and I will
now recognize Mr. Hinojosa, the senior Democratic member of the
subcommittee, for his opening remarks.
______
Mr. Hinojosa. Thank you, Chairwoman Foxx.
Good morning, everyone.
I want thank our panel of distinguished witnesses for
joining us for the committee's discussion on the role of
accreditation and its relationship to program quality,
accountability, and affordability in higher education.
As Congress works to reauthorize the Higher Education Act
in a bipartisan manner, Congress must ensure that the
accreditation process provides for high quality education
programs that are worthy of student and taxpayer investment and
lead to good family-sustaining jobs and careers.
Under current law, Title IV of the Higher Education Act,
better known as HEA, authorizes the federal student aid
programs and establishes a regulatory structure that includes
three actors. Number one is the U.S. Department of Education;
number two is the states; and number three is the accrediting
agencies, better known as ``the Triad.''
The Higher Education Act recognizes the critical role that
these actors play in providing a framework for shared
responsibility and for ensuring that the gate to student
financial aid programs opens only to those institutions that
provide students with a high quality education.
While I agree that the federal government should not
interfere in the operations, the curriculum, and the
instruction of postsecondary institutions, I do believe that
accrediting bodies and states must do a better job of enforcing
minimum standards for program quality. Students, taxpayers, and
the federal government must have a return on their investment.
Without a doubt, strengthening the accreditation process
should involve increasing accountability. Accreditors should be
empowered to institute a greater array of oversight and
accountability tools to more closely monitor problematic
institutions.
Finally, we should take care to consider learning wherever
it occurs, even beyond the walls of traditional colleges. This
committee should consider changes to the accreditation system
that would enhance program quality; that would promote
innovation; incentivize states and institutions to make college
more affordable; and finally, increase student outcomes.
If the current system cannot accomplish that goal, we
should consider establishing new gatekeepers that could help
the Department of Education evaluate learning quality provided
by education entities.
To be clear it seems to me a renewed emphasis on program
quality should not stifle innovation. As you panelists know,
some alternative learning models, including some of the
massive, open, on-line courses are nonprofits. Because these
alternative learning models are not institutions of higher
learning, they are not eligible for Title IV funds.
An alternative accreditation model could serve to recognize
high quality, on-line courses and degree programs to expand
access to higher education for millions of students. With this
in mind, I applaud the Secretary of Education, Arne Duncan and
Under Secretary Martha Kanter for encouraging accrediting
agencies and states to engage in a robust conversation about
quality, innovation, and affordability in higher ed.
The reauthorization of HEA is an opportunity for us in
Congress to discuss ways in which we can strengthen our current
accreditation system, and I look forward to hearing from our
experts on these vitally important issues.
Thank you, and I yield back.
[The statement of Mr. Hinojosa follows:]
Prepared Statement of Hon. Ruben Hinojosa, Ranking Member,
Subcommittee on Higher Education and Workforce Training
Thank you, Chairwoman Foxx. Good morning! I want to thank our panel
of distinguished witnesses for joining us for the committee's
discussion on the role of accreditation and its relationship to program
quality, accountability and affordability in higher education.
As Congress works to reauthorize the Higher Education Act in a
bipartisan manner, Congress must ensure that the accreditation process
provides for high quality education programs that are worthy of student
and taxpayer investment and lead to good family-sustaining jobs and
careers.
Under current law, title IV of the Higher Education Act (HEA)
authorizes the federal student aid programs and establishes a
regulatory structure that includes three actors: the U.S. Department of
Education, the states, and the accrediting agencies, known as ``the
Triad.''
The Higher Education Act recognizes the critical role that these
actors play in providing a framework for shared responsibility and for
ensuring that the ``gate'' to student financial aid programs opens only
to those institutions that provide students with a high quality
education.
While I agree that the federal government should not interfere in
the operations, curriculum, and instruction of postsecondary
institutions, I do believe that accrediting bodies and states must do a
better job of enforcing minimum standards for program quality.
Students, taxpayers, and the federal government must have a return on
their investment.
Without a doubt, strengthening the accreditation process should
involve increasing accountability. Accreditors should be empowered to
institute a greater array of oversight and accountability tools to more
closely monitor problematic institutions.
Finally, we should take care to consider learning wherever it
occurs, even beyond the walls of traditional colleges. This committee
should consider changes to the accreditation system that would enhance
program quality; promote innovation; incentivize states and
institutions to make college more affordable; and increase student
outcomes.
If the current system cannot accomplish that goal, we should
consider establishing new gatekeepers that could help the department of
education evaluate learning quality provided by education entities.
To be clear, a renewed emphasis on program quality should not
stifle innovation. As you know, some alternative learning models,
including some of the massive open on-line courses (MOOCs) are
nonprofits. Because these alternative learning models are not
institutions of higher learning, they are not eligible for Title IV
funds.
An alternative accreditation model could serve to recognize high
quality on-line courses and degree programs to expand access to higher
education for millions of students. With this in mind, I applaud the
Secretary of Education Arne Duncan and Under Secretary Martha Kanter
for encouraging accrediting agencies and states to engage in a robust
conversation about quality, innovation, and affordability in higher
education.
The reauthorization of HEA is an opportunity to discuss ways in
which we can strengthen our current accreditation system, and I look
forward to hearing from our experts on these vitally important issues.
Thank you.
______
Chairwoman Foxx. Thank you Mr. Hinojosa.
Pursuant to committee rule 7(c), all subcommittee members
will be permitted to submit written statements to be included
in the permanent hearing record. Without objection, the hearing
record will remain open for 14 days to allow statements,
questions for the record, and other extraneous material
referenced during the hearing to be submitted in the official
hearing record.
It is now my pleasure to introduce our distinguished panel
of witnesses.
Dr. Elizabeth Sibolski is currently the president of the
Middle States Commission on Higher Education. Prior to joining
MSCHE, she was director of University Planning and Research at
American University in Washington, D.C.
Dr. Michale McComis serves as the executive director and
chief executive officer of the Accrediting Commission of Career
Schools and Colleges, managing the organization's day-to-day
operations and overseeing the accreditation process for 750
postsecondary career-oriented vocational education
institutions.
Ms. Anne Neal is the cofounder of the American Council of
Trustees and Alumni, and has been president since 2003. Prior
to joining ACTA, Ms. Neal served as general counsel and
congressional liaison for the National Endowment for the
Humanities.
Mr. Kevin Carey currently serves as the director of the
Education Policy Program at the New America Foundation. Prior
to joining New America, Mr. Carey worked as a policy director
of Education Sector and as an analyst at the Education Trust
and the Center on Budget and Policy Priorities.
Before I recognize you to provide your testimony let me
briefly explain our lighting system. You will have 5 minutes to
present your testimony. When you begin, the light in front you
will turn green. When 1 minute is left the light will turn
yellow. When the time is expired the light will turn red. At
that point, I ask that you wrap up your remarks as best as you
are able. After you have testified, members will each have 5
minutes to ask questions of the panel.
I now recognize Dr. Elizabeth Sibolski for 5 minutes.
STATEMENT OF DR. ELIZABETH H. SIBOLSKI, PRESIDENT, MIDDLE
STATES COMMISSION ON HIGHER EDUCATION
Ms. Sibolski. Madam Chair and members of the subcommittee,
thank you for the opportunity to testify this morning on the
role regional accreditors play in ensuring quality in our
nation's system of higher education.
For 4 years I have served as the president of the Middle
States Commission on Higher Education, and I am also serving as
the current chair of the Council of Regional Accrediting
Commissions.
All of the regional accrediting agencies are private,
voluntary, nongovernmental, membership associations that
define, maintain, and promote educational excellence and
improvement.
MSCHE is one of seven commissions across six regions. Each
region employs a modest staff to oversee the work of the
commission while over 3,500 volunteers carry out the actual
work of accreditation.
Collectively, the seven regional commissions accredit over
3,000 highly diverse institutions. Almost all of these rely on
accreditation for eligibility to participate in federal student
financial aid programs.
Each regional creditor must be recognized by the U.S.
Secretary of Education as a reliable authority on the quality
of education through a process which involves review by the
National Advisory Committee on Institutional Quality and
Integrity.
Under the U.S. DOE's guidelines for preparing and reviewing
petitions and compliance reports, we regional accreditors and
in fact all accreditors, are subject to roughly 100 separate
requirements as part of the recognition process.
Each regional accreditor uses similar processes for
initially accrediting institutions. Once accredited,
institutions are monitored to ensure ongoing compliance and are
re-reviewed for reaffirmation of accreditation.
In cases where an institution is not meeting standards,
action is taken and the institutions are required to return to
compliance with those standards.
Today, accreditation is very different from what it was a
few years ago. Regional accreditors are working with
institutions to facilitate approval of innovative offerings
that would increase access and affordability.
At MSCHE, we are in discussions with institutions that are
eager to explore approval for competency-based direct
assessment programs. This past year NEASC approved what is
widely viewed to be a landmark direct assessment program at
Southern New Hampshire University and other regions are
similarly engaged.
Commissions are doing more to streamline their own
accreditation processes. The Higher Learning Commission is
transitioning one of its current programs into two new
pathways.
The Northwest Commission recently updated their process
making it more strategic, analytical, and outcomes based. We
have reacted to the demand for increased transparency as well.
MSCHE posts significant information about areas of required
follow up with our institutions on our website.
Both WASC commissions have expanded the information
available on-line including team reports and beginning this
month SACS will initiate a process of posting a form of
disclosure for all institutions following their reaffirmation.
We recognize the demand for more information about student
achievement. NEASC has been working to expand availability of
data on retention and graduation rates.
WASC/ACCJC is now asking institutions to report annually on
institution level, student achievement, and outcomes data while
WASC Senior has a new process to evaluate retention and
graduation data.
Our regional agencies face numerous challenges though. For
example, how do we expedite the accreditation process while
remaining thorough and careful in what we do? How can we move
to quickly sanction an institution that is substandard while
still providing the necessary due process protections? How
should we balance the competing needs for thorough review, with
review that is cost-effective and timely?
Congress can play a key role in helping us address some of
these challenges. For example, our efforts to promote
innovative practices would be enhanced if the Higher Education
Act explicitly allowed accreditors to develop demonstration or
pilot programs.
We also urge the administration to rethink the steady
stream of new regulations such as those focusing on state
authorization. These regulations often present significant
burdens for institutions and accreditors alike, without
producing significant new benefits.
Accreditation is far from perfect and there is always room
for improvement. However, if there is a single message I would
leave today, it is that academic communities continue to
provide the most effective way to evaluate quality in higher
education today.
Thank you.
[The statement of Ms. Sibolski follows:]
Prepared Statement of Dr. Elizabeth H. Sibolski, President,
Middle States Commission on Higher Education
Good morning Mrs. Chairwoman, Mr. Ranking Member and Members of the
Subcommittee. Thank you for this opportunity to testify today on the
important role regional accreditors play in ensuring quality in our
nation's system of higher education.
For the past four years, I have served as the President of the
Middle States Commission on Higher Education, where I spent the prior
nine years in a variety of other positions. I am also the current Chair
of the Council of Regional Accrediting Commissions, which coordinates
and advocates on behalf of regional accrediting commissions.
Reflecting my own experience and background with MSCHE as well as
the broader perspective of regional accreditors collectively, I will
focus my testimony today on four key areas. Specifically, the structure
of regional accreditation; the process used by accreditors in
recognizing institutions; recent ways in which regional accreditation
has responded to the changing landscape of higher education; and
finally, an overview of some of the key challenges facing regional
accreditors.
I would like to begin by explaining the value of accreditation.
Simply put, accreditation is the way in which colleges and universities
give the public confidence that they provide a quality education. It is
for this reason accreditation is used by the federal government as a
key requirement for participation in federal student aid programs;
employers use accreditation for evaluating the education credentials of
prospective employees and for decisions regarding tuition reimbursement
programs; and colleges and universities use accreditation as a means
for determining the quality of other institutions for purposes of
determining transfer-of-credit policies.
Just as important is the fact that accreditation is a critical tool
used by colleges, universities, and other institutions of higher
education to sustain and strengthen their quality as part of a process
of continuous improvement. Institutional improvement has been a core
aspect of regional accreditation since its founding a century ago.
Structure
The Middle States Commission on Higher Education (MSCHE), as with
each regional accreditor, is a private, voluntary, non-governmental,
membership association that defines, maintains, and promotes
educational excellence and improvement. Regional accreditors accredit
entire institutions, not individual programs, units, or locations.
Regional accreditors also require that undergraduate programs (if the
institution offers any) include a significant general education or
liberal studies component.
MSCHE is one of seven Commissions across six regions. The Western
Association of Schools and Colleges is unique in that it maintains
separate commissions for senior and junior colleges.
A professional staff oversees each Commission while over 3,500
volunteers carry out the work of accreditation by serving on visiting
teams and on commissions. These volunteers include college and
university presidents, academic officers, faculty, and campus experts
in finance, student services and library/technology. At least one of
every seven Commissioners is required to be a public member, although
some Commissions have a higher ratio of public members and find they
provide valuable insight into ensuring that accreditation is relevant.
Collectively the seven Regional Commissions accredit over 3,000
institutions, which include public, private non-profit, and private
for-profit entities. The range of institutions in each region includes,
but is not limited to, community colleges, liberal arts colleges,
special-purpose institutions such as seminaries and medical schools,
research universities, and institutions with on-line programs serving
every state of the nation. These institutions have diverse missions,
student populations, and resources and enroll over 17 million students
in programs ranging from associates through doctoral degrees
Each regional accreditor must be recognized by the U.S. Secretary
of Education as a reliable authority on the quality of education and
training provided by the institutions of higher education that it
accredits. Acquiring this recognition involves each agency undergoing a
review by U.S. Department of Education staff, which provides
recommendations to the National Advisory Committee on Institutional
Quality and Integrity (NACIQI)--a committee with Members appointed by
Congress and the U.S. Secretary of Education. Accreditors must also
appear before NACIQI, which in turn advises the Secretary regarding
recognition.
Recognition is based upon criteria set forth under the Higher
Education Act (HEA) and through significant regulations. In fact, under
the USDOE's Guidelines for Preparing/Reviewing Petitions and Compliance
Reports, we are subject to roughly 100 separate requirements as part of
the recognition process. Among these criteria is the requirement that
accreditors maintain certain standards that must be used in quality
reviews. In particular, accreditors must ensure they have standards
that assess an institution's success with respect to student
achievement in relation to the institution's mission, curricula,
faculty, facility, equipment and supplies, fiscal and administrative
capacity, student support services, recruiting and admission practices,
measure of program length, and record of student complaints, as well as
record of compliance with its program responsibility under Title IV of
HEA. All institutions--public, private not-for-profit, private for-
profit--are evaluated using standards that are generally the same.
For an institution, accreditation by an agency recognized by the
Secretary provides an assurance of education quality and is necessary
in order to participate in federal student financial aid programs.
However, the Department of Education and individual states also have
distinct roles in ensuring quality in higher education. Under this
``Triad'' as it is referred to, states ensure a process for addressing
consumer complaints and the federal government oversees financial
responsibility and administrative capability of institutions.
Process
Within this overall structure, each regional accreditor uses a
similar process for accrediting institutions. The MSCHE's process
includes several distinct steps, which can take several years to fully
complete, reflecting the need for regional accreditors to hold true to
their obligation to serve as a reliable authority of quality. These
steps toward initial accreditation include:
Deciding whether to apply and whether to make institutional
changes
This is an initial period of inquiry during which the institution
has an opportunity to learn about and judge its position relative to
MSCHE requirements and expectations.
