Higher Ed 101: Accreditation Explained

So, Michael, I can't count the number of times I've heard over the last few years from college leaders who say, oh, we would totally do X, Y or Z, but we can't because our creditor won't allow us.

It does seem that accreditors, Jeff, are always the boogeyman, if you will, of higher education. Everyone, including us, always has hot takes on accreditation. You know, what accreditors should or shouldn't do, how they should or shouldn't operate, how to reform them, and more. Even former President Trump had a take recently saying the current accreditors should just sort of go away or something like that. And yet it seems that far too few of the folks in and I guess around higher ed actually know all that much about how accreditors operate and what they do and don't do.

Which is why we wanted to bring back one of our most popular episode formats from last year, Higher Ed 101. And on this episode of Future youe, we will use that format to explain the fundamentals of a critical piece of higher ed accreditation.

This episode is brought to you by the Bill and Melinda Gates foundation, working to eliminate race, ethnicity and income as predictors of student success through innovation, data and information policy, and institutional transformation. This episode of Future youe is sponsored by Ascendium Education Group, a non profit organization committed to helping learners from low income backgrounds reach their education and career goals. For more information, visit ascendiumphilanthropy.org earn continuing education units this spring with Teaching Practice, an online faculty development program from CourseHero. Over a series of asynchronous courses, you'll uncover new ways to leverage tech in the classroom and build inclusive curriculum, all while supporting your own well being. Plus, you'll get weekly office hours support from leading instructors. Enroll for free today@education.coursehero.com I'm Michael Horn.

And I'm Jeff Salingo.

Jeff, I've obviously been plenty outspoken over the years in critical ways about accreditation, and I'm far from the only one. Whether it's from the right or left, it's not hard to find accreditation critics among the chattering classes.

Yeah, Michael, and while your critiques may or may not be right, depending on who's listening to them, accreditors are a mainstay of the American higher education system. They are central to how colleges get fair federal financial aid, and they've long played central roles in self improvement for institutions. Now, to state this up front, this episode won't feature a debate on the points of accreditation that isn't our objective with this episode. Instead, our objective is to level set. Just what is accreditation? What is its history in this country and why is it so central? And how do accreditors actually operate and what might be changing down the line? Because from my experience, frankly, forget about all the critiques, far too few folks from inside the academy even know what accreditors actually do and the role they play. And yet, if you want to improve, if you want to innovate or boost your value, learning about accreditation is important. So in today's episode, we want to do A Higher Ed 101 on accreditation. And to help us, we're bringing on someone who led one of the main accrediting agencies in the country. Barbara Brittingham is the former president of the New England Commission on Higher Education, also known as NECHI, which accredits over 200 colleges and universities in the six New England states and eleven American style institutions abroad.

Barbara, it's great to see you. Welcome to Future U.

Thank you. It's good to be here. Good to see you, Barbara.

Good to see you again. And so let's start with the history of accreditors. How did these bodies actually get their start?

Actually, the New England Commission of Higher Education is the oldest quality assurance system in the world. And it traces its roots to 1885 when Charles Elliot, who was president of Harvard, got together with some of his colleagues and some headmasters of secondary schools. And originally what they wanted to do was assure that secondary school students were prepared for college. And as they kept working, they decided they needed to draw the line between secondary and higher education, which I know it has been blurred lately, but that was what they wanted to do. And it was more difficult in New England because there were things called academies in northern New England that were the grades essentially 10 to 14. And so they had to come up with some kind of system. 1885 typewriters were just starting to be used. The first useful roadmaps didn't come along till the next decade. So they had some challenges that we don't have today. But it ended up in founding the New England association of Schools and Colleges, a membership organization for K12 in higher education. And NACHI was part of that until 2018 when it became separate. I recently went back and looked at some of the early standards, and one of them was that to be accredited, a college had to have at least 8,000 books in its library. Could they all be the same title? They didn't say. Would it have to be matched to the curriculum? Who knows? But students have to use it. So that was a clear input standard. And then later the commission started looking at did students actually use the book, a process standard, and more recently, outcome standards. Students, when they graduate, know how to find, evaluate, and use information. So accreditation has evolved over time. The other regional accreditations came along shortly after that, with the west coast ones coming along in the early 1900s, in the 18. In the 1980s and 1990s. About a century later, quality assurance agencies spread up around the world. And that was about a century later, after New England got started.

Wow. So if that's their history and origins, what was their initial purpose as they were convening and creating these organizations?

I would say when it got to be accreditation, it was to identify legitimate colleges and universities and also come up with a process that added value. So it's a system based on peer review, which is very valued in higher education, as you know, for use for grants, for scholarly publications, for arts, for prizes. So it's considered a legitimate process.

And that's not all they do now, of course. What's the secondary function that they have evolved to play?

And this is the one that gets a lot of public attention. That's the quality assurance. So an accredited institution is deemed to be at least okay or better academically for students to enroll. The academics are satisfactory, the institution is honest, they look after their students well, and they have the capacity to do what they say they'll do.

