ACCREDITATION AND THE CHALLENGE OF FEDERAL REGULATION Judith S. Eaton Task Force on Government Regulation of Higher Education 12 February 2014
IN THE BEGINNING: ACCREDITATION AS A “…RELIABLE AUTHORITY AS TO THE QUALITY OF EDUCATION AND TRAINING…” INTENT: FEDERAL GOVERNMENT DOES NOT DO THE WORK OF HIGHER EDUCATION AND ACCREDITATION, BUT TURNS TO ACCREDITATION FOR THIS PURPOSE UNDERSTANDING: FEDERAL GOVERNMENT CONTINUE ITS RESPONSIBILITIES WITH REGARD TO THE NON-EDUCATIONAL SPHERE, E.G., USE OF FEDERAL FUNDS ACCREDITORS HAD A SINGLE PAGE OF OBLIGATIONS: PUBLISHED STANDARDS, IN OPERATION, FISCALLY SOUND
THIS HAS COME TO MEAN THAT ACCREDITORS… MUST RESPOND TO 93 CRITERIA: 10 PAGES OF LAW, 28 PAGES OF REGULATIONS AND 88 PAGES OF SUB- REGULATORY GUIDANCE ( GUIDELINES ) [200?] OPERATING UNDER THE HIGHER EDUCATION ACT: • ARE REVIEWED BY NATIONAL ADVISORY COMMITTEE ON INSTITUTIONAL QUALITY AND INTEGRITY AT LEAST EVERY FIVE YEARS • ARE ALSO SUBJECT TO “DEAR COLLEAGUE” LETTERS, NEGOTIATED RULEMAKING
THE PRESENT FOR ACCREDITORS… AVALANCHE OF LAW AND REGULATION THE BIGGEST PROBLEM IS REGULATION FROM USDE EXTENT AND TYPE OF REGULATION IS (ACCREDITORS): INCONSISTENT, PRESCRIPTIVE, INTRUSIVE, GRANULAR, BURDENSOME, UNNECESSARY, COMPLIANCE-DRIVEN, MANDATES INTERFERE WITH INNOVATION TOO MUCH REGULATION, THE WRONG KIND, REGULATION FOR REGULATION’S SAKE
EXAMPLES PROVIDING 300-500 DOCUMENTS FOR A REVIEW IS COMMONPLACE 178 CITATIONS; 3 ADDRESS EDUCATIONAL QUALITY RECEIVING VISITS FROM THE OFFICE OF INSPECTOR GENERAL BETWEEN RECOGNITION REVIEWS ACCREDITORS ARE IN A CONSTANT AND CHANGING STATE OF FEDERAL SCRUTINY
IN THE COURSE OF A RECOGNITION REVIEW, ACCREDITORS ARE REMISS IF… THE BIOGRAPHY OF A CEO IS NOT ON AN ACCREDITOR’S WEBSITE THEY HAVE A NEW POLICY, BUT DO NOT YET HAVE A REASON TO USE IT THE ACCREDITOR SENDS OUT A GROUP MEMO INSTEAD OF INDIVIDUAL MEMOS TO INFORM CONSTITUENTS OF A NEGATIVE ACTION
CURRENT FEDERAL OBLIGATIONS – AS EXAMPLE 1. Assignment of Credits, Program Length and Tuition 2. Institutional Records of Student Complaints 3. Publication of Transfer Policies 4. Practices for Verification of Student Identity 5. Title IV Program Responsibilities • General Program Responsibilities • Financial Responsibility Requirements • Default Rates • Campus Crime Information, Athletic Participation and Financial Aid, Related Disclosures • Student Right to Know • Satisfactory Academic Progress and Attendance Policies • Contractual Relationships • Consortial Relationships
CURRENT FEDERAL OBLIGATIONS – AN EXAMPLE - 2 6. Required Information for Students and the Public 7. Advertising and Recruitment Materials and Other Public Information 8. Review of Student Outcome Data 9. Standing with State and other Accrediting Agencies 10. Public Notification of Opportunity to Comment 11. Information on Contractual and Consortial Arrangements
WHAT DO WE DO? STREAMLINE FEDERAL RECOGNITION REVIEW CLARIFY DISTRIBUTION OF RESPONSIBILITIES
STREAMLINING: REDUCE OR ELIMINATE THE GUIDELINES MODIFY FEDERAL REVIEW: LESS FREQUENT, FOCUSED ON FEWER ISSUES REQUIRE CONSISTENCY IN APPLICATION OF REGULATIONS REDUCE OR ELIMINATE “SUBSTANTIVE CHANGE” E.G., CHANGE IN MISSION OR OBJECTIVES, LEGAL STATUS, OWNERSHIP, PROGRAMS OF STUDY, CREDIT HOURS TOWARD A DEGREE EMPHASIZE CURRENT LAW: “…SUCCESS WITH RESPECT TO STUDENT ACHIEVEMENT IN RELATION TO THE INSTITUTION’S MISSION, WHICH MAY INCLUDE DIFFERENT STANDARDS FOR DIFFERENT INSTITUTIONS AND PROGRAMS, AS ESTABLISHED BY THE INSTITUTION….”
CLARIFYING FEDERAL GOVERNMENT’S PRIMARY RESPONSIBILITY IS ENFORCEMENT OF LAW OR REGULATION GOVERNING USE OF FEDERAL FUNDS, NOT EDUCATIONAL QUALITY • STUDENT FINANCIAL AID • DEFAULT ACCREDITATION’S PRIMARY RESPONSIBILITY IS EDUCATIONAL QUALITY • STUDENT ACHIEVEMENT • INSTITUTIONAL EDUCATIONAL PERFORMANCE
NEXT STEPS REVIEW ALL REGULATIONS AND REMOVE OR MODIFY BASED UPON: • ASKING: “IS A REGULATION DIRECTLY RELATED TO HOLDING ACCREDITORS ACCOUNTABLE FOR EDUCATIONAL QUALITY?” • AFFIRM THE ROLE OF THE FEDERAL GOVERNMENT IN OTHER AREAS, E.G., STUDENT AID • DEVELOP LEGISLATIVE OR REGULATORY LANGUAGE THAT WHILE THE FEDERAL GOVERNMENT HOLDS ACCREDITORS ACCOUNTABLE FOR EDUCATIONAL QUALITY, GOVERNMENT DOES NOT DETERMINE EDUCATIONAL QUALITY
LET’S HAVE AN ACCREDITATION – FEDERAL GOVERNMENT RELATIONSHIP BUILT UPON… • ACCREDITATION’S ROLE: • HELPING STUDENTS TO LEARN • IMPROVING EDUCATIONAL QUALITY • PROMOTING QUALITY INNOVATION
NOT PART OF U.S. ACCREDITATION…. DIRECT CONTROL BY GOVERNMENT NATIONAL/FEDERAL STANDARDS NATIONAL/FEDERAL QUALIFICATIONS FRAMEWORK FEDERAL COMPARISONS (BUT DO HAVE COMMERCIAL RANKINGS)
THANK YOU WWW.CHEA.ORG
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