Submitting an application that demonstrates eligibility for
accreditation
Demonstration of eligibility for accreditation involves the
presentation of documentation and analysis showing the institution's
current or potential compliance with accreditation standards. At this
stage, MSCHE staff conduct an initial review and determination of the
institution's capacity to demonstrate sustained compliance.
Commission staff visit
The Commission staff visit provides an opportunity to confirm the
institution's readiness to continue the accreditation process
successfully and to discuss, with the institution's constituencies, the
next steps in that process.
Applicant assessment team visit
The applicant assessment team visit allows for a validation of the
information that has been submitted to MSCHE and a determination via
peer review as to whether the institution is ready to be granted
candidate-for-accreditation status by the Commission.
Updated accreditation readiness reports and candidate
progress visits
These reports and candidate progress visits are employed if the
Commission does not immediately invite the institution to initiate
self-study when it grants candidacy. This interim period allows the
institution time to focus on issues where work may be required to
ensure sustainable compliance with standards for accreditation.
Self-study and the evaluation team visit
The self-study and evaluation team visit are the final steps in
candidacy wherein the institution prepares its first self-study and
hosts a full evaluation team visit.
Becoming accredited
This is the action taken by the Commission following a successful
self-study and peer-evaluation process.
Once accredited, institutions are monitored by the Commission to
ensure on-going compliance and within the context of reaffirmation of
accreditation. While there is variation among regional processes, MSCHE
works within a decennial time frame that includes two main
accreditation events that result in accreditation decisions in the
first year and in the fifth year.
MSCHE uses a three-stage decision-making process both for initial
accreditation and for reaffirmation of accreditation. In the first
stage, peer reviewers consider reports and evidence presented by the
institution and develop an action recommendation. A second-stage review
happens in one of the Commission's standing committees. This review
allows for a look across a number of similar reviews and gives us a
mechanism for considering consistency and fairness in the decisions
that have been made. Adjustments are possible as the committee then
makes its action recommendations to the full Commission. The final
stage of review rests with the full Commission, which can make further
adjustments in reaching a final accreditation action.
In addition to these two main accreditation events, MSHCE also
reviews institutions through annual data submission via an
Institutional Profile. Through this process, the Commission may
identify instances where additional follow-up may be necessary.
In addition, we maintain ongoing contact with our institutions in a
variety of other ways. This includes receiving from them follow-up
reports from reviews and substantive change requests related to such
issues as the addition of new branch campuses or additional teaching
locations.
Increasingly, we find the need to work with institutions upon
learning about significant developments such as new financial issues or
other matters that have drawn serious attention by media or in cases
where we learn of complaints or third-party comments about the
institution.
It is especially important to emphasize that, in cases where an
institution is not meeting our standards or is in danger of non-
compliance, as identified as part of a scheduled review or on-going
monitoring, the Commission takes action requiring the institution to
report back to us.
If warranted, a special visit by an evaluation team at the
institution will be scheduled.
The team will report back to the Commission, which will then take
action as may be warranted. The range of actions may include steps
toward termination of accreditation if necessary. To give you a sense
of how often we must take such steps, in 2012, 18 percent of our
institutions were placed on warning following a self-study; 10 percent
were placed on warning after a periodic review; after follow up, 4
percent of warnings were continued and 1 percent were placed on
probation.
Clearly, terminating accreditation is a last resort and has serious
implications for institutions and students alike. For this reason we
devote substantial time and energy in working with institutions from
the very beginning to help prevent terminations and to identify and
respond to issues through monitoring and oversight before they result
in serious problems.
The accreditation status of an institution--particularly in cases
where there has been a sanction--is critical information for the public
and especially students to know and be aware of. For this reason,
accreditors are also responsible for disclosing the accreditation
status of reviewed institutions. This responsibility includes providing
such information as current status, including sanctions imposed and
reasons for the sanctions and requested monitoring reports. In addition
to the status being posted on our own websites, this information is
also provided to the U.S. Secretary of Education and posted on the U.S.
Department of Education's website.
Accreditation 2.0
Higher education today is far different than when our Commission
first began its work nearly 100 years ago. Indeed, the landscape has
changed dramatically in just the last 10 years, with the explosive
growth of new modes of delivering education; increased numbers of
institutions providing services, especially in the for-profit sector;
and a comparatively large amount of spending on higher education--both
by the federal government and through family financing.
This evolution in higher education shows no sign of slowing, as
evidenced by the advent of Massive Open Online Courses (MOOCs), which
are driving new pathways and partnerships to a degree I have never seen
in all of my years in higher education.
Just as all of higher education is changing, so too is regional
accreditation. Today, our practices and policies are vastly different
from what they were a decade or even five years ago. These changes have
been critical for many reasons, including enabling us to keep up with
the changing nature of the delivery of education; to maintaining proper
oversight of increasingly complex fiscal management systems; and to
meeting a growing demand by policymakers and the public for increased
transparency and for a focus on outcomes in higher education.
Below are just a few examples of what regional accreditors are
doing to meet the new demands in our changing landscape:
Promoting Innovation in Educational Programs
Regional accreditors are working with institutions to enable them
to deliver degrees in ways that increase access and affordability while
ensuring and improving outcomes. For example:
At MSCHE, we are in discussion with several institutions
that are eager to explore approval for competency-based/direct
assessment programs.
Meanwhile, this past year, the New England Association of
Schools and Colleges (NEASC) approved what is widely viewed as a
landmark program at Southern New Hampshire University which will
provide access to federal financial aid for a degree program offered
without credits or semester terms--a so-called ``direct assessment''
program--making these programs more accessible, affordable and focused
on outcomes. That program has now been approved by the U.S. Department
of Education for participation in federal financial aid programs.
NEASC is also focusing on the role of accreditation in
considering ``credits from elsewhere''--credits that students bring
with them or credits that institutions recognize or validate for non-
collegiate study. This will lead to a discussion of the institution's
responsibility to assure the quality of anything for which it awards,
recognizes or accepts credits (e.g., Straighter Line, MOOCs,
competencies, prior learning assessments).
The Higher Learning Commission (HLC), which accredits
institutions throughout the Midwest and as far west as Arizona, has
moved forward with a pilot program to enable institutions to authorize
the offering of competency-based programs as a means of reducing the
time required to complete a degree and the cost.
The Southern Association of Colleges and Schools (SACS)
recently received its first proposal for a competency-based program,
and will be convening a task force to examine the relevant issues in
more detail.
Streamlining the Accreditation Process
As accreditors, we recognize that certain aspects of the
accreditation process have historically been viewed as over-burdensome
and costly--both financially and in terms of staff time and effort.
While the level of burden is in part due to federal laws and
regulations, more is being done to streamline the accreditation process
and improve the benefits to institutions:
At MSCHE, we are renewing our accreditation process,
including looking at ways to change aspects of our 5th-year reporting
in order to streamline that activity.
The Higher Learning Commission (HLC) is in the process of
transitioning one of its current programs for maintaining accreditation
into two new Pathways--the Standard Pathway and the Open Pathway--both
of which would reduce the reporting burden on institutions by
collecting as much information and data as possible from existing
institutional processes and in electronic form as they naturally occur
over time.
The Northwest Commission on Colleges and Universities
(NWCCU) has shortened its accreditation cycle from ten years to seven
years. The foci and requirements of the Commission's new accreditation
reports streamline the process without compromising the rigor or value
to institutions and the Commission. The process is more strategic,
analytical, and outcomes-based and is driven by an institution's own
stated mission, core themes, and objectives.
Increasing the Transparency of the Accreditation Process
We believe it is critical for students to understand the
accreditation status of the institution they attend or are considering
attending. However, there has been a growing demand for more
information going beyond just the current accreditation status of an
institution, and the regional accreditors have reacted by developing
new ways in which to increase transparency.
For example, MSCHE posts a significant amount of
information on our website about the specific areas where individual
institutions have required follow-up.
The Accrediting Commission for Community and Junior
Colleges (WASC/ACCJC) now requires all member institutions to post
their self-evaluation report, the evaluation team report, and any
Commission action letters online.
The Western Association Schools and Colleges Accreditation
Accrediting Commission for Senior Colleges and Universities (``WASC
Senior'') has, since last year, posted all team reports and Commission
action letters on its website, and the postings also include a link to
any institutional response.
Beginning this month, SACS will initiate a process of
posting a form of disclosure for all institutions following their
reaffirmation actions which will include areas of continued monitoring
if applicable.
Enhancing Focus on Student Outcomes
Assessing student outcomes is central to the work of accreditors.
In addition, we also recognize the growing demand on the part of
policymakers, students, and the public for more information about the
extent to which individual institutions are successful in such areas as
retention and graduation. In just the last few years, regional
accreditors have devoted a significant amount of time and effort to
this issue, including:
At MSCHE, I have seen an increased demand on the part of
our institutions for assistance with more sophisticated ways to improve
student learning outcomes assessments, and we have met this demand
through an extensive schedule of workshops.
NWCCU has developed a new accreditation model that is
outcomes-based and emphasizes outcomes in the Year One, Year Three and
Year Seven Reports and evaluations.
Since 2011, NEASC has required institutions to discuss
``what students have gained as a result of their education'' as part of
their fifth-year interim report. In addition, institutions must report
(in both the comprehensive evaluation and the fifth-year interim
report) retention and graduation rates, licensure passage rates, and
the rates at which students go on to higher degrees.
For the past five years, many NEASC institutions have
agreed to display retention and graduation rates for part-time
students, transfers and on-line students. This goes beyond the
information on first-time, full-time students currently collected by
the Integrated Postsecondary Education Data System (IPEDS). This month
NEASC is convening a meeting to develop consensus on what retention and
graduation rates are most useful for non-first-time-full-time students.
WASC/ACCJC is now asking institutions to report annually
on institution-level student achievement data and student learning
outcomes data, and is monitoring this information, which comes from the
institutions' annual reports.
WASC Senior has undertaken several initiatives focused on
outcomes and quality. Included among these initiatives is a new process
to evaluate retention and graduation data, going beyond the first-time,
full-time data. WASC is also requiring all institutions to address the
meaning, quality, and integrity of their degrees so as to ensure that
they are coherent and are supported by effective quality assurance
processes. In addition, institutions awarding undergraduate degrees
will be expected to demonstrate, using their own approaches, graduation
proficiencies in the major and in at least five key areas: written
communication, oral communication, critical thinking, quantitative
reasoning, and information literacy.
Improving On-going Monitoring of Institutions
While ongoing monitoring has always been a component of
accreditation, as I have outlined above, the increased complexity of
higher education--particularly related to financial information--has
demanded we do more.
Our Commission has expanded its fiscal monitoring of all
member institutions. Each year, financial data and audited financial
statements are collected and analyzed using ratios, some of which were
developed by KPMG. In cases where the analysis reveals a concern, the
Commission reaches out to the institution for additional information
that may subsequently, depending on the situation, be considered by the
Commission or one of its committees.
WASC Senior has begun using specially trained finance
teams who review audits and financial ratios every three years to
identify financial issues, in addition to conducting annual reviews of
institutional audits.
The examples I have just outlined point out the significant work
regional accreditors are doing to respond to the changing landscape of
higher education. However, these examples also point out the value of
the ``regions'' being able to test new approaches and to build upon the
best practices developed elsewhere.
Challenges
While MSCHE and other regional accreditors have been working hard
to improve accreditation, it is worth noting a few key areas that are
illustrative of the challenges we face.
Explaining Accreditation as it Exists Today
Higher education accreditation is a complex undertaking that has
evolved significantly, especially during the past decade. This
testimony has included descriptions of some of the ways that regional
accreditors have embraced change. We don't often have an opportunity to
discuss this aspect of our work, and it is difficult to summarize in a
few words or phrases. Continuing to spread the word about what
accreditation is and what it does best represents a serious challenge.
If there is a single message in this regard that I would leave you with
today, it is that academic communities--through the vehicle of non-
governmental, voluntary peer/membership-based accrediting agencies--
continue to provide the most effective way to evaluate quality and
effectiveness in higher education.
Addressing Dilemmas in Accreditation
Regional accrediting agencies face numerous dilemmas in the current
environment. How can we expedite accreditation activity while remaining
thorough and careful in what we do? How can we move to quickly sanction
a substandard institution while still providing appropriate due-process
protections? How should we balance the competing needs for thorough
review and review that is cost-effective? How should we best promote
the use of data and evidence in self-study and review without relying
on the wrong metrics, becoming too prescriptive, or stifling creativity
and diversity? MSCHE and the other regional commissions are well aware
of issues like these. Addressing them appropriately represents a
continuing challenge.
Safe Space for Innovation within Accreditation
This country's higher education community stands at a crossroads
where such issues as cost, value, and access must be and are being
addressed in a variety of ways. Innovations in technology and delivery
are changing the face of higher education, yet it is often difficult
for accreditors to allow innovative practices and at the same time
remain within the boundaries of federal regulations. This challenge
might be addressed by explicitly allowing accreditors to develop
demonstration or pilot programs that would not put recognition of the
agency in jeopardy.
Regulations
While a certain level of regulation of accreditors is
understandable given our role as ``Title IV gatekeepers,'' we have
become increasingly concerned with the steady flow of increased
regulations that often seems to approach constant regulatory change.
New regulations, such as those focusing on defining ``credit hour'' and
involving new rules on ``state authorization,'' have created
significant burdens and challenges for institutions and accreditors
alike while at the same time providing questionable real benefits for
students and the public at large.
Effective Collaboration
The Department, regional and specialized accrediting agencies, and
state governments all have roles in reviewing and recognizing
institutions of higher learning. Understanding separate roles and
finding appropriate pathways for communicating and sharing information
are especially important in this time of transition. However,
sustaining collaborative relationships is a challenge and does not
always happen.
Conclusion
I have spent most of this testimony explaining what accreditation
is, how it works, and the many ways in which we are striving to
improve. However, accreditation is far from perfect, and there is
always room for improvement. As this Subcommittee moves forward with
efforts to reauthorize the Higher Education Act, we welcome the
opportunity to work with you on ways not only to improve accreditation
but to ensure that our system of higher education in this nation
remains second to none.
______
Chairwoman Foxx. Thank you, I now recognize Dr. Michale
McComis for 5 minutes.
STATEMENT OF DR. MICHALE McCOMIS, EXECUTIVE DIRECTOR,
ACCREDITING COMMISSION OF CAREER SCHOOLS AND COLLEGES
Mr. McComis. Good morning.
Madam Chair and members of the subcommittee, my name is Dr.
Michale McComis, and I am the executive director of the
Accrediting Commission of Career Schools and Colleges, ACCSC, a
private, nonprofit, independent, national accrediting agency
recognized by the United States Secretary of Education.
I am honored to appear before the subcommittee this morning
to discuss accreditation; the contribution that it makes to the
quality of education in this country.
Accreditation has been relied upon for educational quality
assessment purposes by the federal government for 6 decades.
Although accreditation has come under increased scrutiny by
policymakers, accreditation can and should continue to serve in
his gatekeeping capacity albeit in a strengthened form.