So, Barbara, how is this different from quality assurance in much of the rest of the world? And how did the second function come to be so?

It's different because in most of the rest of the world, accreditation is done by a government agency. And accreditation in the US are essentially membership organizations. The work here is carried out by volunteers. In many parts of the world, it's carried out by consultants who are paid modest fees. And one of the things that accreditation looks for is candor in self assessment. The accreditor wants to know that the institution or the program can be honest with itself. At some level. It's proof exercise. You have to convince people that you meet the standards. But it's more than that. The standards have evolved in quote, regional accreditation, at least to be aspirational as opposed to bright line. They're not literal regulations, and it's based on the mission of the institution. And that was a contribution of what is now the Higher Learning Commission in the middle part of the country, realizing that there was such a diversity of institutions that you couldn't have a bunch of bright line regulations and look after Such a diversity. The 10th Amendment to the Constitution says the powers not delegated to the United States by the Constitution nor prohibited by it to the states are reserved to the states respectively, or to the people. And that's why we have no Ministry of Education. We have a wildly decentralized system of education. There are almost 14,000 school districts in the US and about 4,000 accredited colleges and universities. There wasn't even a Department of education until 1980 here, when it was split off from Health, Education and Welfare. One difference of accreditation in the US is the size of the staff. So NCCI, as an example, accredits a little over 200 institutions and has 10 staff members. And where the government does this, this will come as a shock to you. It's not uncommon to find the equivalent of one staff person for every two institutions, often because they keep adding functions to what they do. So one reason that the US Is different too, and this is the foundation for accreditation, is that federal aid to education here is a payment to institutions for qualified students, whereas in most countries, the national government will allocate directly to institutions. And that doesn't happen here except military institute academies and, you know, a few institutions. And so that allocation of aid to students started with the GI Bill after World War II, providing military veterans with the opportunity to go to college. And it was followed in 1965 by the higher Education act, which, among other things, created what we now refer to as Pell Grants, Federal student loans to students who attend institutions that are accredited by a federally quote recognized accreditor, and that word recognized as important. The federal government put more money into aid for students as a needed way to assure students were attending institutions that were satisfactory or better. And when they did this, they either had to determine that institutions were satisfactory themselves or find someone to do it. And lo and behold, accreditors were already doing something that was good enough, because, you know, we don't want a Department of Education anyway, and heaven only knows we don't want them inspecting our institution. So we'll let the accreditors do it. And in the early days, what creditors would do would be type up a list of accredited institutions and stick it in the postal mail and send it off to Washington. And that was it. But now we have about $120 billion in federal financial aid to students. So the department has evolved a more formal process, shall we say, to recognize accreditors with $120 billion on the line. That's important. So people frequently speak about the triad, and that's the states which authorize institutions to operate in their boundaries and provide consumer protection. Recognized accreditors which assure the academic quality. And the U.S. department of Education that oversees Title IV federal financial aid and who's eligible for that.

So earlier, Barbara, you referred to Netshe and then some of the other accreditors that sprung about in the subsequent years. What are the basic kinds or categories of accreditors?

Right. So there are basically two categories. Institutional accreditors that accredit the whole institution and professional or specialized accreditors that accredit programs within institutions. So for the institutional accreditors, there are what have been called the regional accreditors, seven of them in six regions. And of course, now institutions can choose one of those accreditors outside of the region. That was done under the last administration. There are institutional faith based accreditors, five of them, Jewish Biblical Theological Schools. There's deac, the Distance Education Accrediting Council, which traces its roots to correspondence education back in the day. There are career related institutional accreditors. There are five of them now, and they accredit mainly for profit institutions. And then there has been the New York State Board of Regents, a state agency that has done recognition, but they've decided to get out of that business. I guess it was too much trouble and not interesting enough, so they leave it to others. And then there are specialized accreditors, and they have different categories. Some of them are essentially required. So if you want to have a nursing program, you better be accredited by a recognized nursing accreditor. Medicine would fall under the same category. Physical therapy, some of the health programs. Then there are some that are highly advised. And I would put law and engineering in that. In some states you don't have to recognize, you don't have to graduate from an ABA accredited law school in order to take the bar in practice. There are some specialized accreditors that may convey status on an institution. I would put business in that category. Anybody can have a business program if yours is accredited. And there are three business accreditors that may say that you believe yours is better than the ones that are not accredited. And then there are some accreditors that are, I would call them available. So they're out there. Public administration, recreation. You can have a recreation program and not have it accredited. And I'm not sure, depending on where you are, if that's a great advantage or not. And then some of the accreditors accredit both institutions and specialized programs. So nursing is an example of that. It can accredit a nursing program in a college of education Freestanding college or accredit, a nursing program that's part of a university in a college of nursing, law, theological schools, dance, music, art and theater, all in that category, institutional and specialized. So there are 38 federally recognized accreditors. And to be recognized by the federal government, you have to be a gatekeeper to federal aid. And for the most part, that's title four. But there are a few other categories where the law is written such that the money can only go to institutions that are, or programs that are accredited by a federally recognized accreditor.

