Regional Accreditors: The Cornerstone of U.S. Accreditation

The beginnings of regional accreditation go back over a century, when liberal arts colleges and universities began collaborating on standardizing admissions requirements and, ultimately, facilitating student transfer from one such college to another. The idea was that, if students wanted to transfer to your college, your college would accept their credits only if their college was accredited. In those days, students rarely transferred from one part of the country to another, so these groups recognized colleges in discrete geographic regions of the United States. Today there are seven regional accreditors:

• Higher Learning Commission (HLC) of the North Central Association of Colleges and Schools
• Middle States Commission on Higher Education (MSCHE)
• New England Association of Schools and Colleges (NEASC) Commission on Institutions of Higher Education
• Northwest Commission on Colleges and Universities (NWCCU)
• Southern Association of Colleges and Schools Commission on Colleges (SACS-COC)
• Western Association of Schools and Colleges Accrediting Commission for Community and Junior Colleges (ACCJC)
• Western Association of Schools and Colleges Accrediting Commission for Senior Colleges and Universities (WASC Senior)

Accreditors have been described as private clubs (Associated Press, 2013) and, for decades, the analogy was apt. Private clubs are by definition exclusive, and in order to thrive they must maintain a reputation of exclusivity, limiting membership to those they consider appropriate. Private club membership is voluntary; peer pressure notwithstanding, there is no law requiring anyone to join. Private clubs keep an eye on their members’ behavior, because one member whose behavior is embarrassing can diminish the reputation of other members and the club itself. (“So and so is a member? But he’s a mess! The other members must be a mess, too; they must hide it better. I wouldn’t want to join a club with people like that.”) Private clubs try to address troublesome members collegially and quietly, through private conversations. If those conversations do the trick, the problem is resolved without any public embarrassment to the club or the member. If not, the club puts the wheels in motion to kick out the member who has become a liability, an action that can become public knowledge.

For generations, regional accreditors followed this general model of exclusivity. Colleges initially “approved” by MSCHE in 1921, for example, included Bryn Mawr College, Georgetown University, Lehigh University, New York University, and the University of Pennsylvania, among others (Middle States Commission on Higher Education [MSCHE], 2009). Regional accreditors defined quality by the strengths of their (prestigious) members, which were largely what I call inputs into the educational process: attributes such as faculty credentials, incoming students’ qualifications, library collection, facilities, and money in the bank. The regional accreditors also required—and continue to require—a commitment to the traditional values of higher education, including:

• Study of the liberal arts and sciences
• Shared collegial governance
• Faculty research and scholarship
• Ongoing improvement beyond the minimum required for accreditation
• Collegiality within and across colleges

Actual student learning did not factor much into this equation; the assumption was that if a college had all these inputs, well, of course learning was bound to happen.

Also, for generations regional accreditation was purely voluntary; many colleges operated successfully without accreditation, with quality assurance provided only through state licensure.

And regional accreditors, just like private clubs, have always kept a quiet eye on their members, because continuing to accredit a college of poor quality can damage the reputation of the accreditor and its other member colleges. The accreditors’ traditional approach has been to work with troubled member colleges collegially and quietly, giving the college a chance to improve without damaging its public reputation. Only in the rare instances when it has become clear that a college does not have the capacity to bring its quality to an appropriate level has the accreditor traditionally taken steps to remove accreditation and make its action public.

Accreditation as a Process of Collegial Peer Review

Today the foundation of the accreditation process remains peer review. The American Council on Education (ACE) National Task Force on Institutional Accreditation has explained the benefits of peer review: “As in medicine and scientific research, peer review is the foundation of professional integrity and largely defines what it means to be a profession. . . . Peer review also promotes the dissemination and exchange of best practices as faculty and administrators visit other institutions and provide advice designed to improve performance” (2012, p. 12).

The Higher Education Act and Title IV

Things began to change in 1965 with passage of the first Higher Education Act (HEA). Title IV of the 1965 HEA established a number of federal postsecondary financial assistance programs, including Pell grants and federally guaranteed student loans. To be eligible for these programs, students must attend a college accredited by an accreditor that is recognized by the U.S. Department of Education as a Title IV gatekeeper.

After the 1965 HEA was signed into law, colleges that wanted their students to have access to Title IV financial aid programs—and that would be just about every U.S. college—saw accreditation no longer as an option but as a necessity. Hundreds of colleges that had not been accredited sought and earned regional accreditation in the 1960s and 1970s, including most community colleges.

Other accreditation organizations sought Title IV gatekeeper status to meet the needs of colleges that did not meet regional accreditation requirements. The Accrediting Commission of Career Schools and Colleges (ACCSC), for example, was founded in 1965 (n.d., “History of ACCSC,” para. 1).