Accreditation employs an earnest and collaborative approach
within a peer-reviewed network that identifies best practices
and assesses how well an institution meets those best practice
standards. It is not nor can it be a one-size-fits-all system
with rudimentary metrics that do not take into account
subjective and qualitative elements of an institution's
operations and success.
Accreditation derives its strength from four essential
pillars that are built upon a foundation of peer review. Those
pillars are one, standards or best practices; two, self-
evaluation; three, ongoing institutional improvement; and four,
accountability.
The success of any accrediting agency is based upon the
strength of each of these fundamental pillars in the agency's
system of accreditation and the strength of the peer review
foundation.
Accreditation also takes different forms and serves a
myriad of institutions and as such, institutions will be
accredited by agencies with different standards and different
expectations of learning and outcomes. This is both appropriate
and necessary and through this lens the differences amongst
accreditors should be viewed as a strength to our system.
I recognize that Congress has a vested interest in ensuring
the strength of accrediting agencies. As such, the Congress
should seek to make changes to the Higher Education Act that
will provide such assurances, strengthen accreditation, but
without injecting undue federal intrusion into the academic
processes of higher education or that might serve as a barrier
to innovation.
Judgments regarding the effectiveness of accreditation
should not lose sight of the fact that the oversight of higher
ed is a shared responsibility amongst accreditors, states, and
the federal government.
Triad partners working together strengthens the existing
oversight system and retains the positive qualities of
accreditation and the expertise that peer review represents and
delivers.
So then, how can accreditation be strengthened through the
Higher Education Act? The following are some suggestions for
the subcommittee to consider.
Outcomes. Outcomes measures are not a one-size-fits-all
solution and should not be mandated by the Congress or the U.S.
Department of Education. However, accreditors working with
their accredited institutions must define the right set of
measures and metrics to evaluate institutional and student
success and hold those institutions accountable to those
outcomes.
Transparency. Accreditors should be required to provide
useful disclosures, responsible disclosures, of the
accreditation actions taken that can help the general public
make informed decisions about the quality of an institution or
program.
Credit hour definition. The complex federal definition of a
credit hour should be removed from current regulations and an
accreditor should be required to define the elements of a
program that go into quality assessment paradigms.
Accreditation area of focus. It may be useful to require
accreditors to focus narrowly on the types of institutions
accredited in order to ensure strong peer-review foundation and
solid measures related to outcomes and accountability.
Transfer of credit. Accreditors should be required to have
and enforce standards that prevent institutions from unfairly
or unjustifiably denying credit transfer.
Changing accreditors. Institutions that have been subject
to a monitoring sanction from one accreditor should not be
allowed for federal financial aid purposes to seek a new
accreditor for some set period of time after the sanction has
been lifted.
Other areas for the subcommittee to consider have been
included in my written testimony, including the appeals process
and strengthening substantive change requirements.
I hope the subcommittee finds these recommendations useful
as it goes about its work, and I am happy to provide additional
details regarding each.
As the executive director of a national accrediting agency,
I am keenly aware of the important role that accreditation
plays as a gatekeeping entity in the Triad, and that questions
remain regarding accreditation's effectiveness.
To that end, I look forward to the continuing dialogue on
ways to strengthen accreditation as a means to ensure that it
continues to fulfill its role as gatekeeper to the Title IV
federal student financial aid programs.
Thank you again for the opportunity to testify before the
subcommittee, and I stand ready to answer any questions you may
have.
[The statement of Mr. McComis follows:]
Prepared Statement of Dr. Michale S. McComis, Executive Director,
Accrediting Commission of Career Schools and Colleges (ACCSC)
Madame Chair and members of the Subcommittee, my name is Dr.
Michale McComis and I am the Executive Director of the Accrediting
Commission of Career Schools and Colleges (ACCSC), a private, non-
profit independent national accrediting agency recognized by the United
States Secretary of Education. ACCSC accredits over 730 postsecondary,
career- and vocational education-oriented institutions that serve
225,000 students throughout the United States. I am honored to appear
before the Committee this morning to discuss accreditation and the
contributions that it makes to the quality of education in this
country.
Accreditation as an education quality assessment mechanism has been
the hallmark of educational success in this country for over a century
and relied upon by the federal government for this purpose for six
decades. Although accreditation has come under increased scrutiny by
policy makers, accreditation can and should continue to serve in its
gate-keeping capacity, albeit in an enhanced form which I will describe
later in my testimony. Accreditation employs an earnest and
collaborative approach within a peer-review network that identifies
best practices and assesses how well an institution meets those best
practice standards. It is not, nor can it be, a one-size-fits-all
system with rudimentary metrics that do not take into account
subjective and qualitative elements of an institution's operations.
Accreditation has four essential pillars that are built upon a
foundation of peer review. Those pillars are: 1) standards or best
practices, 2) self-evaluation and assessment, 3) on-going institutional
assessment and improvement, and 4) accountability.
1. Standards: Through peer review, best practices are established
and mandated;
2. Self-evaluation: Institutions are evaluated internally and
externally and assessed as to how well they meet standards and can
demonstrate success through student outcomes;
3. On-going Institutional Assessment and Improvement: Expectations
of significant and on-going institutional assessment and improvement
are established; and
4. Accountability: Institutions are held accountable for compliance
with standards and outcomes--to include the loss of accreditation--when
expectations are not met.
Accreditation also takes different forms and serves many different
kinds of institutions. National accreditors, such as the agency I
represent, primarily accredit institutions that offer an array of
career- and vocationally-oriented programs that are mainly non-degree
and sub-baccalaureate degree with some baccalaureate, master's and
doctoral degree programs. Regional accreditors, on the other hand,
primarily accredit community colleges, 2 and 4 year colleges, and
universities that offer degree programs in in an array of liberal arts
and professional fields as well as some non-degree and degree programs
in vocational fields. Given the wide variety of accredited
institutions, it follows that institutions will be accredited by
different types of accrediting agencies with different standards and
different expectations of learning and outcomes. This is both
appropriate and necessary. However, the differences among accreditors
and the types of institutions they accredited do not make one type of
accreditation ``better'' than another--the success of any accreditation
agency is not based on the type of institution accredited but upon the
strength of each of the fundamental pillars in the agency's system and
the strength of the peer review foundation. All accreditors, regional
or national, and regardless of the types of institutions accredited,
should enforce an accountability-based model that combines rigorous
input standards with performance outcomes in categories such as student
learning, student assessment, and student achievement.
I recognize that the expectations of accreditors by the federal
government are changing, such that accreditors are subject to far
greater federal oversight than at any time in the past. Congress has a
vested interest in ensuring that the strength of any accrediting agency
is at an appropriate level before that agency may be recognized as a
gatekeeper to Title IV funds. As such, the Congress should seek to
enact changes to the Higher Education Act that will responsibly and
appropriately provide such assurance; however, this should be done
without injecting undue and inappropriate federal intrusion into the
academic processes of higher education.
The President has stated that he will call on Congress to
``consider value, affordability, and student outcomes in making
determinations about which colleges and universities receive access to
federal student aid, either by incorporating measures of value and
affordability into the existing accreditation system; or by
establishing a new, alternative system of accreditation that would
provide pathways for higher education models and colleges to receive
federal student aid based on performance and results.'' From my vantage
point, measures relating to performance and results are present in the
existing accreditation system, although in a variety of forms and not
always in easily packaged up or down metrics. However, it is the
variety of these measures that contribute positively and materially to
the strength of our decentralized oversight of education in this
country. Given the President's statement, however, accreditors must do
better at defining student achievement outcomes with greater
transparency to show how these measures are applied so that the public
and policy makers can rely on the results of their evaluation
processes. Accreditation, as the sector with the principle
responsibility for quality assurance in higher education, needs to work
earnestly toward moving the discussion of quality through accreditation
from skepticism to confidence.
My sincere hope is that any judgment regarding the effectiveness of
accreditation not lose sight of the fact that the oversight of higher
education, as set forth in current law and regulation, is a shared
responsibility. Each member of the regulatory triad--state government,
accreditor, and federal government--has an essential role to play in
the oversight of institutions. In this regard, the Subcommittee should
consider several of the recommendations made by the National Advisory
Committee for Institutional Quality and Integrity (NACIQI) in its April
2012 Report, including the need to clarify and to articulate common
understandings about the responsibilities of each member of the triad,
and foster increased communication among triad actors to achieve
greater commonality across the quality assurance/eligibility
enterprise. By continuing to work together in partnership with the
various organizations within the regulatory triad, I believe we can
strengthen the existing oversight system while retaining the positive
qualities of accreditation and the expertise and nuance that peer-
review represents and delivers.
Moreover, for the sake of higher education's advancement, the
higher education community--including accrediting agencies--must be
allowed to adapt and innovate in order to accommodate the diversity of
students, student preferences, and learning. This supports reasons why
there is not, and should not be, a one-size-fits-all system of
accreditation. As higher education takes a more diverse shape,
accrediting agencies and the peer review process should foster avenues
for institutions to develop and deploy innovative approaches that both
increase access to higher education and fundamentally change the manner
in which education is delivered. Ensuring the quality and integrity of
these programs without undue regulatory burden must also remain a
paramount concern. The federal definition of a credit hour, however, is
an example of undue regulatory burden and intrusion into the academic
process by the federal government that stunts innovation. In my
experience, competency models of student assessment are superior to
``seat-time'' models of student fulfillment. But, by creating the
federal definition of a credit hour, the U.S. Department of Education
federalized a basic academic concept and developed a complex and
confusing system that unintentionally serves as a barrier to innovation
in educational delivery models such as a movement to competency
assessment. Although the Department's position on ``direct assessment''
is a step in the right direction, it coexists in federal regulation
with the federal definition of a credit hour, which causes uncertainty
on how to move forward with more innovative models.
So then, how can accreditation be enhanced through the Higher
Education Act? The following are some suggestions for the Subcommittee
to consider:
Macro Areas
1. Outcomes: Outcomes measures are an important part of the
assessment paradigm for higher education institutions. But, outcomes
measures are not a one-size-fits-all solution and should not be
mandated by Congress or the U.S. Department of Education. Accreditors,
working with their accredited institutions, must find and define the
right set of measures and metrics to evaluate institutional and student
success. While program-level rates of graduation and employment work
well for the types of institutions accredited by my agency, those same
measurements may not be as appropriate in other types of institutions.
Moreover, outcomes measures by themselves are not a panacea and alone
cannot provide a sole assessment of the quality of an institution or
its programs. Input standards are an equally important part of the
assessment paradigm and serve to illustrate why accreditation is an
important part of the higher education regulatory landscape. Outcomes
measurements work best when complimented with rigorous input standards
(e.g., standards pertaining to management and educational
administration; curriculum design, development, and evaluation; faculty
qualifications; learning resources; facilities; student services;
student learning; student assessment; and other areas that contribute
to quality education programs).
Generally, outcomes measures should be a reflection of how an
institution performs relative to standards (i.e., best practices) and
should minimally require institutions to assess learning and competency
attainment as well as:
Rates of retention or graduation;
Rates of employment and certification/licensure exam pass
rates in career and professional programs and measures related to
``employability'' \1\ in other program areas; and
---------------------------------------------------------------------------
\1\ By ``employability'' I mean assessments made by graduates and
employers about how well the graduate was prepared to enter the
workforce based on the education received. This could serve as an
appropriate outcomes measure for student pursuing education in many
liberal arts fields.
---------------------------------------------------------------------------
Measures of student and graduate satisfaction.
These kinds of outcomes taken together with an assessment of an
institution's adherence to input standards provide the tools necessary
to assess quality and value.
2. Accreditation Area of Focus: It may be useful to require
accreditors to focus narrowly the types of institutions accredited to
ensure a strong peer-review foundation. This is known as the ``bucket''
approach whereby types of institutions are grouped into buckets with an
accreditor that is focused on that specific type of institution e.g.,
career- and vocationally-oriented institutions, community colleges,
liberal arts colleges and universities, research universities, etc.
This approach may allow for better peer-to-peer evaluation and bring
about better measures related to outcomes and accountability.
3. Transparency: Accreditors should provide useful disclosures of
the accreditation actions taken by the agency that can help the general
public make informed decisions about an institution or program.
4. Transfer-of-Credit: Accreditors should have and enforce
standards that prevent institutions from unfairly or unjustifiably
denying credit transfer.
5. Credit Hour Definition and Clock Hour Conversions: Seat-time
requirements for funding programs do not preserve academic integrity
nor promote competency assessment and as such the federal definition of
a credit hour and the complex clock-hour conversion formulas should be
removed from the federal regulations. If accreditors are going to be
the purveyors of educational quality assessment, then accreditors
should be given the discretion necessary to define the elements that go
into the assessment paradigm.
6. Changing Accreditors: Institutions that have been subject to a
monitoring, Show Cause Order, or Probation Order from one accreditor
should not be allowed, for federal financial aid purposes, to seek a
new accreditor for some set period of time after the sanction has been
lifted (e.g., three years).
Micro Areas
1. Appeals Process: The last reauthorization of the Higher
Education Act yielded several significant changes to the process that
accreditors most enact with regard to the appeal of an adverse
accreditation decision. While I believe the Congress was well
intentioned, the ensuing regulations have created a far more complex
and cumbersome process that has not, in my experience, yielded greater
due process for institutions. I suggest the Subcommittee review the
history of legislative intent and regulatory changes in this regard and
consider reverting back to the pre-2008 requirements.
2. Substantive Changes: The Subcommittee should review the
provisions that permit accreditors to visit only a ``representative
sample'' of additional locations if an institution operates more than
three additional locations and that allow an institution to establish
additional locations without prior approval from its accreditor. In my
experience, growth of an institution, to include the addition of
geographically distant campuses, should require greater oversight, not
less. Accreditors should be required to visit and evaluate fully each
campus or location where federal Title IV financial aid dollars may be
spent by students.
It is my hope that the Subcommittee finds these suggestions to be a
useful addition to the discussion regarding accreditation's continued
role as a gatekeeper to federal financial aid programs and I will be
happy to provide additional information as may be requested.
As the executive director of a national accrediting agency, I can
attest that my organization is keenly aware of the important role that
accreditation plays as a gate-keeping entity in the triad and
understands the impact that role has on ensuring the reliability of our
nation's current higher education oversight system. I am also cognizant
that questions remain from policy members, regulators, and the general
public regarding whether accrediting agencies have been living up to
our collective responsibilities, and whether or not accreditation has
the appropriate level of rigor and outcomes assessments. To that end, I
look forward to continuing the dialogue on ways to strengthen
accreditation as means to ensure that accreditation continues to
fulfill its role as a gatekeeper to the Title IV federal student
financial aid programs.
Thank you again for the opportunity to testify before the
Subcommittee and I stand ready to answer any questions you may have.
______
Chairwoman Foxx. Thank you very much.
I now recognize Ms. Anne Neal for 5 minutes.
STATEMENT OF ANNE D. NEAL, PRESIDENT,
AMERICAN COUNCIL OF TRUSTEES AND ALUMNI
Ms. Neal. Good morning, and thank you, Madam Chairman and
members of the committee.
If policymakers and parents think of accreditation at all,
they typically assume that it is a good housekeeping seal of
approval, but it is not. As I have outlined more fully in my
written testimony, accreditation has failed the taxpayer and
failed American families.
It has not insured quality, or transparency; imposes
significant costs on colleges and universities; interfered and
institutional autonomy and proven a barrier to innovation.