So, Barbara, it's really interesting that the accreditors kind of existed before kind of the federal government really got into the business of, of, you know, awarding money to students in terms of federal financial aid. And then the accreditors seem to have raised their hands and said, hey, you know, we could do this gatekeeping role for you, federal government. So the question I have is like, do accreditors ever lose their status for that gatekeeping function with the federal government? And if they do, could they kind of just go back to what they used to do, which was, you know, exist in the realm of quality improvement for their institutions and then what happens to those institutions that worked with that accreditor if they lose that gatekeeping function?

Right. That's a great question. So ACICS is the most recent and highly visible accreditor that lost federal recognition. It took six years. When it was tried the first time in the Obama administration, most of the institutions that were accredited by it looked for another accreditor. They didn't all look or they weren't all successful. So there were some that. That hung on with acics, which I believe is closing. If you are an institutional accreditor and you can't provide access to federal financial aid, it's hard to find an audience, hard to stay in business that way. If you go to Wikipedia and look for recognized accreditors, they have a list of those that have come and gone. And it's item. I've seen it, haven't gone through it, but it's. There's a list there. Yeah.

So let's stay with this for a moment because this is important. So how does recognition work for creditors for the purposes of giving federal financial aid? And, you know, what does the federal government require of creditors to keep them in that gatekeeping role?

Right. I should mention that there's an organization called chia, the Council for Higher Education Accreditation. That's a membership organization of institutions. And they do a recognition process that is in many ways overlaps with what the federal government does. But there are some accreditors that are not federally recognized or not eligible because they're not gatekeepers. And this is a way for them to gain some public recognition. But I am going to talk about federal recognition. And so if you go to ed.gov up in the right hand corner there's a little box and if you type in accreditation there, you can find all the information you'd ever want to know about federal recognition. The requirements and the process are part of the Higher Education act, which was last reauthorized in 2008. And what the accreditor does is prepare a report based on the regulations. And There are about 160 criteria and provide evidence. So here's how we meet that and here's some documentation. Examples to show that we do that. There's a staff member assigned and that person reads what the accreditor has submitted. They come on site and check the file. They go to a commission meeting and then go on a visit or two or three to watch the process playing out. Then they prepare a report. Now, accreditors submit somewhere between hundreds and thousands of documents because the staff member typically asks for follow up on certain things. And the staff member then writes a report. And the staff member report can be three or four hundred pages. There's a lot of electronic paper involved here. And they make a recommendation to somebody called the senior department official, who is somebody chosen by the secretary of education to make these decisions. Then there's another group, it's called Naseki. It's the National Advisory Committee on Institutional Quality and integrity. It's an 18 member committee by law, six of them are appointed by the secretary. And when the new secretary comes in, they wait till the terms come out and they appoint their members and, and then six by the House and six by the Senate. And of those six and six, three are Republicans and three are Democrats. So the idea is to not have an overly partisan Nasiki meeting. They have a public meeting that used to be in person and it's now on zoom. But it's live and the public can sign up and give comments, pro or con, about the accreditor Nasiki at that meeting before they finish talking about a particular accreditor in front of them. They also make a recommendation to the senior department official and the senior department official makes the decision. And what that does is leave the secretary available in case there's an appeal of the decision. So the feds require standards and I'm going to list the categories of the standards, but they don't say what they have to do. So the standards have to address success with respect to student achievement, curricula, faculty facilities, equipment and supplies. I love the supplies part there. Fiscal and administrative capacity, student support services, recruiting and admissions, calendars, catalogs, grading and advertising, and the measure program length and student complaints. Now, faculty was one of those. They don't say any more than that. They don't say what the standard has to be, but it has to be credible as judged by that staff person, by Nasiki and by the senior department official.

So Barbara, the Education Department just says that these are the areas that the accreditors have to focus on. But they don't tell them which within these areas you have to do X, Y or Z because it gives the accreditors, in other words, some flexibility in terms of what they want to say about faculty or facilities in terms of requirements.

Right, right. And remember, some of the recognized accreditors have a religious mission and so their faculty standards would likely look different than they would for a, quote, regional accreditor.

So Barbara, let's get into the mechanics then below that. How does the accreditation process, when they're working with the institutions or the programs themselves, how does that actually work?

