CHAPTER 19
DEMONSTRATING QUALITY TO ACCREDITORS

Every accreditor has its own requirements, and this book and this chapter do not serve as substitutes for them. As explained in the Preface, the purposes of this book are to help you understand why accreditors require what they do and to give you practical advice on meeting those requirements. But if any of my advice contradicts what your accreditor says, go with your accreditor!

Use Accreditation Processes as a Tool and Lever

Believe it or not, accreditation is good for you (Mark Curchack, personal communication, July 11, 2013). Accreditation actions force colleges to address problems that have been swept under the rug too long, like an outdated curriculum or a dysfunctional governance system. Accreditation is both a carrot and stick. The carrot is that no one likes being rebuked or “dinged” by an accreditor or the burden of extra reporting that follows; as Rose Mary Healy has explained, “It’s just easier to be good” (personal communication, September 5, 2013). The stick is getting that ding and being asked for that additional report; while no one likes it, virtually every college I have worked with has eventually admitted that it was the kick in the pants the college community needed to improve quality and effectiveness.

Even if your college has no major issues, accreditation processes are a great opportunity to advance a quality agenda and bring about needed change. With the right mindset—that you are implementing the cultures of quality for yourselves, not for your accreditor—no matter how good your college is now, it will be even better after an accreditation review.

Understand What Your Accreditor Is Looking For . . . and Why

Whether I am asked what accreditors are looking for or what good practices in higher education are, I give the same answers, because accreditation requirements are intended to be principles of good practice.

The key to meeting accreditation requirements, especially those of regional accreditors, is thus not to comply blindly with specific requests or requirements but to understand why accreditors are asking for those things. Every accreditation requirement is there for a reason. The better you understand the reason—the principles of good practice underlying each requirement—the better your chances of doing what your accreditor wants you to do and of undergoing a successful review.

Read the directions and ask questions. The most important resources for preparing an accreditation report are the information and guidelines provided by your accreditor. Yes, its requirements can be a long, slow read, but read them carefully nonetheless, at least those that are applicable to the report you are preparing. Read equally carefully your accreditor’s guidelines for the report you are preparing, along with any other materials from the accreditor that provide context. Many accreditors offer training sessions or other venues for addressing specific questions not answered through their materials.

Understand your accreditor’s underlying concerns with your college. All reports to accreditors have the same fundamental purpose: to verify that your college meets all or some of the accreditor’s requirements. No matter what the accreditor requests, even something straightforward such as an audited financial statement, the accreditor’s fundamental concern is with compliance with one or more of its requirements. Make sure you understand which requirements are the subject of your current review. If you are asked for a report on your enrollment management plan, for example, is the accreditor concerned with student retention or with tuition revenues and your college’s financial health? Read the accreditor’s request for the report carefully. Review prior reports and correspondence between your college and your accreditor to gain a sense of the history of the issue at hand.

Start Early, with an Honest Appraisal of Where You Are

The success of your accreditation review will depend largely on your capacity to be honest with yourself, recognize quality and compliance shortcomings, and grasp what you need to do to address them before the review is conducted. Colleges that fail to acknowledge that they are out of compliance with a requirement until their accreditor points this out often waste time in anger and denial before getting down to the business of making needed changes by stipulated deadlines.

The following continuum of quality may help you determine where your college is regarding accreditation compliance.

Level 1: A pervasive, enduring culture of quality, actively embracing all five dimensions. Your college not only has thorough documentation of compliance on hand but uses that documentation on a regular basis to inform decisions. This is the best possible scenario; preparation for accreditation review consists simply of conducting an overall analysis of existing documentation. Faculty who assess student learning regularly, for example, have on hand a good body of evidence plus documentation of resulting actions that they need merely summarize and analyze for the accreditation review.

Level 2: A culture of quality, but one that is informal, without systematic documentation. As some people have told me, “We’re doing this; we just need to organize and document it better.” Developing and implementing documentation processes and systems can take some time. To make matters worse, without systematic documentation, what was done for the last review may have been lost or forgotten, so extra time is spent reinventing the quality wheel.

A word of caution: undocumented perceptions can be wrong. For example, during my first year of full-time freelance consulting on assessment and accreditation, I could have sworn that the advice I gave colleges most frequently was to clarify their goals. Then I did a qualitative analysis of my consulting reports. To my surprise, my most frequent advice was to invest in faculty professional development (Suskie, 2013). I have seen enough other examples of undocumented perceptions not matching the reality of systematic evidence to conclude that assessment without documentation is not assessment, and many colleges that think they are at Level 2 are really at Level 3. By the time they come to realize this, they are often so close to the accreditation review that they do not have enough time to make necessary changes.