Given these flaws, it is not surprising that there has been
increasing bipartisan support for change. Indeed President
Obama has suggested reforming accreditation or replacing it
with a system focused on performance and cost.
It is time for Congress to overhaul this broken system. Let
me explain why. Accrediting agencies have a schizophrenic
existence that makes them unable to protect the public
interest.
Peer review is by nature collegial and designed to help,
but not mandate institutional improvements. The only quality
assurance tool is to revoke accreditation, which is a death
sentence for most institutions and something accreditors don't
want to do.
This is due in part to the fact that accreditation is a
revelatory capture. The very people who benefit from federal
funds, administrators and faculty, are the people who determine
whether federal funds should flow.
Congress' hope that it could rely on membership-based
accrediting agencies and their peer review process to be
reliable authorities on quality was misplaced. Accreditors are
also barriers to innovation.
Today the American higher education landscape is changing
rapidly and as we have heard from Representative Foxx, leading
universities and faculty are creating MOOCs many students never
even enter a classroom, yet accreditation is focused largely on
bricks and mortar institutions with little framework for
dealing with these new models.
Under the current regime, in fact, as you have heard from
Dr. McComis, institutions are being forced to focus on concepts
such as seat time when keeping a bottom in every seat is part
of the problem, not part of the solution.
Accreditation is also secretive, the consumer essentially
knows only one thing; that the so-called seal of approval has
been bestowed, but it doesn't mean that the college meets high
standards or even that all of its programs are good.
Federal dollars are flowing today to schools that graduate
fewer than a quarter of their students in 6 years. The consumer
is being duped and Congress is letting it happen.
Accreditation interferes with governance and management,
and it is costly and burdensome when college costs are already
too high. Duke, Stanford, and the University of Michigan have
reported spending over $1 million dollars on accreditation, and
Princeton expects much the same. One can only guess the
hardship imposed on less wealthy schools in these difficult
times.
Of course we might accept the cost if accreditors
effectively guaranteed educational quality, but they have not.
The National Assessment of Adult Literacy found that a majority
of 4-year college graduates could not reliably compare two
editorials or compute the cost per ounce of food items.
As I am sure you have heard in your districts, employers
consistently complain that their college graduates can't write,
think critically, or offer the services they need. This is a
national crisis and it is surely not quality assurance.
It is time to break the link between federal student aid
and accreditation. One option provided to you would ensure
baseline financial protection and provide key data on student
learning in a far simpler and more transparent system of
quality assurance.
To protect the federal dollar, institutions would establish
their financial stability certified by an independent auditor.
Federal funds could be cut off in cases of noncompliance and
institutions would have the option to present a bond.
Schools would also be required to provide key information
in a clear and readily accessible format such as cost of
attendance, graduation rates disaggregated by demographics,
repayment rates, license or test results; much of what is
already collected for the Department of Education's College
Navigator site.
This could again be independently certified. Removing the
gatekeeping function for Title IV puts all institutions on a
level playing field in terms of access to federal funds.
This consumer-friendly alternative would not create new
federal benchmarks or inappropriately insert the federal
government into the workings of our colleges and universities.
It would instead empower individuals to make their own educated
choices and allow institutions to focus on key metrics of
student success.
I look forward to further discussion.
[The statement of Ms. Neal follows:]
Prepared Statement of Anne D. Neal, President,
American Council of Trustees and Alumni
Accreditation is not a household word. But it's one of the most
critical issues facing higher education. I want to thank Chairman Foxx
and members of the Committee for taking time to discuss this system
which--by any measure--has failed the taxpayer and failed American
students and families.
So why do we have accreditation? In passing the Higher Education
Act nearly 50 years ago, Congress linked accreditation and federal
student aid to prevent students from squandering money on diploma
mills. It took accreditors who had traditionally been peer review teams
focused on self--improvement and made them gatekeepers of federal
dollars. According to the Act, recognized accreditors were to serve as
a ``reliable authority'' on the ``quality of education or training
offered.'' In other words, the federal government delegated the
determination of what schools would receive Pell grants and federal
student loans to agents known as regional or national accreditors.
Accreditation was thought to be a good proxy for quality. This
assumption has been proven wrong.
Today, nearly 7,000 colleges, universities, and professional
schools in the United States are accredited (sometimes by more than one
accrediting body). And institutions rarely lose accreditation. Parents
and the public mistakenly believe accreditation is a good housekeeping
seal of approval, proof that an institution has passed rigorous tests
and is capable of ensuring students will graduate with a quality
education. Sadly, that's not the case.
Higher education quality has declined under accreditors' watch.
Professors Richard Arum and Josipa Roksa recently reported in their
book, Academically Adrift, that 45% of students didn't demonstrate any
significant improvement in critical thinking, reasoning, and writing
skills during their first two years of college. After four years, a
stunning 36% still didn't show improvement. And this was among
accredited colleges. Meanwhile, the American Council of Trustees and
Alumni has reviewed nearly 1,100 accredited colleges and universities
and found that students today can graduate with vast gaps in their
skills and knowledge; a mere 20% of the surveyed schools require
students to study U.S. history or government; only 5% require
economics, notwithstanding the importance of this subject in our global
economy.
The Department of Education has, itself, documented troubling
academic decline. The most recent National Assessment of Adult Literacy
found that a majority of four-year college graduates could not compute
the cost per ounce of food items or reliably compare two editorials.
Employers, too, consistently report concerns that the quality of higher
education is inadequate for workforce needs. We are talking about a
national crisis.
Far from safeguarding taxpayer dollars and the public trust,
accreditation is actually doing the opposite. In the 2011-12 school
year, federal student aid amounted to $175 billion. Student debt now
exceeds $1 trillion.
It is not surprising that the chorus for reform is growing--on all
sides of the political spectrum--from President Obama who suggested an
alternative accreditation system based on performance and results, to
educators, outside experts, and citizens who are realizing that
accreditation has privileged the status quo and restricted innovation
in ways that undermine America's global leadership. In their book, A
Dream Deferred, professors Stoesz, Karger and Carrilio see
accreditation as nothing more than an outdated industrial-era monopoly.
There are many good people doing their best to function in a broken
system. And, as you have heard today, there are many who believe that
the system is sound and that amendments are all that is necessary. But
I would submit to you that it's urgent for Congress to overhaul and
completely modernize the quality assurance process. If we are going to
achieve greater access, quality, and affordability (and we must), we
need a simpler, transparent system that ensures financial stability,
outlines key markers of academic quality, and allows accreditors to
thrive as voluntary associations for the self-improvement of higher
education.
Why is an overhaul of accreditation in the Higher Education Act
needed? Let me explain six fundamental problems with the existing
system.
Gatekeeping and self-improvement don't mesh. As it currently
exists, accreditation is a house divided against itself. The kind of
peer review that assesses and enhances quality cannot thrive alongside
the gatekeeping function necessary to referee an institution's
eligibility to receive federal funds--a financial life and death issue
for most colleges and universities.
Accreditation is a perfect example of regulatory capture. The very
people who benefit from federal funds--administrators and faculty who
constitute accrediting teams--are the people who determine whether
federal funds should flow. They know they will be judged by similar
accrediting teams, making them unwilling to apply rigorous
accountability standards.
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.'' Given this
self-referential system, it is no wonder that academic quality has
declined under accreditors' watch.
Accreditors operate as a monopoly. Accreditors describe themselves
as private voluntary membership organizations. But, quite frankly,
there is nothing voluntary about them. In order to receive federal
financial aid, colleges and universities must be accredited under
existing law (and one can count on one hand those schools which do not
depend on taxpayer dollars). To become accredited, institutions must
pay membership dues to one of the regional or national accrediting
bodies. And because the federal approval process allows the regional
accrediting bodies to divide the country into regional cartels,
institutions such as University of North Carolina-Chapel Hill or the
University of Ohio, under existing law, effectively have only one
accrediting body they can join. Accreditors, in other words, can hold a
gun to the heads of college and university members that seek approval
to receive federal funds.
Accreditation is a barrier to innovation and is putting our global
leadership at risk. Nearly 15% of U.S. college students study without
ever setting foot on campus. The lecture as the primary means of
delivering learning is rapidly being replaced by new teaching methods
that blend technology and classroom experiences in ways that boost
student outcomes. America's leading universities and faculty are
creating Massive Open Online Courses (MOOCs) in which hundreds and
thousands of students from all parts of the world enroll in a single
course. And students and families have, thanks to the worldwide web, a
plethora of resources about colleges and universities that were not
even imagined in 1952 when accreditation was first adopted. One only
need to acknowledge the changes in the higher ed landscape to realize
that a change in the regulatory process--which has no framework for
dealing with MOOCs and is still largely focused on the traditional
constituencies of four-year bricks and mortar institutions--is long
overdue.
Accreditation is too costly. At a time of limited resources,
accreditation adds to institutional costs without providing clear
benefits. Princeton provost and incoming president Christopher
Eisgruber (Appendix A)--in recent written testimony to the Department
of Education's National Advisory Committee on Institutional Quality and
Integrity--explained that the cost of federally-mandated accreditation
often exceeds $1 million for a single institution and hundreds of hours
of staff time. Stanford calculated that in 2009-10, it expended well
over a million dollars towards reaccreditation, without even tallying
the costs of the six years needed for the entire reaccreditation
process. Vanderbilt University estimated that it devoted 5,000+ hours
to accreditation-related work annually and that its School of
Engineering devoted 6,250-8,000 hours annually, in years when reports
were not due. The University of Michigan estimated $1.3 million direct
and indirect costs. And this does not even begin to address the costs
necessitated by other input-based standards, lengthy approval processes
for institutional changes, and opportunity costs.
Accreditation interferes with institutional autonomy. Rather than
ensuring ``educational quality,'' accreditors have increasingly
intruded in governance and institutional matters to tie the hands of
America's colleges and universities. The ABA, which accredits many law
schools, currently insists on a certain percentage of tenured
professors, limits the amount of online learning, and compels a minimum
number of instructional hours, all of which micromanage how a law
school may be run--not to mention add cost. In 2012, although current
University of Virginia policies reserve complete authority to the board
in matters of hiring and firing a president, the Southern Association
of Colleges and Schools placed UVA on warning, concluding that the
University failed to comply with standards regarding governing
processes and failed to consult the faculty before terminating the
president. This is not the first time accreditors have engaged in what
amounts to a power play with leaders on campus. In written testimony to
NACIQI, then president of Dartmouth, Jim Yong Kim, now head of the
World Bank, criticized accreditors for often substituting their own
judgment for that of an institution's trustees and administrators. And
former University of Colorado president Hank Brown concurred in a Wall
Street Journal column calling on Congress to overhaul the failed
accreditation system ``before it's too late'' (Appendix B).
That's why the time has come to replace accreditation as the
linchpin of federal student aid.
I'd like to outline one option which has received support from
Republican and Democratic members of NACIQI and been submitted to
Secretary Arne Duncan in response to his request for advice on HEA
reauthorization. Over a quarter of those voting supported the
alternative, submitted by Neal and Arthur Rothkopf, former president of
Lafayette College (Appendix C).
This alternative would ensure baseline financial protection and
provide key data on student learning in a far simpler and transparent
system of quality assurance. And it would break the link between
federal student aid and accreditation.
To protect the federal dollar, institutions would establish their
financial stability, as they must do today, and post a statement on
their websites, certified by an independent auditor, that they have
sufficient resources to ensure that all enrolled students can be
supported to the completion of their degrees. If the statement is not
supplied, or is found inaccurate by the independent auditor, federal
funds would be cut off. Alternatively, institutions could present a
bond.
At the same time, schools would be required to provide families key
information in a clear and readily accessible format on an annual
basis, including cost of attendance; degree programs; graduation rates
disaggregated by demographics; student loan default rates; student
outcomes measured by licensure test results; and job placement rates--
much of which is already collected for the Department of Education's
College Navigator site. This could again be independently certified so
that if the data is falsified or inaccurate, federal funds would be cut
off.
Removing the gatekeeping function for Title IV puts all
institutions on a level playing-field in terms of access to federal
funds. At the same time, this alternative provides more consumer
protection and quality assurance than the current accreditation system
provides.
And let me be clear. This alternative would not create any new
federal benchmarks or insert the federal government into the workings
of our colleges and universities. It would, instead, empower
individuals to make their own educated choices and allow institutions
to focus on key metrics of student success. Indeed, the proposal takes
its cue from Stanford provost John
Etchemendy, who stated in written testimony that, ``accreditation
is no substitute for public opinion and market forces as a guide to the
value of the education we offer.''
This new system would model transparency and accountability, and it
would be a considerable contrast to the existing accreditation system
whose stamp of approval offers virtually no public information. If you
look at the websites of accredited institutions in your Districts, you
will find little more than that the school is accredited, and, on
occasion, a disclaimer--even more disquieting--namely, that the
accreditation does not apply to any programs at the school, only the
institution.
Meanwhile, accreditors would return to their original function--
voluntary institutional self-improvement--where their judgment would
reflect the best practices of their peers and no longer be confused by
the competing and contradictory gatekeeping role. They would offer
their stamp of approval in education much as the very distinguished
LEED system does in architecture.
There, through voluntary standards, LEED has made Gold, Silver, and
Platinum universally-recognized in the marketplace for environmentally-
friendly construction. The power of the LEED imprimatur rests in the
honest and objective application of meaningful criteria--and needs no
governmental mandate.
There is no time to wait. It's time to realize accreditation as a
gatekeeper for federal student aid is ineffective and intrusive. If we
want to lower the cost to colleges and universities and reduce federal
intrusion in higher education, we can start by demanding an end to this
opaque, outdated regulatory system that benefits college insiders--at
the expense of students and taxpayers.
appendix a
[GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
______
Chairwoman Foxx. Thank you very much.
I now recognize Mr. Carey for 5 minutes.
STATEMENT OF KEVIN CAREY, DIRECTOR OF THE
EDUCATION PROGRAM, THE NEW AMERICA FOUNDATION
Mr. Carey. Thank you, Madam Chair, Ranking Member Hinojosa,
and members of the committee.
The federal government disperses $150 billion per year in
support of higher learning and nearly every dollar goes to an
accredited college or university. Students, parents, and
taxpayers rely on the accreditation system to protect their
interests. That system is failing.
Recent years have seen broad evidence of abuse and consumer
exploitation in for-profit and non-profit colleges alike. All
of them were accredited.
Last year 454 colleges reported 6-year graduation rates
below 30 percent. All of them were accredited. Academic
standards are in decline; students work half as much as they
did in the 1960s, while the proportion of all course grades
given an A rose from 15 to 43 percent.
Nearly 20 percent of students report studying less than 5
hours a week outside of class all at accredited institutions.
There are currently almost 6 million Americans in default on
student loans taken to attend accredited colleges and
universities. Why has this happened?
Well, I echo the comments of my colleague, Anne Neal; a
system built around collegial peer review is different than a
system built around necessary regulation of organizations
taking large amounts of taxpayer dollars.
There is also a financial conflict of interest built into
the system. Accreditors are financed by fees and dues paid by
the same institutions they evaluate. This is like bond rating
firms giving AAA ratings to mortgage backed securities sold by
the same firms that pay their fees. It does not work out well
in the long run.
Accreditors use those fees to conduct work that is largely
hidden from view while Congress has restricted the ability of
accreditors to enforce academic standards.