Okay, so it starts with a set of standards that are approved by the accrediting commission, usually with a process that takes, you know, a couple of years even for revisions, to listen, to be aware of what's going on in that in the external environment, to listen to the membership. And then the institution or the program writes a self study against the standards. And normally for institutional accreditation, it takes 12 to 18 months to do that, sometimes a little longer. In New England, the institutions are asked to write their response to the standard in three part a description. This is what we do to meet the standard, an appraisal, because we're interested. Can they be candid with themselves? What are we good at here and what do we still need to work on? And then a projection which is a realistic plan for how to get better in that particular area. There's also a set of data forms and then there's a visit scheduled by a peer group of trained evaluators. Depending on the size of the institution, that could be five to eight or so people, frequently with, quote, regional accreditation. Some of those people come from outside the region, so there's some cross fertilization there. They visit for about three days. They draft a report, give an oral report. Before they leave, they send that written draft report back to the institution for factual corrections. And then the institution is invited to write a Written response. And it could be we agree on the facts, but we don't agree on what the facts mean. The team said X and they were critical, but we think it works because of Y and Z. Or they can more commonly also talk about here's areas identified as concerned by the team. And you know, we share at least most of those and here's what we're going to do about it. So to show that it's an ongoing process, the president, and sometimes the president will bring someone with him. The board chair or the provost will meet with the commission. The commission will decide is this institution continued in accreditation and what follow up do we want? In New England, the cycle is 10 years with everybody does a fifth year report, but the decision can include other things. So it can include a progress report, probably on one of the most often on one or more of those things that were identified as a concern. It can include a focused evaluation, which is like a progress report, only a visit by a small team. The commission has RFI process annual report on finance and enrollment to monitor financial stability. It can issue a notice of concern, which is turning up the volume a bit on an area. And this is a private action in New England. But it announces that the commission has a stronger concern about a particular area. It can issue a notation which is similar to a notice of concern, but it's public. So the public has some idea that the commission has a fairly strong concern about a particular area. It can ask the institution to come back and show cause why it shouldn't be placed on probation or why it shouldn't have its accreditation withdrawn. If the commission doesn't think it has enough information, it can defer and get some information. I should say here that New England continues to have a lot of independent colleges and there is a strong system of monitoring the finances of independent institutions. And they're shortly going to get into looking more directly at the finances of public institutions too. So when institutions come along, they're first deemed eligible. And then there's generally a candidacy period. When the Naval War College was accredited, it didn't have to go through candidacy. It was already 100 years old, so it was up and running. And you'll be glad to know since it's a Naval War College, fully functioning. So that was good. But just about everybody else has to go through a candidacy period. The commission looks at substantive changes and we can talk about those if you like. I mentioned financial monitoring and now the commission has a policy on innovation which provides some structure to institutions wanting to do something that's coloring a little bit outside the lines, as it were. NECHI has quite a range of institutions. It accredits all the public universities, colleges and community colleges in the six New England states. It accredits four Ivy League institutions and mit. And then I'm going to name some that tell you basically what they do just by the name of the college. Hebrew College, Montserrat College of Art, Woods Hole Oceanographic Institution. And there it comes again, the Naval War College. It accredits Southern New Hampshire University, SNHU, which has about 3,000 students on its campus and about 170,000 students studying online. And when you look at the number of students in a given state, New Hampshire looks bigger than it should be. And that's all about SNHU Commission also accredits the Conway School of Landscape Design, which has 18 students in a one year program and yes, a master's program in landscape design. I like to say they used to have 17 students, but you can't, that's a prime number. And you can't divide students into small groups. So they decided 18 was better. And then they accredit 11American style institutions abroad again through this peer review process.

So to state the obvious, Barbara, there are certain institutions whose accreditation really isn't at risk every couple of years. And you had several of those in your purview, ranging from Harvard to Amherst, just to pick out two. So for places like that, what's the real purpose of the process? Because these are institutions that have been around hundreds of years. They have tens of billions of dollars in their endowment. It's really a lot of work, given what you just went through, for them to go through this, not only for the people on campus, but for the people visiting those campuses. So why do it? For those institutions, why do it?

They want access to federal financial aid. But how can we make it helpful? So I used to say to certain presidents, unless you know something we don't know, your institution is going to continue to be accredited. Now we want to make it helpful to you. And there are basically two things that we could do. And one is to help them think about how they can gain value from the process. What are things that they want to work on that are within the purview of the standards. Now, if they want to work on athletics, that's, you know, that's outside the standards. But a lot of things that institutions want to work on are addressed by the standards assessment. Revising general education, which is a process that sometimes can take years and sometimes accreditation can help move that along and say we really don't need five years to do this. We should be able to get this done. Engaging the board in the right way, as AGB likes to say, noses in, hands off. And that can be an issue. Using the data that they have or getting data that they should have is sometimes an issue. Institutions do program reviews and so making sure that the time spent on those is worth it, that they result in some program improvement that's helpful to the institution. And then sometimes there are involvement issues to address. Faculty and the governing board are two groups that come to mind and that's related to the standards as well. And then the second thing the accreditor can do is send them a team of peers, people that they respect from peer institutions, aspirant peers. You know, here's an institution that's similar to ours, they're better at assessment than we are. Here are three institutions we'd like. Somebody from one of those peers will be well prepared, engaged, will be fair minded, will ask good questions and help them think about themselves. Help the board think. Because involving the board can be very valuable. Where the feedback is helpful, both the formal feedback that shows up in the report and the informal feedback during the team visit is important. And use every opportunity for improvement. For the volunteers on the teams, it's interesting and important work. People learn something. They get to see deeply into generally a peer institution in a way that they wouldn't if they didn't work there. They feel that they make a difference and they do. And it's a cost effective way to do it. Again, we don't pay, the expenses are paid, but there's no stipend for the peer reviewers. It can be a great professional development experience. I've talked, I heard from faculty, senior faculty members appointed to co chair the self study process on several occasions where the faculty member says, I thought I understood this institution. I've worked here for 25 years. I thought I knew everything about it until I co chaired the self study. And then one time I called the president from a different region who had chaired kind of a challenging visit, shall we say. And I thanked him and he said, you don't have to thank me. I've quit going to conferences. I do one of these a year and it's my professional development. So it's a lot of work for them and hopefully it's valuable work. They get value from it too.