Level 3: Not yet a pervasive culture of quality, so not yet doing everything your accreditor requires. Preparing for an accreditation review when you are at this level is a major undertaking. If an academic program has not yet begun work on assessing student learning, for example, the faculty must articulate key program learning outcomes, then identify where in the curriculum they are addressed, then identify or develop assessment opportunities, then collect evidence, then review it, then use it to identify and implement improvements. This cannot be done in one semester.

I often suggest that colleges make a chart listing every line of text in their accreditor’s requirements: every sentence, phrase, or clause. Next to each line, list the college’s source(s) of documented evidence of compliance with that aspect of the accreditor’s requirements, and annotate how well the evidence demonstrates compliance. This can help everyone grasp where your college is in terms of compliance.

You may conclude that your college is at varying levels of compliance; some areas are at Level 1, while others are at Level 2 or perhaps even Level 3. I discuss how thorough your college’s compliance should be later in this chapter.

Understand Your Accreditor’s Emphasis on the Five Cultures of Quality

Of all the stakeholders who want to see evidence of your college’s quality and effectiveness, none expects more than your accreditors. Many stakeholders are interested in only some aspects of your college’s quality, but accreditors’ interests encompass all five cultures of quality. Your accreditor may emphasize some of the cultures of quality more than others, however. Stay up-to-date with your accreditor’s emphases by reading its correspondence and attending its meetings and workshops.

Focus on the culture of evidence. When the regional accreditors revised their requirements around the turn of the century to focus on evidence of achievement of goals (outcomes assessment), they knew they could not snap their fingers and immediately have all colleges in compliance with these heightened expectations. So they initially expected assessment plans and then gradually scaled up expectations of compliance, moving to expecting implementation of those plans, to expecting assessment results: evidence of achievement of key goals. As discussed in Chapter 20, specialized accreditors also require attention to the culture of evidence, although their emphasis on it varies.

Focus on the culture of betterment. As colleges are increasingly amassing evidence, regional accreditors and some other accreditors are now looking for evidence of the culture of betterment: the pervasive use of systematic evidence to ensure and advance quality, including informing goals, plans, and resource deployment.

Watch for increasing emphasis on the culture of relevance, including stewardship, accountability and transparency, integrity, and meeting stakeholder needs and the public good, especially by regional and national accreditors.

Demonstrate a pervasive, consistent, enduring culture of quality. Accreditors have a responsibility to ensure, for example, that all your students, no matter where or how they are learning, achieve your learning outcomes at appropriate levels of rigor. Accreditors also have a responsibility to ensure that your college can sustain compliance into the future. An accreditor would be concerned, for example, that a one-time gift is balancing your annual operating budget or that your assessment program is currently funded by a grant with no concrete, viable plans to sustain it after the gift or grant ends.

Organize Your Report and Supporting Documentation

Accreditors can be quite prescriptive in how they want your report and supporting documentation organized, so my fundamental advice here is to attend your accreditor’s meetings, webinars, and workshops and read and follow its guidelines. That said, consider the following approaches to organizing your report if they fit with your accreditor’s directives.

Organize information on your activities and evidence around your purpose and key goals. Regional accreditors in particular begin their reviews with your college’s mission and strategic goals literally in hand, continually comparing your evidence against the promises made in those statements. Evidence that is not clearly connected to key goals may not have much meaning to them. I see so many accreditation reports organized with one section on goals, another on programs and activities, another on assessments (with perhaps one subsection on rubric results and another on the results of a published test or survey), and yet another on improvements. Accreditation reviewers look at all this and think, “Well, we’re glad that you’re doing all those things and that you’ve collected all that evidence and made all those improvements, but what we really want to know is how they connect. What are those rubric and test results telling you about your achievement of your goals? How did those improvements flow from that evidence?”

These questions call for organizing and presenting evidence and improvements by goal, rather than separately. A college that has been asked by its accreditor to report on its assessment of its general education curriculum, for example, might organize its report as shown below if it has the flexibility to do so.

Organization of an Accreditation Report on General Education Assessment

  • Introduction, with an overview of the college, a description of its general education curriculum, and the context for the accreditor’s request
  • A brief history of how and why the college arrived at the curriculum’s structure and learning outcomes, showing that they reflect research and good practices
  • Separate sections or subsections for each learning outcome of the general education curriculum, each providing:
    • The learning outcome
    • A description of how student achievement of this learning outcome is assessed, with documentation, such as copies of rubrics, in an appendix
    • A summary of the assessment results for this learning outcome, such as scores for each rubric criterion, presented in a simple table
    • Analysis of the assessment results, comparing them to the college’s definitions of successful results, with defensible justifications of those definitions
    • Overall conclusions regarding student achievement of this outcome (tying together, perhaps, rubric scores, results of relevant survey questions, and relevant test sub-scores)
  • Overall conclusions from the assessments and next steps
    • Identification of outcomes for which student learning is satisfactory
    • For less than satisfactory outcomes, steps that have been or are being taken to improve student learning
    • Plans for improvements in general education assessment processes, as appropriate