Colleges are free to define their own standards of learning
which accreditors must accept. Unsurprisingly, nearly all
colleges believe they are successful. Unfortunately research
such as Richard Arum and Josipa Roska's ``Academically
Adrift,'' which found limited or no learning among a large
number of college graduates suggests otherwise.
Accreditation is also a major barrier to innovation.
Imagine if in 1970 Toyota had needed General Motors' permission
to start selling cars and was required to build the same kind
of cars in the same way using the same labor contracts in the
same kinds of factories.
The American automobile market would have been very
different and not in a way that was good for consumers and
competition. Because of accreditation, that is basically the
way higher education works today.
Imagine for example that a Nobel prize-winning scientist
wanted to create a startup company that did nothing but offer
the world's greatest undergraduate physics curriculum on-line
and charge one-tenth as much money as typical students pay
today.
Under current law, a student could give their Pell Grant or
Stafford Loan money to the most dysfunctional or chronically
mediocre college in America, but not to that Nobel Prize winner
and his or her company. Why? Because of accreditation.
The problem is not that the Nobel Prize winner's startup
would fail to meet existing accreditation standards; it is that
existing accreditation standards don't even apply to that kind
of scenario.
So we recommend the following changes to the accreditation
process. Accreditors should create multiple tiers of approval
to distinguish excellent institutions from those who only meet
minimal standards.
They should be required to publicly disclose all
accreditation documents including negative information about
local colleges.
Congress should remove financial conflicts of interest from
the system. Instead of paying the same organizations that
evaluate them, colleges should pay accreditation fees to the
U.S. Department of Education, which would then disburse money
to accreditors based on volume and performance. Accreditors
that approve colleges with high default rates on federal
student loans, for example, would be financially penalized.
Students would also benefit from creating a new system of
approving innovative higher education organizations, not just
colleges, to receive federal financial aid. Under such a
system, organizations would be allowed to seek approval for
individual programs or even individual courses that meet high
standards of value and quality.
They would have to disclose what learning outcomes students
would need to achieve, what process would be used to evaluate
those outcomes, and the actual student learning results on an
ongoing basis.
To ensure that such a new system promoted needed price
competition in higher education, we would suggest that
available financial aid per course be set at 50 percent of the
current per course average amount available for a full-time
student receiving a Pell Grant.
In other words, organizations applying for approval under
this system would have to meet much greater standards of
transparency and accountability for learning and do it for half
as much money compared to colleges working under the existing
system.
This would create the kind of market competition and
downward pressure on prices that is the only real solution to
the long-term cost crisis in American higher education.
This is not a problem that can be regulated away. We need
new competitors in the market to provide better services for
less money, and we need the accreditation system to not stand
in the way.
Thank you very much.
[The statement of Mr. Carey follows:]
Prepared Statement of Kevin Carey, Director,
Education Policy Program, New America Foundation
It is difficult to overstate the importance of higher education
accreditation. Of the $150 billion per year in grants and loans that
the federal government disburses in support of higher learning, nearly
every dollar goes to an accredited college or university. Students,
parents, and taxpayers rely on the accreditation system to protect
their interests. Accreditation is the only college quality control
system of national scope, the only mechanism by which the federal
government decides who gets to be a college and who does not.
And it is failing.
College is becoming more and more expensive, pricing out middle-
and lower-income families and driving more students into debt they
cannot repay. At the same time, the quality of the education colleges
are providing is increasingly suspect. Only half of students who start
college earn a degree within six years, and the latest research
suggests that many of those who graduate don't learn very much.
Recent years have seen broad evidence of abuse and consumer
exploitation at for-profit and non-profit colleges alike. All of them
were accredited.
According to the U.S. Department of Education, 89 four-year
colleges increased their net price by over 40 percent between 2008 and
2010. All of them were accredited.\1\
---------------------------------------------------------------------------
\1\ http://collegecost.ed.gov/catc/Default.aspx#
---------------------------------------------------------------------------
Last year, 454 college reported six-year graduation rates below 30
percent. All of them were accredited.\2\
---------------------------------------------------------------------------
\2\ http://www.collegeresults.org/
---------------------------------------------------------------------------
Nearly six million people are currently in default on billions of
dollars in federal student loans, facing the prospect of ruined credit,
ballooning payments, and years of financial struggle because their
degrees aren't worth the price they paid. All of that money was
borrowed to attend accredited colleges and universities.
Meanwhile, academic standards are in decline. In 1961, full-time
college students studied full-time, devoting 40 hours a week to class
and academic work. By the 2000s, the average had dropped to 23 hours
per week.\3\ At the same time, the proportion of all course grades
given an ``A'' rose from 15 to 43 percent.\4\ Grades are going up as
student effort goes down. Nearly 20 percent of students report studying
less than five hours a week outside of class--all at accredited
institutions.
---------------------------------------------------------------------------
\3\ http://www.nber.org/papers/w15954.pdf
\4\ http://newamerica.net/publications/policy/
cracking_the_credit_hour
---------------------------------------------------------------------------
The accreditation system did not stand by and allow costs to
skyrocket and standards to decline because accreditors are indifferent
to these problems. They did it because the accreditation system is not
equipped to solve these problems. It never has been, and never will be,
as currently designed.
If Congress wishes to make meaningful process on the twin crises of
college cost and quality, it will need to think about accreditation and
quality control in very different ways.
The organization that accredits most colleges here, in Washington,
DC, is called the Middle States Commission on Higher Education. It was
founded in 1887 by a group of colleges that joined forces to lobby the
government for tax breaks. (Some things don't change.)
Middle States became one of the six so-called ``regional''
accreditors that dominate higher education quality control today. Those
organizations evolved into their current form in the first decades of
the 20th century, as voluntary non-profit clubs that performed peer
review. This remains the heart of accreditation. Officials from other
accredited colleges perform site visits and render a broad judgment on
the procedures, structures, and attributes of their peers. At the same
time, the colleges being evaluated undergo a lengthy ``self-
assessment.'' It is by nature a complicated and opaque process,
involving many meetings and a lot of paperwork. College officials say
it is valuable for self-reflection and continuous improvement, and
there is no particular reason to disbelieve them.
The problem is that this very old, secretive process of voluntary
peer review has been twisted over the years to serve a variety of
additional purposes for which it is ill-suited. Most significantly, the
federal government outsourced the job of protecting taxpayer and
student interests to voluntary accreditation associations. Accreditors
are the principal gatekeepers to hundreds of billions of dollars in
federal Title IV aid. If you are accredited, you can become rich and
famous running a college or university. If you are not accredited, the
financial cards are so heavily stacked against you that there is no
real opportunity to be a college at all.
This creates several large problems. There are huge incentives for
logrolling. Every college that sends a representative to a peer review
team knows that its turn for evaluation will eventually come. It is no
surprise, then, that colleges hardly ever lose accreditation, despite
years or decades of poor performance.
There is also a financial conflict of interest built into the
system. Accreditors are financed by fees and dues paid by the same
institutions they evaluate. This is like bond-rating firms giving
Triple-A ratings to mortgage-backed securities sold by the same firms
that pay their fees. It doesn't work out well in the end.
Accreditors use those fees to conduct work that is largely hidden
from view. Candid evaluations of problems and weaknesses are not made
available to the public. Accreditors and colleges insist that this is
necessary for peer review--which may be true. But it also means that
accreditation provides little or no useful information to students
choosing colleges, and that the public's agent of quality control is
concealing information from the public itself.
The scope of accreditation review is also limited by a combination
of capacity constraints and Congressional limitations. Organizations
such as Middle States have roughly 40 employees to oversee more than
800 institutions, meaning there is no way to engage in meaningful
oversight of all the schools it works with.
And even if they had such capacity, Congress has enacted
restrictions over the years that give institutions significant freedom
from accreditors' attempts to define high-quality learning.
Accreditors are required to evaluate 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 * * *'' The law further stipulates that
a college shall not be restricted in its ability ``to develop and use
institutional standards to show its success with respect to student
achievement * * *'' [emphasis added]
In other words, colleges are free to define their own standards of
academic success, which accreditors must accept. Unsurprisingly, nearly
all colleges believe they are successful.
Unfortunately, research such as Richard Arum and Josipa Roksa's
Academically Adrift, which found ``limited or no learning'' among a
large number of college graduates, suggests otherwise.
The result is that many institutions are visited only once or twice
a decade, and the review is limited mostly to organizational policy and
procedure. Accreditation involves no legitimate investigation of how
much students are learning or what kind of academic standards, if any,
are enforced. The existing accreditation process simply does not allow
for such questions to be asked, or answered. That is why standards have
fallen so far under the aegis of accreditation.
And despite the minimal oversight, accreditation is still very
burdensome for colleges. The self-evaluation for Georgetown
University's recent re-accreditation process, for example, is 107 pages
long, not counting 33 separate appendices, which include the ``OADS
Organization Chart,'' ``Faculty Sizing Planning, 2005-2006 (Appendix 18
from Georgetown University's Periodic Review Report for the Middle
States Commission on Higher Education, May 2007),'' the ``STIA
Curriculum Map,'' and ``Enlarged Figures for Standard 14.''
The accreditation process is also a major barrier to innovation.
Accreditation is a club, and if you want to join the club, or be
allowed to stay in the club, you have to show that you're like the
other members. This all but eliminates the possibility of price
competition from new entrants to the higher education market, which is
the only thing that will solve the nation's college cost problem in the
long run.
Imagine if, in 1970, Toyota had needed General Motors' permission
to start selling cars. To get that permission, it had to demonstrate,
after a number of years involving many meetings and a great deal of
paperwork, that it would build the same kind of cars as General Motors
in the same kind of way--the same weight and styling and gas mileage,
in the same kinds of factories, with the same labor contracts. The
American automobile market would have been very different, and not in
way that was good for consumers and competition.
That's the way higher education works today. New entrants to the
college market are in a Catch-22: They have to conform to the standard
model and enroll students before they can become accredited, but they
need accreditation to compete on a level financial playing field and
enroll students. It's little wonder that while whole American
industries have been transformed in recent decades, most of higher
education looks remarkably the same--except it's a lot more expensive.
Virtuous competition does not come from new organizations built to
be as large, expensive and complicated as the old ones. Instead, it
comes from nimble, flexible competitors using the latest technological
innovations to offer customers a better service for a lower price.
Assume, for example, that a Nobel-prize winning scientist wanted to
create a start-up company that did nothing but teach the world's
greatest undergraduate physics curriculum online, a multi-course
sequence that uses the latest discoveries in cognitive science along
with cutting-edge teaching tools. Because of economies of scale, and
because such an organization would be unburdened by administrative
bloat and decades or centuries of tradition, it could charge one-tenth
as much as a typical student pays today.
Under current law, a student could give their Pell grant or
Stafford loan money to the most dysfunctional or chronically mediocre
college in America--but not to the Nobel Prize winner. Why?
Accreditation. The problem is not that the Nobel Prize winner's start-
up company would fail to meet existing accreditation standards. The
problem is that existing accreditation standards don't even apply to
such a higher education organization.
We know that the prospect of such programs is not science fiction.
Right now, the world's greatest colleges and universities are serving
millions of students through Massive Open Online Courses, or MOOCs,
taught by leading professors at universities including Stanford,
Harvard, and M.I.T. At the moment, it's free to take these courses. But
it's easy to imagine students paying a small fee to take a proctored
exam, or receive additional one-one-tutoring. Yet they could not use
their federal financial aid to pay for these services, and the reason
is accreditation.
Students and families across America are increasingly calling for
someone to solve the problem of rising college costs. No such solution
is possible in a higher education system ruled by institutional
accreditation. As long as incumbent colleges get to decide what the
meaning of ``college'' is--as long as only ``colleges'' as we have
historically known them can compete financially on fair terms--higher
education will continue to become more ruinously expensive, and deeply
rooted quality problems will not improve.
The following changes to accreditation can help fix this problem.
First, there a number of opportunities to improve the existing
regime of institutional accreditation. They include:
Require accreditors to create multiple tiers of
accreditation. The current system is binary an institution is in the
club, or it is out. This provides little consumer information and the
inevitable effects of log-rolling and bureaucratic pressure create low
minimum standards. Accreditation status is essentially meaningless for
the best colleges and too meaningful for the worst. Accreditors should
reduce the burden on institutions that succeed in serving students well
while place greater scrutiny on less-successful colleges, including
plans for stronger monitoring, meaningful improvement plans, and a
clear timeline for eligibility loss.
Require accreditors to publicly disclose all accreditation
documents. The possible benefits of secrecy to the peer review process
are outweighed by the interests of transparency and public disclosure.
As long as accreditors are serving a public function by granting and
denying access to the Title IV financial aid system, their work should
be available to see.
Remove financial conflicts of interest. Instead of paying
the same organizations that evaluate them, colleges should pay
accreditation fees to the U.S. Department of Education, which would
then disburse money to accrediting organizations based on volume and
performance. Accreditors that approve colleges with high default rates
on federally subsidized student loans, for example, would be
financially penalized.
Accreditors could choose not to conform to these new requirements,
in which case they could continue to operate as they were historically
founded: as voluntary non-profit organizations with a primary mission
of conducting peer review. They would not, however, have the authority
to grant colleges eligibility to receive Title IV funds.
The second set of needed accreditation changes involve creating new
methods of giving innovative, high-quality, low-cost higher education
organizations access to the federal Title IV system. This approach
reflects policy ideas recently advanced by both Democrats and
Republicans. In policy documents accompanying the 2013 State of the
Union Address, President Obama proposed ``establishing a new,
alternative system of accreditation that would provide pathways for
higher education models and colleges to receive federal student aid
based on performance and results.'' The distinction between ``higher
education models'' and ``colleges'' suggests liberating students from
the incumbent college model and allowing entrepreneurs to develop new
methods and designs that meet rigorous quality standards.
In his response to the State of the Union, Senator Marco Rubio
called for ``student aid that does not discriminate against programs
that non-traditional students rely on,'' again suggesting that the time
has come to create new opportunities for non-traditional organizations
to receive federal financial aid.
Some of these innovations can be advanced using existing statutory
authority. The U.S. Department of Education recently wrote a ``Dear
Colleague letter'' describing how colleges can be approved to offer
courses and programs under the ``direct assessment'' provisions of the
Higher Education Act. The ``experimental sites'' provisions of HEA also
hold promise for supporting and seeding innovation. It will be
important for established accreditors to help facilitate this process
and not stand in the way of colleges that are working to adopt
innovative, high-quality, low-cost higher education models that serve
the needs of diverse students.
But in the long run, students would benefit most from creating a
new system of approving innovative higher education organizations--not
just colleges--to receive federal financial aid. Such a system would
have the following characteristics:
Course- and program-level approval. The ``traditional''
college student who takes all of his or her courses from a single
institution is already a thing of the past. Most students who earn
bachelor's degrees today accumulate credits from multiple institutions,
and this trend is likely to continue. The archaic practice of limiting
financial aid to colleges that offer complete degree programs is a
barrier to innovation and price-reducing competition. Both non-profit
and for-profit colleges should be allowed to seek approval for programs
and individual courses that meet high standards of value and quality.
Real standards of quality. The current accreditation
system evaluates organizations, not learning. Programs and courses
approved under the new system would have to disclose what learning
outcomes students would need to achieve, (B) What process would be used
to evaluate those outcomes, and (C) Actual student learning results on
an ongoing basis.