Yeah, it's interesting. It's like they get a consulting service if you're the institution, if you're one of the volunteers, you just learn a heck of a lot during the, during the ride. But it brings up the question of the composition of accrediting agencies, which is that they, they're membership organizations.

Right.

And as you know, this is often a source of criticism, which we're going to address in a little bit. But, but for starters, can you just actually lay out the rationale for why they are membership organizations and what that membership looks like?

Right. So again, it's not a government entity, so it has to be something else. And a membership organization is the clearest way to involve the membership in helping to develop the standards they have to live with them. And so feeling that there's a voice in what they should be bringing to the Commission's attention that came from an action, this policy on innovation that I mentioned earlier came from an institution coming up with something that they wanted to do. And the Commission listened carefully and approved it, but thought, you know, this is, again, coloring outside the lines a little bit. Maybe we need a general policy to do this. And it's, I think membership organizations lend themselves to that. The commission itself, which makes the decision, has institutional members, presidents, academics, finance specialists, people who work in student services. And by law, at least one of every seven commissioners must be a public member. And that means that they have some general knowledge of higher ed and they're sensitive to mission diversity. But they cannot have been active as an educator for the past 10 years, not as an employee, a board member, an owner, a shareholder, a consultant to a NECHI institution, or applications, nor can their spouse, parent, child or sibling be in one of those categories. So they are truly removed. I like to say this is one of my favorite federal regulations because good public members are hard to find. When you get a good one, they're fabulous and they're hard enough to find. I'm not sure we would have done it if it wasn't required. So it's a good regulation, and that opens it up a bit. And then NCCI also has trustee members because boards play an increasingly important and vital role, I think, in higher education. And so having that board membership at the table can be helpful as well.

That makes a ton of sense. We're going to take a brief break on Future you, and when we come back, we're going to get into a sea of issues around where accreditation may evolve, some of the controversial aspects of accreditors, and much more. We'll be right back on Future youe. This episode is being brought to you by the Bill and Melinda Gates Foundation. Today's college students are more than just students. They are workers, parents and caregivers and neighbors. And colleges and universities need to change to meet their changing needs. Learn more about the Foundation's efforts to transform institutions to be more student centered@usprogram.gatesfoundation.org

this episode of Future youe is sponsored by Ascendium Education Group, a non profit organization committed to helping learners from low income backgrounds reach their education and career goals. Ascendium believes that system level change and a student centric approach are important for our nation's efforts to boost post secondary education and workforce training opportunities. That's why their philanthropy aims to remove systemic barriers faced by these learners, specifically from first generation students, incarcerated adults, veterans, students of color, adult learners and rural community members. For more information, visit ascendiumphilanthropy.org. So welcome back to Future youe, where we're continuing our conversation around accreditation and really kind of talking about and explaining something that is so critical and so foundational to higher education here in the US and around the world, but particularly around the US System. So Barbara, I want to get into some of the other work that accreditors do or don't do. We've talked about their role during the accreditation process itself, and you talked about their role in substantive change. But let's just go a bit deeper on this. You often hear about how accreditors play an outsized role in things like new programs or degree launches. You you know, innovative program design that maybe questions the time spent earning a degree or this idea of change of control question. In other words, mergers and acquisitions closures and the like. So let's take those one by one. Let's start with new program or degree launches, for example.

So most new programs don't need accreditation approval. They're routine. They're within the bounds of what the institution does. It's only when they're substantive change, which is a term of art here. And the federal regulations lay out some of what that means. One is if an institution wants a higher or lower degree. So Colby Sawyer is a good example. They have very strong nursing programs. They had bachelor's degrees, they had master's degrees. They wanted to offer a doctor of nursing practice, a dnp, a higher level degree. So that took the commission needed to review that and give them the okay to do that. And again, it goes back to the role that the commission plays with respect to the federal government. The government wants to know that the institution has the capacity to do that in the case that it's a professional program, if there are state approvals or other things that they need to do it should be approved so that the students aren't put at undue risk. Program delivery mode is another substantive change. And so with the pandemic, there were institutions already approved for distance ed and now that list is very long because the government lightened up a little bit and let accreditors do kind of a quick approval because they had to, to keep the train running. And now more institutions have general approval for, for distance education. There are new programs that I call them outside the circle. So if one example would be Wheaton College here in Massachusetts, which is the liberal arts institution and they wanted to offer a nursing program. And so if you draw a line around what's liberal arts and then you add nursing, nursing is going to be outside that circle. So they needed to get that approved ahead of time. Mergers, it could be independent institutions or it can be public institutions. So in Vermont, three of the public institutions are merging officially as of July 1st to become Vermont State University. And Granite State University in New Hampshire, which was a separately accredited institution, is now the College of Professional Studies at the University of New Hampshire. So we're seeing some mergers in public institutions, at least in New England as well. The commission meets four times a year for regular meetings and twice a year for retreats. And if something is urgent, important, they will consider it at a retreat. So they're up to six times a year. So they're not slowing things down. It's the last step. And so I think in any multi step process that one last step can sometimes seem like it's taking longer than people want it to. I get that.