HEA is reauthorized or amended every few years, and each reauthorization brings more requirements for accreditors in order to maintain their federal recognition. Further complexity is added by regulations developed by the U.S. Department of Education (ED) to implement each HEA reauthorization or amendment. For example, if HEA requires colleges or accreditors to report on something, ED regulations explain what to submit, how, and when. (While HEA/Title IV requirements are part of the U.S. accountability picture, this book does not discuss them in any detail, because they are subject to frequent and dramatic change.)

While accreditors are still private membership organizations, accreditors recognized as Title IV gatekeepers are now subject to so many federal regulations that some people (incorrectly) refer to them as quasi-government agencies. If an accreditation policy or requirement does not make sense to you, it may well flow from a federal regulation, with the accreditor no happier about it than you are. SACS-COC lists its requirements flowing from HEA and ED regulations separately from its other requirements and standards (Southern Association of Colleges and Schools Commission on Colleges [SACS], 2012). Even if your college is not accredited by SACS-COC, its separate list is a good way to identify those accreditation requirements that flow directly from federal regulations.

A Focus on Evidence of Outcomes

By the late 1980s, HEA was requiring Title IV gatekeeper accreditors to require the colleges they accredit to demonstrate that they are achieving their missions. Because the fundamental mission of virtually every college is education, this was essentially a requirement to demonstrate that each college’s intended student learning outcomes were being achieved by its students.

The 1998 HEA strengthened this language, requiring Title IV gatekeeper accreditors to require colleges they accredit to demonstrate “success with respect to student achievement in relation to the institution’s mission, including, as appropriate, consideration of course completion, state licensing examinations, and job placement rates” (1998 Amendments to the Higher Education Act of 1965, Title IV, Part H, Sect. 492(b)(4)(E)). This language has remained largely in place through subsequent amendments and acts. The examples in this statement imply that the federal government defines student achievement as a combination of student learning, course and degree completion, and job placement. After the 1998 HEA, many accreditors rewrote their standards to require more directly and explicitly the assessment of student learning outcomes and other aspects of college mission.

The Spellings Commission and Its Aftermath of Criticisms

In 2006 the Commission on the Future of Higher Education appointed by U.S. Secretary of Education Margaret Spellings (and commonly referred to as the Spellings Commission) issued a report that was highly critical of U.S. higher education, including accreditors. As Judith Eaton has explained, “Accreditation was called upon to provide more robust public accountability, to strengthen the rigor and thoroughness of its reviews, to take responsibility for what were characterized as higher education’s limitations in serving students, and serve as a catalyst, not a barrier (as alleged in the report) to educational innovation” (2013, para. 5).

While the Spellings Commission report led to greater federal regulation of accreditors through the 2008 enactment of the Higher Education Opportunity Act (HEOA), criticisms of U.S. accreditation from both within and outside the higher education community have not abated (ACE, 2012; NACIQI, 2012). Perceptions, whether true or not, include the following. (In Chapter 21, I suggest some ways that accreditors might address some of these perceptions.)

Accreditation is perceived as insufficiently rigorous. Some assert that, because accreditation is a collegial affair, reviewers are loath to create problems for colleagues at the colleges they are reviewing, so shortcomings and failures are swept under the rug.

Accreditation is perceived as inconsistent and unreliable. Some assert that two colleges with similar levels of quality and effectiveness may receive very different accreditation actions, partly because a degree of subjectivity is unavoidable—colleges are complex human enterprises, and many accreditors use volunteer peer reviewers with limited training—and partly because of inconsistency in requirements and procedures across accreditors. A regionally accredited college on the east shore of Lake Champlain in Vermont, for example, must require 40 credits of general education for a bachelor’s degree, but one on the west shore in New York can require less. These kinds of disparities can encourage “accreditation shopping” by colleges that operate locations in more than one accreditation region or are located outside the United States and are seeking regional accreditation. Such colleges may try to identify the regional accreditor whose requirements appear easiest to comply with and locate the university’s “main” campus in that region.

Accreditors are perceived as slow to remove the accreditation of sub-par colleges, although accreditors’ hands are tied by federal regulations that require due process before accreditation is removed (ACE, 2012).

Accreditation is perceived as not putting enough emphasis on meeting stakeholder needs, especially relevance and stewardship (Chapters 5 and 6). At this writing, only two of the seven regional accreditors explicitly mention serving the “public good” in their requirements (Higher Learning Commission [HLC], 2013; Western Association of Schools and Colleges Accrediting Commission for Senior Colleges and Universities [WASC Senior], 2013). As noted in Chapter 1, ED defines quality as “compliance with federal law and regulation in relation to employment, graduation, consumer protection, transparency, and affordability” (Eaton, 2013, para. 3), but some of these aspects of quality, such as affordability, have not been consistently areas of accreditation focus.