Better value for students, families and taxpayers: To
ensure that the new system promotes needed price competition in higher
education, available financial aid per course would be set at 50
percent of the current per-course average amount available for a full-
time student receiving a Pell grant.
Multiple tiers of performance. An organization's success
in serving students should be reflected in what types and amounts of
aid it can receive, as well as how much administrative burden it faces.
High-quality providers in the new system should have fewer time-
consuming obligations, while those that struggle should be subject to
stronger ongoing monitoring and expectations for improvement or loss of
eligibility.
In other words, organizations applying for approval under the new
system would have to meet much greater standards of transparency and
accountability for learning results and do it for half as much money,
compared to colleges working under the existing accreditation system.
If no organizations choose to compete under these conditions, there
would be no harm to the taxpayers. If, however, innovative
organizations approved under this system used new technology to create
a new market for high-quality, low-cost higher education programs, it
would alter the dynamics of the higher education market, forcing
existing colleges to improve quality and reduce prices on behalf of
students.
Without major reforms to the accreditation system, the American
higher education system is doomed to more of the same: rising prices,
declining quality, missed opportunities for upward mobility, and a
diminishment of the nation's human capital in a time when education is
the key to economic prosperity and civic life.
______
Chairwoman Foxx. Thank you very much Mr. Carey.
I thank all the witnesses again.
I now recognize the chairman of the Higher Education
Workforce Committee, Mr. Kline, for 5 minutes.
Mr. Kline. Thank you, Madam Chair.
Thank the witnesses for being here today for excellent
testimony. It is an issue which we have been struggling with
frankly and debating among ourselves and as we look at
reauthorizing the Higher Education Act, this we think is a very
key piece to that.
So let me start Ms. Neal with you. You are suggesting that
we dramatically reform the accreditation process and you were
talking about information being made available to students and
parents and so forth. Would there be no word called
accreditation in your system?
Ms. Neal. Thank you very much. In my system, the
accreditors could still flourish and in fact it envisions
returning accreditors to their original role which was to serve
as voluntary, private, peer-review organizations.
So they could in fact do the very things that we have heard
from both accrediting bodies and Kevin Carey. They could have
tiers of approval. They could have sector-based approval. They
could have a range of approvals that would provide considerably
more information to consumers than they receive now, but what
they would not have is the gatekeeping role.
So I think we could be assured under this system rather
than the conflict between self-improvement and accountability
and quality assurance.
In this case they would simply be self-improvement, peer-
review groups, aiding and assisting institutions that chose to
have their assistance.
Mr. Kline. So in that system what would the role of the
Secretary of Education be in this gatekeeping business?
Ms. Neal. The gatekeeping would essentially be set by
financial solvency, which would be established as it is now by
the Department of Education, but what we would add is an
independent statement that would be certified--so that the
Department of Education could proceed and sanction and take
away federal dollars from an institution that is not federally
financially solvent.
And then we would also have institutions providing key data
for families seeking to go to college, which quite frankly are
just not available now. As I said earlier, when schools are
accredited we really don't know anything about them, and
accreditors themselves say that it does not ensure that
programs in school are good.
It simply is a blanket seal that really tells us very
little and as Kevin has indicated, masks the fact that many of
these institutions are graduating less than 25 percent on the
federal dollar.
Mr. Kline. You use the term ``independent agency.'' What
would that be?
Ms. Neal. Independent--well, in this case, this would be an
independent auditor--what we are envisioning--I am sorry, what
we are envisioning is that the institutions would indicate to
students that they would have sufficient resources to pay for
them in the event that they went belly up.
And that this then would be certified by an auditor.
Similarly, information about a particular outcome, about price,
about license rates could be certified by an independent
auditor so that in the case that they are engaging in fraud or
deceiving the consumer, actions could be taken against them. So
we would have some basic stability and insurance for the
consumer as well as information.
Mr. Kline. Okay, thank you very much.
Dr. Sibolski and Dr. McComis, how much time does it take
for an institution to become accredited initially? And do you
have any idea what the expense associated with that might be?
Ms. Sibolski. Let me take the first answer on that. For an
initial accreditation it can take up to 3 years for an
institution to go through the process that exists today, and
that is because there are several steps, and my full testimony
does outline what all of those steps are that we take an
institution through.
One of the reasons for that amount of time is so that we
are being sure that we are accrediting an institution that will
be solidly accreditable and that we won't find ourselves 6
months after having accredited an institution with a need to
put that institution on sanction of some sort.
So we want to be careful and we want to be sure that an
institution is doing an application for us and then doing a
clear self-study.
You had another question in there?
Mr. Kline. Cost.
Ms. Neal. The cost. Actually no, I haven't done a study of
cost of that. Certainly could be done, but it hasn't to this
point.
Mr. Kline. Okay. I certainly have some follow-up questions,
but I can see the light is orange and getting ready to go red,
and I am in an ever sort of futile effort to convince my
colleagues that we ought to stay within the time limit, but at
some point if others don't ask we'll come back to you for
answers on the record about what is the time and what is the
cost for an already accredited institution to open another
campus, for example. So anyway thank you very much for your
testimony, and I yield back.
Chairwoman Foxx. Mr. Hinojosa, I recognize you for 5
minutes.
Mr. Hinojosa. Thank you.
My first question is to Mr. Carey. New models of education
and learning are happening everywhere. Distance learning and
all that has exploded here in the last 5 years.
It is becoming clear that many Americans are learning
important skills both inside and outside the classroom.
However, it is very difficult to gain access to Title IV money
and perhaps rightly so. Should the evolution of new high
quality, low-cost centers of learning like MOOCs, which I think
stands for massive open-line courses, have the opportunity to
access Title IV funds?
Mr. Carey. Thank you. I believe they should. I think that
the kind of competition the higher education market needs won't
come from other colleges. It will come from flexible, low-cost
providers of higher education that are nimble that focus on
certain aspects of the college experience. They don't need to
provide everything to everybody as the----
Mr. Hinojosa. I agree with you, but in this case if we were
to get what you are talking about and I agree with, could the
current accreditation system we are using accommodate these new
and unique entities? Or should an alternate system be created
in tandem with the current one?
Mr. Carey. The current accreditation system cannot
accommodate them. It is a club of colleges that admits other
colleges to the club. I believe we do need an alternate system
to work in tandem with the existing accreditation to provide
access to Title IV funds so new organizations can compete on a
level financial playing field if they are willing to subject
themselves to high standards of quality and value on behalf of
students.
Mr. Hinojosa. Thank you.
Ms. Neal, are there regulatory functions that the
department and the U.S. Congress have delegated to accreditors
that might be better handled by others?
Ms. Neal. As I indicated in my proposal, the Department of
Education has delegated to accreditors this quality review, but
in essence they have really provided no guarantee of quality.
So what I think--appreciating the need to give autonomy to
our colleges and universities since that has been a great
strength, the greatest strength of American higher education--I
think a system that will ensure baseline stability and then
provide consumer information is one that will intrude the least
but provide the most protection, which we don't really have
under the current system.
Mr. Hinojosa. Ms. Neal, you, in your statement, indicate
that accreditation is too costly and you mentioned some of the
Ivy League schools like Princeton and Stanford, Vanderbilt,
University of Michigan all saying that they are going to be
spending plus or minus $1 million, plus thousands of staff
hours to do this accreditation. How can that be changed?
Ms. Neal. Again, I think that the process that we currently
have is a burdensome one. As you have heard, it takes multiple
years. It requires vast piles of paper-pushing. Often a focus
on matters that do not relate directly to educational quality,
which is the very purpose of the accreditors according to the
existing Higher Education Act.
We see numerous accrediting bodies focusing on governance,
focusing on management. For instance the American Bar
Association has a certain percentage of tenured professors that
it requires. It limits on-line learning for students. It also
restricts instruction. It does not allow the institution to
make these decisions on its own. These are all cost-inducing
efforts by the accreditors that have very little to do with
quality.
Mr. Hinojosa. You also said in your statement that some of
the accreditation is secretive. How can they make it secretive?
Ms. Neal. Well again this is the nature of peer review.
Peer review is for self-improvement. Collegial bodies are
helping one another to try to enhance better quality.
Now one can question whether or not that has happened at
all, but the essence of this peer-review, self-improvement is
not to tell the world. It is to quietly work together to figure
out how to do things better.
So it is essentially contradictory when you are trying to
have a quality assurance accountability regime.
Mr. Hinojosa. And the President, in your remarks, you said
President Obama suggested an alternative accreditation system
based on a performance and results to the educators, outside
experts, and citizens. Is that realistic? Can that be done?
Ms. Neal. Well, I certainly think that it underscores the
broad-based concern about the current system. Obviously the
President does not feel that it is focusing properly on
affordability and on performance, and certainly my remarks
would second that.
I think the proposal that I set forth which is on financial
stability and key data--it is interesting to note that that was
supported by a bipartisan group of members of the National
Advisory Committee on Institutional Quality and Integrity.
So I think that there is broad-based support across the
party line here to do some radical changing of the
accreditation system in order to protect the consumer and to
keep basically the federal government out of the workings of
our colleges and universities.
Mr. Hinojosa. I yield back.
Chairwoman Foxx. Thank you, Mr. Hinojosa.
A thought that strikes me in terms of your comments about
secrecy as someone who has been through accreditation, the
thing that hit my brain was that old saying, ``a camel is a
horse designed by committee.''
As I think about accreditation and the pain that most
schools go through, I think about that in terms of all the
machinations that happen and while you are trying to get some
good things out of it, you wind up with a camel instead of a
horse.
I don't know if that helps you any or not but I think
people that have been through it could identify with that.
I now recognize Mr. Walberg for 5 minutes.
Mr. Walberg. Thank you, and what does a subcommittee design
then? I would ask the--what does a subcommittee design then? I
will leave that for later.
Dr. Sibolski, interested in hearing your testimony, and
specifically the insight you gave on how schools go about
becoming accredited.
As you know tuition prices continue to climb. Students just
expect that every year and wonder in amazement how in the world
they are going to afford it.
As student tuition dollars fund all types of higher
education activities, I am curious as to the actual cost and I
go back to what our full committee chairman requested about
costs.
When we have schools such as University of Michigan that
come upwards of $1 million to go through the accreditation
process, it has to have some impact upon our students and
students' tuition.
I think you indicated that you don't have a cost figure for
what it would cost an institution of higher education to go
through the initial accreditation process, am I right?
Ms. Sibolski. That is correct.
Mr. Walberg. So you wouldn't have any understanding then of
what it would take a school to go through reaccreditation
either?
Ms. Sibolski. Actually I could answer that, I think. While
there are some indications out there of the type that Ms. Neal
commented on, there are also some other studies that have been
done.
One in particular that I am familiar with is a doctoral
dissertation that was done by someone out in California that
addressed the cost of reaccreditation, and found through that
study that the average price was a good bit lower than what the
research universities had indicated in the testimony
previously.
Even at that though, I have to admit that what the result
was that came out in that study, was that over the course of 7
to 10 years what would be a normal accreditation cycle, the
price was still someplace in the neighborhood of $400,000.
So do the math and it is going to be $50,000 or $60,000 a
year. That is not inconsequential and we know it, and some of
what we try to do is to make sure that an institution is using
the process not just to become accredited, but to do something
that will be of benefit to the institution, too.
So while we have to do self-studies, we certainly want an
institution to look at areas where they believe that they need
to make some improvements. Perhaps focusing on planning and
budgeting, perhaps focusing on areas like student learning
outcomes assessment.
Mr. Walberg. In your term as president, how many schools
have gone through the accreditation process?
Ms. Sibolski. Oh gosh, we do--the Middle States Association
has--the Middle States Commission on Higher Education has 532
accredited and candidate institutions and we run on a 10-year
cycle.
I have been there about 10 years so we have been through
that full cycle and the accreditation actions are taken both at
the 5-year period and at the 10-year period. So just double up
the number and that is probably a good estimate.
Mr. Walberg. Okay.
Dr. McComis, I guess I would ask you, I saw you doing some
calculating down there. What would be the cost for a school to
go through initial accreditation and subsequently
reaccreditation?
Mr. McComis. Congressman, for initial accreditation the
average length of time is 2 years. Direct costs to ACCSC as an
agency is less than $10,000. It depends on the size of the
institution; the larger the institution is, the more on-site
evaluators are required for that process.
When I say direct costs I mean the application process, the
on-site evaluation processes that go with that, would be less
than $10,000.
Mr. Walberg. So Baker College in my district would go
through the process in 2 years, $10,000 cost?
Mr. McComis. Depending on the size of that organization.
Mr. Walberg. Okay.
Ms. Neal, you have had some extremely constructive
criticisms and that the fact that you indicated that parents
mistakenly believe that this is a good seal of approval. Expand
a little bit on what you see as changes that can be made in
Higher Education Act reauthorization that would make it better
for these parents to understand that they are getting the bang
for their buck?
Ms. Neal. Well, as we heard from Kevin we are looking at
$150 billion to $175 billion in student financial aid. We are
also looking at $1 trillion in default. So this is a major
issue for you all and for the American people.
And so I think there is a great concern that we find a
quality assurance system that will protect the federal dollar
and that will also ensure quality and provide information to
families who are seeking to find a college.
And so I think today the system that we have really just
doesn't do that. As I indicated, the consumer is provided
virtually no information and in fact, I think is often deceived
by the so-called good housekeeping seal of approval because it
may mask the fact that the institution is graduating very few
people and that many of the students have massive debts.
It really doesn't tell the consumer much of anything, and I
think what we need to do to protect the federal dollar is to
have essentially a guarantee that the institutions which are
receiving funds are financially stable and will be able to
compensate students and then to also to provide information
that will be key indicators of student success at colleges and
universities.
And I know when Shirley Tilghman spoke to the National
Advisory Committee on Institutional Quality and Integrity
talking about issues such as alumni satisfaction, graduation
rates, placement rates; these sorts of criteria that will help
the consumer to be able to compare and contrast between
institutions and to be a set of standard data that could be
outlined that would make it much easier for parents to walk
with their wallets to a better value and a better institution.
Mr. Walberg. Thank you.
Chairwoman Foxx. Mrs. Davis, you are recognized for 5
minutes.
Mrs. Davis. Thank you Madam Chair.
Thank you all for being here.
I noticed, Dr. McComis, you have actually had a fairly
extensive time to look at institutions and the career
institutions that you have been involved in, and in fact a
number of them you have acted on.
Do you--would you suggest that some of the institutions you
look at are more risky and in fact does that indicate why some
of those were not accredited? What do you think is going on?
How do you compare to other accrediting institutions?
Mr. McComis. Well, I have been with the agency for 18
years. Over the last 10 years or so just kind of looking at
some rough numbers, we have taken, you know, close to 85
actions to revoke accreditation.
I look at that as a part of the accountability process;
that institutions change over time, they become different, they
grow, they become participants in federal financial aid
programs.
And it is an important part of the process to continually
look at whether or not that institution meets the best practice
standards, give them an opportunity to make those
demonstrations, and if they cannot, then the accountability
side of the accreditation process must begin to ensue and have
action taken.
Mrs. Davis. As we look at innovation then, how does that
fit in? And especially with MOOCs, what are we doing then to
ensure that we are moving forward and providing for that
innovation and yet making certain that the cost factor is
something that families can handle, that young people can
handle?
Mr. McComis. Well I can speak--my agency has an allowance
for consortium and partnerships to be part of the accredited
process and part of the program, but the institution still
retains responsibility for that.