So Barbara, this idea that schools and colleges complain, well, the accreditors won't let us do that. So sometimes that is just an excuse. It's not reality, right?

Yes. If it's something I don't want to do, it's easy to say the accreditor won't let us do it. And in some cases it may be the accreditor won't let us do it. Maybe we've asked, maybe we've had an informal meeting. You know, if institution came in and met with the commission staff and they said we want to offer a one year baccalaureate degree, the commission of the staff would likely say you can ask, but the probability that that's going to happen is vanishingly small.

You were able to get a read on that. So I guess that flows into the next area, if you will, which is innovative program designs that maybe questions the time spent earning a degree. For example, there's a bunch of people that want to lessen the number of years, for example, and degrees and the like.

Right. I think that is interesting. There are some. I know there's a group out there looking at three year bachelor's degrees. And I think one of the concerns that a commission would have is if a student gets a three year bachelor's degree and then wants to go on to grad school or law school, would that put them at a disadvantage because their degree didn't, you know, wasn't as robust as long as students from other institutions? The commission has a program on innovation and it has some circles drawn around it. If an institution wants to propose something that's innovative, it means that it doesn't meet some part of the commission standards. But there are some things it has to do. It can't cross the line of something that's required by the federal government because the commission wouldn't have the authority to do that. It has to maintain the standard on integrity, transparency and public disclosure. It has to demonstrate to the commission that it's not putting students at undue risk. So there's some boundaries written around it and that's available on the NACHI website. And I invite people to take a look at that and see how it looks to them. I think that the time to degree is a really important issue. I read some newspapers in the New England state still and a couple recent articles about students graduating from a high school who have earned associate's degrees. So as much as the early NE ask people want to draw that line between secondary and higher ed, the line is getting blurred again. So here are these students getting enough credits to get an associate's degree while they get their high school diploma. And I think that's a really interesting development. The whole idea of transfer credits is one that comes up periodically. And the commission doesn't play, at least in New England, doesn't play a strong role there. But I know that that is a concern and it would not surprise me to see more attention being given to that.

Barbara, I wanted to bring up something you mentioned earlier, which was about finances because there's a lot in the news. Speaking of newspapers, there's a lot in the news right now about the financial solvency of CO colleges and universities. That's particularly acute in New England where there's a lot of colleges, universities and demographics are moving in the wrong direction. We're hearing a lot about potential closures, a lot about potential mergers, change of control, potential acquisitions, in fact. So for example, what role does an accreditor play when Northeastern, which is in the Northeast, acquires a college in California, which is not in the Northeast. Right, right. So, you know, what is the role of accreditors in these areas?

I think, you know, if they're looking for a merger or an acquisition, what the Commission's going to want to know is because it's often that the other institution is having financial trouble, does the acquiring institution have the capacity to take that on? And taking it on can mean all kinds of things. So in that example, they're keeping the Northeastern's, keeping the Mills campus. And another example, when Marlboro College closed, there's a Marlboro Institute at Emerson College. The Marlboro campus closed, but Emerson offered the students and the tenured track faculty and tenured faculty the opportunity to come on board because they valued the curricula structure and they were gratified by the academic rigor of the institution, knew that students were getting a good experience. So they can take many different forms. Nephi has again, has still, I think, a high proportion of independent colleges and universities. So I think it's now over 40 years. They've had a process pronounced ARFI, annual report on finance and enrollment. And when Mount Ida College closed in the Boston area, that was a, I call it loud reaction to that. And as a result, the commission now does an annual review of all independent institutions that they accredit and they're going to do public. So they look at about a dozen metrics, market revenue, cash flow, liquidity, wealth, and if certain flags go off, they will ask for qualitative information. And they have assembled a group of financial experts from colleges and universities and financial institutions to review that. I would say it's a very rigorous process with respect to closures and mergers. Commission has also seen in New England some closures. And it's extremely disruptive event to certainly to the alumni who are often mentioned that they don't want this to happen. It's disruptive to the faculty, to the staff, and mainly to the students. But it's also disruptive to the community because these institutions play an important role in their communities. And when the college closes, that's a real loss for the community as well. The Commission keeps a close eye on institutions that are fragile and I think is increasingly encouraging them to look for merger partners and avoid closure. And what that means, of course, is the institution needs to get into that early enough that they are an attractive merger partner or acquisition, so somebody wants them. There's a new group that you may be familiar with called the Transformational Partnerships Fund. It's Run out of New York by John McIntosh. And it is funded by four foundations. And what it does is provide grants of up to 50 or $100,000 for two or more institutions that are looking for cooperation, which can be anything from sharing back office to merger. And it's a very timely function, I would say. I know some cases where it has been very helpful, some of which resulted in a merger and some of which didn't. But it's helpful and it legitimizes the conversation. I think governing boards sometimes are reluctant to have that conversation. But if this third party, well funded by foundations, says, we'll support you doing that, I think that can be an important signal. The University of Maine system, I should mention this too. This is not a merger. There are seven institutions in the public University of Maine system and they are now accredited as a single entity. And that came about because they have tough demographic. It's the oldest or second oldest state in the country. The numbers were declining for New England. It has big geography. And so these seven institutions, by our standards, look spread out. And they wanted, particularly with more and more online, they wanted to be able to share courses and programs and if they got really good at it. And the commission sent a team into institution A, but they were cooperating with several others on certain degree programs. It would become pretty close to impossible to tell who was really in charge, who was really responsible for assuring the quality of that. And their answer was, it's the system. And so they are now accredited as this public system of higher education. So, you know, accreditation evolves as higher education evolves.