View the report as a cousin of reports to your college leaders. Accreditors should see what your college’s board and leadership team should be asking to see: evidence, not assurances, of the five cultures of quality, presented concisely, with more thorough documentation available if needed. Indeed, if your college truly embraces the five cultures of quality, your accreditation report may consist largely of the reports of evidence that college decision-makers see and records of the decisions they have made based on those reports, such as minutes or e-mail streams. If so, the only thing that needs to be added is an overall analysis.

View the report as a cousin of a scholarly research paper. The structure suggested in the list above is similar to the structure of scholarly research reports familiar to many faculty. Table 19.1 compares the two.

TABLE 19.1. Comparison of Research Reports and Accreditation Reports

Elements Common to Both In a Research Report In an Accreditation Report
Begin with an introduction or overview. Overview of the study Overview of your college and the accreditation requirements under review
Address clearly articulated goals. Purpose of the study College and program/unit-level goals that are germane to the accreditation requirements under review
Articulate targets for those goals. Hypothesis Justifiable targets for key measures
Describe how evidence was collected, to provide assurance of the quality of the evidence and to replicate the work if warranted. Methodology Summary of how evidence was collected
Provide summaries of evidence related to goals and targets, often in simple tables. Results Documentation in supporting appendices, sufficient to demonstrate achievement of goals and to track the impact of subsequent improvements
Analyze evidence. Analysis Analysis
Present conclusions. Conclusions Conclusions
Identify further action based on the evidence. Recommendations for further study Implemented improvements based on the presented evidence

Should you use other reports as models? Chapter 16 talks about the importance of telling the story of your college’s effectiveness and quality in its own voice, and this is important to regional accreditors, who evaluate your college’s quality and effectiveness within the context of its purpose and goals. Combine this with the increasing rigor with which accreditors are enforcing their requirements, and it is not hard to see that the report written last year by a college down the road (or that you wrote five years ago) may not be a good model for what you need to write today.

I often compare accreditation reports to the writing assignments that faculty give to students. Some writing assignments, such as lab reports, expect all students to say pretty much the same thing in the same way. Likewise, some accreditors expect all their colleges to follow a consistent report format and structure. In these cases, using other recent reports as models may be helpful. But some writing assignments expect students to speak in their own voices, identifying their own topics and theses and organizing the assignment in whatever way best conveys their points. If your accreditor expects this approach, models of other reports will not be as helpful. In fact, following the model of someone else’s report may adversely impact the integrity of your story.

Provide Good Quality Documented Evidence for Everything You Say

Accreditors are obliged by their quality assurance responsibilities to require documented evidence and to verify that evidence. Platitudes and unsubstantiated assertions such as “We are in compliance with this standard” have no place in an accreditation report; answers without documentation are not answers (George Kuh, personal communication, August 26, 2013). Assertions like those in Table 19.2 need to be supported with solid evidence or removed.

TABLE 19.2. Examples of Assertions with Suitable Evidence in Accreditation Reports

Examples of Assertions Examples of Suitable Evidence
The strategic plan guides decision making. Meeting minutes and/or annual reports documenting decisions and how the plan supported them
Funding is expected to continue. Letters of commitment from funding sources
The board is composed of well-respected, qualified experts in their respective fields. List of board members and the key qualifications of each. (“Well-respected” would be difficult to document and should probably be deleted.)
Faculty and staff are appropriate in size, preparation, and experience to fulfill their responsibilities and to support the college in fulfilling its mission. Tables summarizing the credentials of faculty and staff and comparing those credentials against their responsibilities and the college’s mission
The Board self-evaluates the overall functioning of the Board of Trustees. Board reports on its self-evaluation process, results, and actions based on those results

Beware of phrases such as, “we believe,” “we hope,” “we anticipate,” or “we are confident that.” It is better to say, “we project, based on this evidence . . .” or “our plans, based on the evidence in Appendix A, are to. . . .”

No matter what kind of evidence you provide, it should meet the characteristics of good evidence that were discussed in Chapter 14. Evidence should be useful, current, and consistent, flow from goals, and have justifiable targets for success. Your report should document not just the existence of evidence but an ongoing, pervasive culture of evidence.

Provide evidence of outcomes, not just efforts. Many accreditors, including regional accreditors, focus more on outcomes than on the structures or processes used to arrive at those outcomes. Instead of requiring a specific governance structure, for example, your accreditor may want evidence that your governance structure is fulfilling its stated responsibilities and is a support, not a hindrance, to achieving your college’s purpose and goals. Similarly, accreditors do not want mere descriptions of assessment processes (or, worse yet, only plans to develop and implement them). Their interest is in whether those processes are generating systematic evidence that is used to advance the quality and effectiveness of teaching, learning, and your college’s programs and services.