So with that partner that an institution can work with,
they may not be accredited or accreditable as Mr. Carey has
pointed out, but it can be part of the program. That
institution however still has to retain the responsibility and
the accountability for all the elements of the program.
So we have put that in place in order to allow for
innovation, to allow for portions of courses to be offered by
entities that might not otherwise be accreditable through our
normal process.
Mrs. Davis. Could the rest of you weigh in on, what should
this look like? I mean, as we move forward, where does that fit
in?
I think the other issue that is really important is how do
we judge outcomes as far as the opportunities for young people
to move on into the workforce?
One of the things we know about providing that information,
and we talk about that as it relates to the G.I. bill, for
example, and what institutions our veterans are going to, the
ability to be able to, you know, indicate the chances of
getting jobs after they leave a particular institution.
How do you feel that that actually is indicated in the
accreditation? Should it be? What kind of data should be
handled as we look at that issue as well? Anybody want to--Mr.
Carey?
Mr. Carey. I think, couple of things. There are many
opportunities now to gather exactly the kind of information you
are talking about. We can calculate for individual programs,
many college or university the percentage of people going on to
get jobs and how much money they make.
We know from surveys that the vast majority of students go
to college for one reason and that is to get a better job. So
absolutely, we should create that kind of information. We
should provide it to students and parents ahead of time so they
can make smart choices.
And I believe that if we are going to approve new models,
innovative kinds of approaches to higher education, we should
set a higher bar. We should set a very high bar for people who
want to do new things and work outside the system and that bar
should be defined in terms of student learning outcomes and
ultimately whether people are able to get jobs and pay back
their loans.
Mrs. Davis. Is that for information for people though, or
is it part of the accreditation?
Mr. Carey. I believe it should be both. There were really
no minimal standards in the accreditation process in terms of
student outcomes. You can be an accredited college and graduate
15 percent of your students every year, and I can point you to
examples of colleges where in fact that is the case.
There are no minimum standards in terms of the percent of
students who get jobs or whether they can pay their loans back.
That is all to the extent that we have such standards those are
parts of federal regulation.
So I do think they should be part of accreditation as well.
Mrs. Davis. Ms. Neal, did you want to comment? I am sorry.
Ms. Neal. I wanted to also talk about the innovation
question. I mean, the current accreditation process is a
decennial, every 10-year process. It is not one that is keeping
up with changes, and in fact, as I think we have heard, it
inhibits and hurts change in a very rapidly changing higher
education landscape.
And as Kevin has indicated, many of the things that we are
seeing come on board are the ones that are most likely to
provide access and affordability; two things that we want for
Americans.
So the current system really can't handle it. How can it be
handled? There are certain things out there now which are
beginning to address this, for instance, ACE now does an
approval process for individual courses so it is possible for
them to obtain credit.
And again, this is a very interesting area because transfer
of credit is also a very costly issue and it is one that is not
well handled by accreditation. It keys into issues of
articulation agreements and one of the questions that ACTA and
Kevin and others have raised is the privileging by accrediting
organizations of their own accredited institutions in the
matter of transfer so that often it may even be difficult to
transfer a SACS credit to another one because two different
accrediting agencies have accredited.
This obviously is not a good situation and we have in fact
asked the Department of Education and Secretary Duncan to
report to us on what the costs of this transfer difficulty are
causing for students.
Chairwoman Foxx. Ms. Neal, I am sorry. We are going over
considerably, and I am trying to be fair to everybody.
Mr. Guthrie, you are recognized for 5 minutes.
Mr. Guthrie. Thank you, Madam Chairman. I appreciate that
very much.
And actually, what Ms. Neal did lead into the question I
was going to ask, the first question I was going to ask any way
and Dr. Sibolski, in your written testimony you talked about--
and what we have heard a lot is that the accreditation process
stifles innovation.
We have heard that and we have also heard that it is very
expensive and so--but in your written testimony you said that
accreditation agencies are reforming their processes to adapt
to innovations within higher education, to be more compliant
with innovation and try to make it cheaper.
So what have your colleagues done to make the process of
accreditation easier or cheaper or to react to more--be more
reactive to innovation for institutions?
Ms. Sibolski. I think two different areas that you are
actually asking about right there. So let me take innovation
first.
We certainly are as outlined in my testimony, trying to
deal with--in the most direct instance right now, competency-
based education, and an awful lot of what is out there right
now is going--seems to be going in that direction where seat
time is not what we really would be measuring, but certainly we
want to look at skills, abilities, and so on as students move
through a program.
The current rules that we operate under do not allow us to
work with competency-based education, so we have to, sort of,
morph that into something that is acceptable through the
financial aid programs and that is through direct assessment
programs.
So, right to begin with, we have a little bit of confusion
with our institutions about--so what is it that they are really
asking about and how do we try to work with this.
We are dealing with that right now, and with the Middle
States Commission we have several institutions that have done
wonderful programs in competency-based education that have been
accredited actually by disciplinary accreditors but are not
eligible for Title IV programs. We are trying to fix that.
So that speaks to the innovation area. In terms of trying
to change our processes, we are aware of the cost. We are aware
of the need to try to pare this down, and I think the question
becomes how do you do that and still address some of the
questions that were towards the end of my oral testimony--how
do you make sure that you are doing a thorough job of doing the
accreditation activity and still make sure that it is cost
effective and timely. That is a tough thing to try to
negotiate.
But again, we do some processes that allow institutions
that are in good stead with us to actually move into a kind of
accreditation that allows smaller teams to visit, that allows--
--
Mr. Guthrie. I have only got so much time and I want to ask
one more question so I----
Ms. Sibolski. All right.
Mr. Guthrie [continuing]. And I appreciate that very much.
I appreciate what--but, Mr. Carey, you were talking about--I
understand if a Nobel Prize winner in physics wants to teach a
physics course, I would love for my kid to be able to go take
that course whether it's on-line or whatever.
But when we are dealing with federal tax dollars and--how
do you know you get what you pay for--and I would guarantee you
if we would say you can follow whatever course you take your
money can follow you, there will be a lot of people popping up
teaching courses.
And it is easy to bring up the example of Nobel Prize
winner because that is self-evident, that is somebody that can
teach a course or at least have something to learn from, but
how would you police what I would guess would be somebody
popping up on every corner trying to teach a course if the
money followed that.
Mr. Carey. I would say that anybody who wanted to get
approval under such an alternate system would have to guarantee
three things.
One, very explicit statement exactly what was being taught
and what students were expected to learn.
Two, what is the process by which learning results are
going to be evaluated.
And three, what are those learning results reported to the
public on a real-time basis so anybody whether it be a
lawmaker, a regulatory body, a state legislator, a parent, or a
student can see exactly what is going on.
Those are three standards that we do not apply currently to
accredited colleges and universities. You can't even tell what
the syllabus is for a lot of classes unless you email the
professor and ask and it is up to him or her to give it to you.
So I think by setting a high bar of at the minimum
transparency for what is being taught, how it will be assessed,
and what the results are, we are actually setting a much higher
standard than we currently have.
Mr. Guthrie. Would you argue that that if you go to an
accredited university--each course should be accredited? Is
that what you are--not accredited like in the traditional way,
but the way you are suggesting?
Mr. Carey. I think that we should for the new system if
people just want to sell one fantastic course and do nothing
else but specialize because I think that is where a lot of
innovation and competition happens in market places; if people
who specialize compete with large organizations, then yes----
Mr. Guthrie. It would be somebody outside of a traditional
university or college. This would be--you would still have an
accredited university that you go to or you could do these
alternative--you would have an alternative accreditation for
alternative courses?
Mr. Carey. Yes, that is correct.
Mr. Guthrie. I am out of time so I yield back, Madam
Chairwoman. Thank you.
Chairwoman Foxx. Thank you, Mr. Guthrie.
Mr. Tierney, you are recognized for 5 minutes.
Mr. Tierney. Thank you.
And thank the witnesses for the testimony.
Dr. McComis, I am going to ask you this question. I think I
am asking the right person. How is it possible that for so many
for-profit private institutions who have such an incredibly
high default rate on their student loans is such a--and very
poor graduation rate factor remain in the good graces of the
accreditors and get accreditation to begin with and keep it?
Mr. McComis. Well, certainly many national accreditors look
at program level outcomes or institutional level outcomes. That
is a primary factor that is reviewed. As part of the Higher
Education Act and regulations that ensued from that, there are
requirements for accreditors to look at cohort default rates
and to evaluate the extent to which institutions encourage
students to pay those loans back.
And my agency for example does a number of things to
monitor on an annual basis those----
Mr. Tierney. I guess--I hear what you are saying but can
you answer the question? How is it that they continually have
these high default rates and low graduation rates, but keep
getting accreditation and retaining it?
Mr. McComis. Well, the graduation----
Mr. Tierney. Who is not doing their job?
Mr. McComis. I am sorry?
Mr. Tierney. Who is not doing their job in the
accreditation area?
Mr. McComis. The benchmark by which cohort default rates--
and this is why the triad is so important as a measure for the
Department of Education to look at and to make a determination
as to whether or not----
Mr. Tierney. Then you are saying that you don't do that;
that is the department's job?
Mr. McComis. We don't set particular rate numbers to
evaluate the effectiveness of the program for cohort default
rates.
Mr. Tierney. Right. You could, but you don't. All right.
Ms. Neal, I am all for transparency. I think that is an
excellent thing only I just talked about one example where it
doesn't quite work no matter how transparent we are in making
sure that people know about the high default rates and low
graduation rates, people keep flocking to a lot of these
private for-profit schools and ending up with a lot of debt and
no certificate or no graduation diploma.
So do you agree there has to be something more than just
information because I don't think there is any evidence so far
that indicates that all the information that they have--and we
put a lot of transparency in the last higher ed bill, but
unfortunately, we don't see that that is driving a lot of
consumer decisions?
People are still sending their kids to very expensive
institutions and not having the costs held down.
Ms. Neal. Two things. I think that clearly we have seen
abuses and problems in the for-profit sector, but I think it is
also fair to say that we are finding the same kinds of problems
in terms of low graduation rates and defaults in the nonprofit
sector----
Mr. Tierney. To a much different degree.
Ms. Neal [continuing]. So I think we have to be fair across
the sectors here because we have got failure everywhere.
Mr. Tierney. So my question is, though--I agree that there
is failure everywhere, but it is exponentially higher in the
for-profits on the private schools on that, but on just
transparency, if we relied just on transparency, I don't think
there is any evidence that shows us that it is going to be the
answer.
Ms. Neal. It is always true to say that a consumer may pick
a bad place and it may not be the best one, but it gives----
Mr. Tierney. Well, but we are the federal government giving
money--we have got a responsibility to be accountable so we
don't want----
Ms. Neal. Well absolutely, which is why I think coming up
with a system that provides key data that admittedly our
imperfect proxy for quality but will provide a consumer with
some sense of graduation rates----
Mr. Tierney. How are you going to get--I hear all that. And
I don't mean to argue with you, I just got limited time. Great.
You have all this information. You have all the data. You throw
it all out there, who is to say the consumer is going to use it
properly or use it at all? There are a lot of people expecting
to send their kids to a----
Ms. Neal. I trust individuals to make good decisions for
themselves and I think----
Mr. Tierney. Okay, despite the lack of evidence that that
is going to happen.
Mr. Carey, who is going to set the standards in your
system?
Mr. Carey. So I--one way in which I may differ from Ms.
Neal is I do think that there needs to be a regulatory
function. I know that this is always a tricky conversation to
have about creating new federal regulatory power, but when we
are dispersing again $150 billion a year into the system, that
is where we are.
I think that--but I don't think that the setting of the
standards needs to come from accreditors necessarily. One could
imagine for example groups of scholars; one could imagine
industry groups contributing to the process----
Mr. Tierney. But we are still in the imagination stage in
this. We haven't firmed up an idea of who this is going to be.
Mr. Carey. Right.
Mr. Tierney. So we are a long way from that on that basis.
I was just trying to find out how much developed we had this
idea and I just note that, you know, having somebody have a
Ph.D. in physics putting an online course out in physics
doesn't mean they can teach anybody. I mean, we have all seen
some pretty boring and noncommunicative Ph.D.s out there so I
think it has got to be something beyond that on that basis and
I guess we are still looking to find out who set the standards
and to make----
Mr. Carey. I agree.
Mr. Tierney. All right.
Thank you. I yield back.
Chairwoman Foxx. Thank you, Mr. Tierney.
Mr. Hudson, you are recognized for 5 minutes.
Mr. Hudson. Thank you, Madam Chairman.
I thank the witnesses for being here today. I actually have
a chart I want to put up if the staff could throw that up.
This is a--it is a little difficult to see but this is a
chart that was given to me from a community college president
in my district that outlines the process of accreditation that
he goes through when accrediting the college.
I will just highlight a few things here. It is a little
difficult to see, but he begins the process and starts to
organize January 2011 and then goes through each step of this
process all the way up to the end with the board action June
2014.
So we are looking at a 3.5 year process. This is for a tiny
rural community college in a rural and disadvantaged community
in my district.
Obviously I am--I recognize the key role that community
colleges play particularly in areas like North Carolina that I
represent. I am a former trustee of a community college. The
community college--we have excellent colleges in North Carolina
that play a critical role in job retraining and helping create
jobs in our communities.
And--but what I am hearing from many of the college
presidents is that compliance with the accreditation process is
taking 3 to 4 years. It is extremely burdensome.
In this college example, their compliance report was 371
pages plus thousands of pages of electronically-linked
supporting documentary evidence.
The college president said that he is having to take
personnel away from the classroom to help prepare these
reports. It is an incredibly onerous process for the colleges.
I guess addressed to Dr. McComis, you have heard Ms. Neal's
model for an alternative to accreditation. I would just like to
offer you an opportunity to maybe respond to this process.
Is there a way that we can do this that isn't so
burdensome, that doesn't take so much time for the college, so
much cost for the college, pulling people out of the classroom?
How would you respond to this?
Mr. McComis. Well, certainly the accreditation process is
one that requires institutions to go through a process of self-
evaluation to demonstrate to their accreditor that they are
meeting those best practice standards, and yes, that takes
evaluative time and it takes effort and it takes thinking on
part of administrators and faculties to come together in a
partnership and in a group to make those kinds of assertions
for themselves to make that demonstration to the accreditors
that is there to look at the quality assessment paradigm that
they are meeting those best practice standards. That is part of
the gatekeeping function. That is why the federal government
relies upon accreditation to do that.
Now, for national accreditors, the institutions tend to be
smaller and the time periods tend to be less and the costs tend
to be less than a much larger research institution or college
or university for the regionals.
The average length of time for an institution to go through
a renewal process with my agency is just over a year. Cost
again is about--direct cost is about $10,000.
So----
Mr. Hudson. With all due respect, that is different from
what I am hearing.
Mr. McComis. Well, again, the institutions tend to be
smaller----
Mr. Hudson. Well this is a small community college, I
promise you, in a rural community in North Carolina. This is
not a major institution. Sorry for interrupting, but----
Mr. McComis. No--so again for an institution accredited by
my agency again it takes about again for the renewal a little
over a year and a direct cost to my organization of about
$10,000.
But the process is what is important and what Ms. Neal is
describing is one that takes away that assessment of all of
those input standards, all of those best practices.