So, Barbara, there's a lot of criticism, of course, of accreditors, and this isn't to the show, frankly, to debate those questions, but more to raise the issues to understand how accreditation might evolve in the future. And one of those questions revolves around transparency and what accreditors actually make public. One of the arguments for more transparency goes something like this. If part of the reason for accreditation is consumer protection, shouldn't prospective students and their families, the consumers of higher ed, shouldn't they have more insight into everything accreditors see? So just help us understand the fundamental state of play around this topic and perhaps the rationale on the other side as well.

Okay. And I think this variation among accreditors, so wasc in California and Hawaii, they make just about everything public. New England does not and could be, I don't know. My hypothesis is it's related more to the predominance of independent institutions in New England. Certainly California has some wonderful ones. But New England has predominant ones. Public members help, I think, to open that up. And then there are complaints. And in our office, we used to make the distinction between complaining and complaints. So students would call and they would say, I got a B minus in my history class and I really should have had a B plus. Well, that's complaining. But it's not a. It's not a complaint in the commission, standards or the school. I don't like it that the school changed the mascot. Well, okay, that's a complaint, but it doesn't fall within the purview. So there has been some attention made so that the legitimate complaint process shouldn't be so arcane or difficult that it discourages people coming forward with legitimate complaints. And I think one thing accreditors have done there recently is they used to require complainers to be very specific about the part of the standards that they were addressing. And that's a hard exercise for, you know, a civilian to do when something is really wrong. And so now what they're more likely to do is to listen to the concern and help them turn it into what may be a legitimate complaint. It's up to the commission to decide whether it is and what to do about it, but at least help them make the process a little bit easier. The commission also has a standard on integrity, transparency, and public disclosure. It's substantial. It runs about three pages. And the idea there is to help make sure that the public can get information they need easily from the institution so that they don't. They're less likely to have to go to the accreditor if there's a notation or if the institution is on probation. The institution's supposed to put that on their website. But the idea is to try to, as much as possible, make sure that they can get all the information they need from the. From the institution itself. So.

So Barbie, you mentioned that perhaps one reason that there is less transparency in New England, for example, is the presence of, you know, more independent and private colleges. And, you know, and it just brings up a fact, again, that these are membership organizations and that there are these inherent conflicts of interest built into the quality assurance process, because it's the membership organization that decides what's public and what's not in that case, for example. So can you say more about the concern there and what's the reason for keeping them as these membership organizations that are essentially run by the industry that they're regulating?

Yeah, well, I think a couple things. One, if you look at the decision letters of different accreditors, they vary in length and some of them are quite short. This is what the commission decided, and they don't give a lot of background information or rationale. And in New England, the decision letters generally are pretty long, six or seven pages is not uncommon. And what they will do is cite the information from the self study, cite the standards, tie the whole thing up together in the hope that it's understandable to the institution. I think also the Department of Education has announced that they're going to do good old negotiated rulemaking. And so if there is a strong concern there about public information, I would think that they would identify that as a topic. They haven't announced yet what the topics are going to be, but that's one place it could come from. Another place it could come from is a reauthorization of the Higher Education Act I mentioned. It hasn't been reauthorized since 2008. Terry Hartle, who until recently was the senior vice president for government affairs at ACE, says it's going to be reauthorized in 2040, give or take a decade. So it's not exactly on the horizon now. So I think what the government has tried to do is use negotiated rulemaking to come up with agendas that they think need some more attention.

Barbara so let's turn to the future. There are movements afoot to add new types of accreditors, create more data transparency between colleges in the labor market. You just mentioned the HEA reauthorization. See how long we can squeeze out between the two reauthorizations there. There's risk sharing for institutions so that their ability to take in federal financial aid is tied to their student earnings outcomes and ability to repay debt, which frankly, is its own form of quality assurance. So curious where a lot of this is going to go. But let's start maybe with data and quality assurance. What are the big questions in play in your mind?