Colleges are perceived as too complex for accreditors to ensure across-the-board quality. U.S. colleges may offer dozens, if not hundreds, of incredibly diverse programs of study, and there is no simple, cost-effective way to review and validate every single one thoroughly. Some regional accreditors require an ongoing system of program reviews (Chapter 20) but, as with college-wide accreditation reviews, such reviews remain subjective, imprecise processes.

Accreditation findings are not perceived to be communicated transparently. Because of the complexity of most U.S. colleges, their quality and effectiveness cannot be summed into a simple report card or checklist; employment, graduation, and affordability measures do not tell their full story.

Accreditation is pass/fail; excellence is not recognized. The best possible action of many accreditors is simply to reaccredit a college; there is no public action that helps the public separate excellent colleges from the merely adequate. The National Advisory Committee on Institutional Quality and Integrity (NACIQI) has urged the federal government to “afford accreditors greater opportunity to offer more gradations in their accreditation decisions” (2012, p. 6).

The reputation of regional accreditation may be pushing some square pegs into round holes. Because the regional accreditors accredit America’s most prestigious colleges, they have the strongest reputations. Today, some employers require job applicants to hold a degree not just from an accredited college but from a regionally accredited college. This has led more and more colleges to seek regional accreditation, even though they may not be a good fit with regional accreditors’ traditional values of the liberal arts, shared governance, and academic freedom or with some regional accreditation requirements, such as faculty credentials.

Accreditation is perceived as taking too much time. Colleges can find accreditation work incredibly time-consuming. Some colleges have full-time administrators who work year-round solely on compiling documentation needed for a specialized accreditor. Many colleges have multiple specialized accreditations, and those accreditors have diverse and sometimes conflicting requirements.

Does U.S. Accreditation Work?

While some of the criticisms of America’s somewhat messy “system” of quality assurance have merit, the system is not irreparably broken.

Accreditation remains a well-regarded seal of approval on college quality. “Accreditors are the most experienced source of information about academic quality” (NACIQI, 2012, p. 2). U.S. higher education and its accreditors continue to enjoy a good reputation at home and internationally; one indicator of this is the number of requests that U.S. accreditors regularly receive from colleges abroad to apply for U.S. accreditation. Despite recent criticisms, the general public still accepts accreditation as evidence of a college’s quality. Indeed, as you might imagine, after years of working for an accreditor, I routinely hear questions from friends and family members along the lines of: “So and so is thinking about applying to X College. Is it any good?” The first three questions I look into are these:

• Is the college accredited?
• Is its accreditor recognized by the U.S. Department of Education or CHEA? Just as there are diploma mill colleges, there are what I call “diploma mill accreditors.” An unaccredited college or one accredited by an unrecognized accreditor may be legitimate, but enrolling there is risky, as credits and degrees earned there may not be accepted by other colleges or by employers.
• Is the college experiencing any difficulties with its accreditor and, if so, what are they? Some concerns, such as an outdated faculty handbook, can be promptly addressed, but sometimes the concerns are so great that the institution’s viability or legitimacy is called into question.

Accreditation weeds out the deadwood. Accreditation actions leading to a college’s closure are relatively rare, because colleges with the capacity to improve do so. But over the last decade, actions by regional accreditors led to more college closures than actions by the U.S. Department of Education (ACE, 2012). “Negative” accreditation actions, such as warnings, sanctions, or orders to show cause why accreditation should not be removed, increased about 50 percent from 2009 to 2011 and 2012 (Krupnick, 2013).

Accreditation respects and facilitates the diversity and complexity of U.S. colleges, which is the greatest attribute of U.S. higher education (ACE, 2012; Baker, Baldwin, & Makker, 2012) and makes it unique in the world. No matter what students want to learn, no matter how they want to learn it, there is a college in the United States that meets their needs, and that is thanks in large part to an accreditation system that lets that happen. A diverse network of accreditors, each with requirements appropriate to its member colleges, offers a comprehensive, balanced approach to quality and effectiveness that examines all five dimensions of quality discussed in this book. The U.S. accreditation system recognizes that most colleges aim to accomplish a lot more than simply prepare students for jobs. It allows a theology seminary, a research university, and a technology institute to address what is vital to each and to deemphasize what is irrelevant to each.

Accreditation can have high impact, forcing necessary improvements. Ralph Wolff has called accreditation “the most incredible process for institutional transformation that exists” (personal communication, July 17, 2013). Accreditation processes are community-building exercises (Mark Curchack, personal communication, July 11, 2013) that generate useful introspection and ideas, yield helpful recommendations from the review team, and force colleges to address issues that would otherwise be swept under the rug. Lebanon Valley College, for example, used a request for an accreditation report as an opportunity for study and introspection, leading to several “Eureka!” insights that led to tangible improvements (Damiano & Dodson, 2014).

Accreditation is a relatively low-cost system of quality assurance. While accreditation work takes considerable time, the reviews are often conducted by volunteers from peer colleges. This is far less expensive—both to colleges and to taxpayers—than paying government employees to do this work.