Governance functions already exist and they aren't
producing the quality either, so to take away the regulatory
component or the oversight component of accreditation seems
counterintuitive to me.
We--there is no evidence that governance alone or the
institutions alone are going to be able to produce any more
quality or meet any more expectations than what accreditation
has attempted to produce.
Mr. Hudson. Thank you for your answer.
And Ms. Neal, with the rest of my time, would you like to
respond to that? I mean, I find your model interesting. I
certainly think the current model is too burdensome for our
colleges. We need to move toward something else. Maybe if you
could respond to what the doctor was saying.
Ms. Neal. I just wanted to concur that the cost really is
not being matched by the benefits. I think for institutions
such as the one in your district, and already college costs are
too high, so I think we really in an effort to protect the
federal dollar and to protect the consumer we have to find a
way that will be simple, understandable, not costly, and I
think that is why this alternative prescription which does keep
a regulatory role of the Department of Education that is
ensuring financial stability, I think there is a list that
comes out regularly about institutions that may or may not meet
the asset test that is required and it is not even clear to me
that even when those schools are on that asset test that they
are closed down.
So I think we would demand that the Department of Education
be more punctilious in applying financial stability and that
would be its regulatory role, and then we would fall back on
consumer information as an additional component.
Mr. Hudson. What--well, my time is expired. I will see if
we have another round, but thank you, Madam Chair.
Chairwoman Foxx. Thank you.
Ms. Bonamici, you are recognized for 5 minutes.
Ms. Bonamici. Thank you very much, Chairwoman Foxx.
And thank you all for this fascinating discussion. I don't
think there is any question here that all of us are committed
to find ways to improve not only accessibility in terms of cost
but also quality and this is an important discussion in that
regard.
Ms. Neal, in your testimony you cite ``Academically
Adrift'' and you talk about the troubling academic decline and
how the quality of higher education is inadequate; you call it
a national crisis--that is pretty alarming.
And Mr. Carey, you sound to some similar alarms with--you
say academic standards are in decline and I was especially
interested in the--and the significant decrease in the number
of hours that students study--pretty alarming.
But I wonder if we could talk a little bit about how much
of that really has to do with accreditation. It sounds pretty
clear that there are some changes that need to be made in the
accreditation system. No question, but how much of that change
is actually going to solve what you have identified as this
national crisis?
If we fix the accreditation system, we still haven't fixed
the funding cuts. We still haven't fixed the problem of a whole
generation of students who have gone through K-12 education
with a limited curriculum narrowed; they are missing arts and
music and classes that lead to critical thinking. So if we fix
accreditation, could you opine about how much we have actually
made a dent in what you have identified are the challenges?
Mr. Carey. Well I certainly wouldn't suggest that fixing
accreditation will solve all of those problems, but I do think
accreditation plays a key role. We know that the long-term
trends in higher education as you said declining academic
standards, prices going up and up and up, and it is not that
the people--it is not that the accreditors are indifferent to
those problems, it is just that as the system is built, they
don't really have any power to solve them.
So in addition to solving the finance problems in the
preparation of students in our K-12 schools and a host of other
issues, we need a quality control infrastructure that
encourages--that is such high academic standards and encourages
competition in the marketplace from colleges or other kinds of
organizations that can prove that the quality of their academic
offerings are very high and at a high value for students, and
we don't have that now.
Ms. Bonamici. I understand what you are saying, but is
there any indication that if we had some sort of solution to
accreditation--I know it is costly, it takes a long time--I
assume for the purposes of this question that that is done, is
there any indication that that is going to change the
challenges of the students who study fewer hours or aren't
graduating? Is that really going to solve the issue or is it
just a piece of the puzzle?
Ms. Neal. Well, we certainly--if we relieve our
institutions of what one person has described as a bureaucrat's
dream and a thinking person's nightmare, the accreditation
system, I think we will give just the opportunity costs that
are lost in processing this paper in a system that really has
not guaranteed quality control, I think will help these
institutions to focus more closely on academic quality.
I mean effectively today, institutions are competing on
their climbing walls and things that do not relate to education
and the accreditation process has certainly done nothing to
turn that attention away.
So I do believe that eliminating a process and that is
costly, time-consuming, and secretive, and allowing then
institutions to focus their energies on what we truly need--
student learning and value added at our institutions--then yes,
we will advance the cause of higher quality.
Ms. Bonamici. And this may be a tough question to answer
because of the link between the financial aid and
accreditation, but has anybody ever studied whether students
and families actually look for accreditation? They have to if
they are getting financial aid, but is it something that is
important to them or are they looking for the good climbing
wall?
Ms. Neal. Again, I think that there is this general
perception by families to the extent that they think about it
at all is that if they see it they think, ah, Good Housekeeping
seal of approval, but in fact, that is not and so I think it is
deceiving parents to the extent that they think about it.
And of course, obviously, if they want to take federal
dollars, they have to go to an accredited institution. So
subliminally at least, they are thinking about it.
Ms. Bonamici. All right. In my remaining time, I know Ms.
Neal you mentioned the accreditation started we are concerned
about diploma mills and I share Mr. Tierney's concerns about
these for-profit colleges with low graduation rates, are you
convinced that we can devise and accreditation system that
still protects students and families?
Ms. Neal. I think on the issue of diploma mills, frankly
accrediting bodies have not been good in addressing that. I
think if we look to the triad, if we look to the states, the
consumer protection and the attorney generals in the states
have been fairly effective in dealing with diploma mills and
consumer fraud. And I think we have to remember that the states
play a significant role in helping to ensure quality in this
regard.
Ms. Bonamici. My time has expired. Thank you, Madam
Chairwoman.
Chairwoman Foxx. Ms. Bonamici, I really appreciate your
honing in on the things you honed in on. I think what we are
not talking about today but that you are skirting around in
your questions is we haven't decided in this country what the
mission of higher education is, I think and that sort of is the
nub of the issue I think you are getting at.
Mrs. Brooks, you are recognized for 5 minutes.
Mrs. Brooks. Thank you, Madam Chairman.
And thank you to the panel for being here. I too have come
from a community college where prior to serving I was a senior
vice president and general counsel for Ivy Tech Community
College, and so my questions are going to be a bit on the
credit hour issues, the transfer of credits, and then the
competency-based education which I am looking and hoping that
we are moving toward in some manner.
And Dr. McComis, you mentioned in your testimony that that
credit hour regulation is one example of federal regulations
that inhibit innovation in higher ed, and as we are getting
ready to go through the reauthorization of the Higher Ed Act,
can you please share with us any other regulations or any other
examples of things we might need to be looking at very
specifically that are preventing that innovation?
We also have while I was at Ivy Tech, Western Governors
University was started in Indiana and I think our you know,
more traditional schools are very leery of things like
Western--WGU and--but it is providing an incredible opportunity
for a lot of adults to get their degrees, and I am just
curious, what are some of the things we should be thinking
about with respect to accreditation and innovation?
Mr. McComis. Well, on the specific issue of the credit hour
and direct assessments which is the term that is used in the
current regulations, relieving the tension that exists between
those two different things and within the regulatory framework
and through the Higher Education Act.
So making clear that institutions and accreditors can look
for and should look for those innovative designs and to use the
tools that already exist and enhance those as I described
before, there are allowances for consortium and partnership,
written agreements between non-accreditable and accreditable
institutions through the regulatory framework. And I would
enhance those and look at ways to broaden and embrace that.
But again, always keep the accountability with the
institution because that really is where the locus of that
control and locus of responsibility should retain.
Mrs. Brooks. Ms. Neal, I am curious where your thoughts are
with respect to the competency-based education and with
technology having, you know, moving at such an incredible pace,
where does our--where should we be looking at that with respect
to the reauthorization of Higher Education Act?
Ms. Neal. Well again, I think we really want to welcome
these new delivery models which provide greater access and are
much more affordable than most of the traditional modes of
delivery that the current accreditation system deals with.
So I think as we look to reauthorization, obviously a
system should be put in place that welcomes and is receptive to
these new methods.
I think our current system quite frankly privileges
reputation because it really doesn't provide any information as
to value, and I think the lack of consumer information makes
the focus on climbing walls or other things because it is so
hard to find out, is the school actually adding value.
So I think there are many hidden gems out there, for
example, the School of Liberal Arts College in Oklahoma, which
for less than $10,000 is providing a rigorous core curriculum,
but how do parents find out about it? Under the current system
of accreditation, they would never know.
Mrs. Brooks. I have one other question with respect to
transfer of credits, and I am curious in the accreditation
process when a community college system specifically encounters
many obstacles in transfer, how is that taken into account
during the accreditation process?
So for instance, a 4-year, your traditional 4-year academic
institution often will deny community college programs
different transfers of credit and how is that being dealt with
in your institutions?
Mr. McComis. So as I mentioned in my written testimony, I
think that it is important for accreditors to have standards
that say that institutions cannot deny credit along those--and
they should take--go through the process of making a
determination about the transferability of those.
And there have been, through the accreditation community,
written statements and agreements that accreditation that
should not be the sole reason why credits are denied.
It is not accreditation that causes the denial, it is the
decisions that are made by institutions and I believe that that
is why standards are so important to say to institutions, you
cannot deny transfer of credit based upon something as simple
as that other agency or where it came from or the type of
school.
Every student should have the opportunity to demonstrate
that their English 101 or whichever course it is, is equivalent
to and institutions should respect that and go through that
process.
Mrs. Brooks. Thank you, and I agree.
And I yield back. Thank you.
Chairwoman Foxx. Thank you very much.
I have a couple of questions and then we'll be wrapping up.
Ms. Sibolski, I wonder--in your written testimony you talk
about how credit hour and state authorization regulations have
created significant burdens for institutions and accreditors.
My colleagues and I have been concerned about these regulations
as well.
In fact, the implementation of this state authorization
regulation has been delayed, somewhat, yet again because of
opposition from Congress, states, and colleges and
universities.
Can you discuss why these regulations are burdensome to
accreditors and institutions?
Ms. Sibolski. Sure. Let me first of all talk about the
state authorization issue. There is an awful lot of confusion
out there and although I think there have been some Dear
Colleague Letters that have been published about this, is it
enough? Clearly it is not. The kind of questions that we are
getting from our institutions indicate to us that they don't
know what they are supposed to do and when they are supposed to
do it.
That is a terrible situation for an institution to be in,
and although it is a problem across the country, we know that
it is specifically a problem in California.
And although I can't comment directly on that, it is not my
region, I would just simply note that that is the case. So if
we are going to add regulations to institutions, we have
certainly got to give them the tools to understand what it is
that they are being asked to respond to and give them
appropriate time to do that.
I think that has not happened in this case. And so in
addition to that, the credit hour rules are a problem for us
because of the volume of what we are now having to look at for
institutions.
Should we be looking and have we been looking in the past
that things like the regulations that institutions use to
define academic quality? Yes. In this case, we are looking at
policies on credit hours.
We should be looking at that level but then to ask
something like a large research university, to go through a
sample of all of its courses that we are selecting in order to
review specifics in each course represents a level of attention
to detail that we have not been at before, and if that is where
we need to go, then we need to get common understanding about
it.
Chairwoman Foxx. Would you say that level of detail is
another phrase for intrusion?
Ms. Sibolski. Yes, I would.
Chairwoman Foxx. Thank you. I know I don't have a whole lot
of time, so I am going to ask you and Dr. McComis to respond to
this next question as quickly as you can.
Could you compare and contrast the accreditation processes
in turn--and emphasis that you have on inputs versus outputs?
This is a great concern to me and others.
Ms. Sibolski. Just very quickly, when I joined the
accrediting commission some 10 years ago, we were looking much
more at inputs. The focus of our standards on student learning
outcomes are really now on what are the skills, abilities, and
knowledge that a student graduates with. As so we really are
focusing on the outputs.
It is still a struggle to work with our institutions to get
there, but we are all of us working on it.
Chairwoman Foxx. Dr. McComis?
Mr. McComis. It is a balance that needs to be achieved
between those two and one informs and drives the other. So to
rely solely on outcome standards would prevent the rich
evaluation that an institution goes through the review of its
own inputs and evaluative process.
But having said that, the reliance upon at the end of the
day, what were the objectives of the institution? What was the
student to know through going through that program? Did they
learn those things? And can we measure that learning?
What are the rates of graduation? And at institutions like
those that my agency accredits, how many of those folks got
jobs at the end?
Chairwoman Foxx. Well, thank you all very, very much for
being here today. I am going to make a few closing comments,
and I want to go back to what I think Ms. Bonamici was getting
at about looking at the mission of higher education.
I do think that that is something that we are not agreed
upon in this country at all and haven't perhaps ever been
agreed upon on it.
I want to in a way, apologize to Ms. Neal for having to cut
her off because it really pains me to do that for any of you
because all of you have brought great information to us today.
I think in many ways that these hearings are an archaic way
of doing business. I have felt that since we got here. We talk
about the need for innovation and the need to use technology,
and yet here we are in Congress, not being very good role
models in terms of how we get out information.
But I frankly haven't found a better model, but I think we
do get sometimes some very revealing information and sometimes
stunning things. I think the comment about there being no
minimal standards for outcomes in accreditation really struck
me, Mr. Carey, and I appreciate your bringing that up because I
do think that is something that the American people don't
understand and Ms. Neal, brought it up in her comments, her
good way of looking at that that people think accreditation is
the Good Housekeeping seal of approval and yet we really don't
know what that means.
Parents and students, Mr. Tierney wants to know is can we
get consumers to use information. Well, they are not getting
very good information and if that is all they know.
I am concerned about Mr. Tierney's comments about the high
default rates and low graduation rates only in the for-profit
sector. If you look at the high default rates and low
graduation rates as you said, Ms. Neal, and I appreciate your
saying that, it exists across the sectors.
There are certainly plenty of nonprofits that have those
same characteristics. So I think it is an issue we have to deal
with in all of higher education.
We haven't even touched the issue of disciplinary
accreditors and as I was going over the material last night in
preparation for this today, I thought, oh my goodness, we are
not talking about the American Bar Association, we are not
talking about business schools being accredited and what they
go through, nursing schools, schools of education.
I mean, we--this is only the tip of the iceberg that we are
talking about because practically every discipline has their
own accreditation process and they are very, very expensive and
they are very, very time-consuming.
So again, we are not very good at innovating here
ourselves, but I do think we are stifling innovation in higher
education with our accreditation process.
Those who are in are in great shape in most cases, but
those who are trying to get in the system have a much higher
bar to jump over it seems to me than those who are already in
and that is not fair, and my colleagues all the time are
talking about fairness and that is something that hardly ever
comes up.
So I want to say thank you again very much for stimulating
some thought and some good conversations here. I think all of
you have brought a lot of good information to us today.
We haven't answered all the questions that people have, I
think, but that is good. In education, what we should be doing
is stimulating thinking. That is not what is always happening
in our institutions of higher education, but I hope it is
happening with hearings like this.
And so I want to thank you all again for taking the time to
do this, and I want to thank the staff, too, because I think
the staff does a wonderful idea--wonderful job of bringing in
people who can help inform us.
We are all torn six ways from thunder and don't have the
time to do all of the reading we need to do and the educating
of ourselves and the staff points us gently in the right
direction a lot of times in ways that we wouldn't go ourselves.
So, thank you all very much.
There being no further business, the subcommittee stands
adjourned.
[Whereupon, at 11:36 a.m., the subcommittee was adjourned.]