You know, I think it's interesting because data are not as good as people want them to be, and I've been including creditors there. So the college scorecard, for example, which came out during the Obama administration, is seen as a big leap forward, and it is. But it only includes students who have federal financial aid because the government doesn't have access to information about the students who do not. And of course, that percent varies widely from institution to institution. There has been some talk last time about unit record systems, meaning a system that would keep track of individuals, maybe starting in high school, through college, through employment. This is a country that not everybody's convinced we should have a department of ed. And so having a unit record system is a pretty high hurdle. The measures themselves have limits. So for example, New England has a small number of women's colleges, some of which are highly selective. And I remember one time going to look at their college scorecard information and looked like their graduates who were pretty recently out of college. We're not making a lot of money. And I thought, what's that about? These are clearly capable students as a very selective institution. Well, it's a women's college and so many of those students might be in graduate school where you don't make a lot of money and some of them might have taken time out for child rearing purposes. So if you look at a comparable co ed school, the numbers might be higher. So the data are not as good as we would like. Another example is community colleges, which have notoriously low graduation rates, most of them. But many students who go to community college don't go there to earn a degree. They may just want a few courses or they may plan on transferring. And if a student transfers, they're shown as a community college lowering the graduation rate. So the measures themselves have real limitations to them. And I'm not sure what it's going to take to get better data widely available.

So, Barbara, we've also seen this new twist in the last few years where colleges can effectively shop for different accreditors and switch out of the their regional accrediting agencies. So what's behind that and what's been the effect of say a college in Florida going out west if they wanted to for accreditation?

Yeah. So as you mentioned, institutions accredited by what have been called the regionals can now go outside the region. And I think that was to foster competition. It was a Republican administration, after all, and they like competition. So that's, that's a good thing. Right now, as far as I can tell, that level of activity is modest. Some of that is from New York State deciding to get out of the business. So there a couple dozen institutions or however many there were, have to find somebody and it'll be a regional accreditor. Some have come to New England, I'm sure some are going to middle states. Where they're all going, I don't know. I think it'll take a while to sort it out. There's the devil you know and the devil you don't know. So I think, you know, there needs to be a reason for an institution to go to another accreditor. The Florida law says that institutions must change. Accreditors and this, the Department of Education, by the way, has written to the state of Florida saying, you know, by law, federal law, institutions have to have a choice. Where that's going, I don't know. It strikes me as a wildly inefficient way to operate, to understand, you know, if you took 100 people and divided them into seven groups and say, right, accreditation standards, you would get a lot of the same ideas, but they would be organized differently, the vocabulary would be different. And so these Florida institutions, if they have to do that, have to learn this whole separate way of organizing, basically the same process, they have to travel farther, it'll cost them more. And I don't see what real value there is there. Former President Trump has come out with part of his platform, which is to get rid of all the current accreditors and get new ones. And talk about impractical. It would take a while to do that, to accomplish it, longer than another four year term would give him to do it, because you'd have to ramp them up. You'd have to, in order to get recognized, they have to already be in the accreditation business and show and who would switch to an unrecognized accreditor. So it shows an attitude, but as a suggestion, it doesn't have any real practicality.

And lastly, we have a question from a listener. And this year those listener questions are sponsored by Coursehero. And these questions are generally for me and Michael, but Barbara, you get the honors this time. And whereas we've been doing facts to this point in the episode, this person wants a little bit to know your viewpoint on it. And so here's the question.

Hi, Jeff. Hi, Michael. My name is Addie Chaney from the Ohio State University. As universities are being called to reimagine their practices in the wake of the pandemic, I can't help but wonder about the role of accrediting bodies when it comes to innovation and change in higher education. How might accrediting bodies need to evolve in order to ensure that they are operating as useful and agile agents of quality and accountability that support rather than hinder innovation?

I think that's a great question and I think it will take several forms. And when I mentioned the NECHE's policy on innovation, and it'll be interesting to keep track of that and see what comes along, I think accreditors are acutely aware of the decline in public trust in higher education and believe that they have an important role to play there. And so I would look to see if accreditors aren't making more public statements and helping the public understand them by pointing out, in part, innovations that their member institutions have undertaken recently. It's been fascinating to me to be in accreditation this long and see the changes in higher education and I would say they are accelerating. Accreditation has to, I think, do a good job of telling its story of being open, of being, you know, the public, being aware of things like public members on the commission and innovation policies and innovations that institutions have undertaken with the approval, not the blessing, of the accreditor.

Barbara A huge thank you for joining us on Future you to help unpack all these questions around the origins, roles and future of accreditors in the accreditation process. These episodes we've heard from our listeners have been helpful in helping make certain fundamental structures and issues that we just sort of assume in higher education much more accessible and understandable. So appreciate you really working with us to help elucidate this work.

Thank you. It's been a pleasure and for all

you listening, thanks for joining in. We will love to hear your feedback on this episode. And we'll be back next time on Future youe.