How much evidence is enough? One of the most frequent questions I am asked is, “What does the accreditor want to see?” Actually, though, people know the answer to this: accreditors want to see evidence that your college is meeting accreditation requirements. Their real question is, “How much evidence is enough to satisfy the accreditor?”

Two very different questions are being asked here. One is how thorough your college’s documentation should be. Does your accreditor need to see all faculty résumés or a summary of faculty credentials? Does your accreditor want to see every course syllabus and assessment reports from every academic program, or will samples suffice? The answer is, of course, to ask your accreditor. A word of caution, however: if you provide a sample, you need to convince your accreditor that your sample is truly representative of what is happening across your college. If you share, say, student learning evidence for just three academic programs, your accreditor may naturally wonder whether those three are truly a representative sample of what is happening across your college, or your college’s best efforts, or the only three programs where assessment is happening. Your accreditor may also be skeptical if your largest programs are omitted or if your examples of student learning evidence are largely from professional programs with specialized accreditation, with little or nothing from your liberal arts programs or your general education curriculum.

The other question asked here is how thorough your college’s compliance with your accreditor’s requirements should be. Will your accreditor be satisfied, for example, if only half of your college’s academic programs have systematic evidence of student achievement of their key learning outcomes? If only three of your college’s eight general education learning outcomes are being assessed? If dashboard indicators have been identified for four of your strategic goals but not the other two? If most programs and units have collected at least some evidence of their effectiveness, but most have not yet acted on that evidence? If each program has examined ten student portfolios? The answer to these questions is, again, to ask your accreditor.

But all these questions are the wrong questions. They imply that you are collecting evidence merely to satisfy an accreditor, not to advance a pervasive, enduring culture of quality, including cultures of evidence and betterment. If you are only collecting evidence of student learning in some programs, in some general education requirements, or at some locations, for example, your college is essentially saying that you care about some students more than others (Lynn Priddy, personal communication, July 9, 2013).

So my answer to these questions is, “How much is enough for you to understand and improve quality throughout your college and ensure an enduring, pervasive culture of quality?” While there are formulas and algorithms for calculating appropriate sample sizes of student work, for example (Suskie, 2009), I find that many faculty and administrators have a good sense of how many student papers or survey responses they need to see in order to draw meaningful conclusions and make appropriate decisions.

If your evidence is time-consuming to collect and analyze—things like student papers, portfolios, or interviews—try a qualitative approach to deciding how much evidence is enough (Suskie, 2009). Use a sample of ten papers or portfolios to draw tentative conclusions about your students’ performance. Then take another sample of ten, and see whether it modifies your initial conclusions. If it confirms your initial conclusions, you are done. But if you gain new insight from the second sample, look at a third sample of ten. Keep doing this until you look at a sample of ten that does not change your conclusions.

Put Shortcomings in Context . . . with Integrity

Nowhere is a culture of candor and honesty more important than with accreditors. In fact, if you misrepresent your college to your Title IV gatekeeper (Chapter 2), you expose your college to possible charges of Title IV fraud and abuse, with fines that can run into millions of dollars.

An accreditation report is, of course, an opportunity to celebrate achievements. If your college is like the vast majority of colleges, you have a great deal to be proud of, and your accreditation reports should reflect that. But nothing raises a red flag faster with accreditors than a completely positive report, painting a picture of a college in which everything is great and there are no areas for improvement other than staying the course. No such college exists, so painting this distorted picture raises questions about your college’s integrity. When your college glosses over or omits information on a key issue from an accreditation report, accreditors cannot help but wonder, “What else are they hiding?” That suspicion is hard to eradicate.

As I noted at the beginning of this chapter, it is just easier to be good. Frame your report to provide full and balanced information, share your college’s story ethically and responsibly, and present an appropriate balance between strengths and accomplishments and areas that need attention.

What if your college is not yet doing everything your accreditor requires? Simply stating intentions to comply with requirements at some point in the future is insufficient. Instead, as suggested in Chapter 16, place shortcomings in context, explaining why progress has been slow, then focus on what you are doing to rectify those shortcomings, with detailed information on how and when solutions will be implemented. If, for example, some of your academic programs are not yet assessing student achievement of their key learning outcomes, explain why and provide concrete, detailed action plans and prompt timelines describing exactly how and when the programs will articulate learning outcomes, identify assessment strategies, implement the assessments, collect the results, discuss them, and identify and implement any modifications. Such thorough action plans assure the accreditor that you understand what needs to be done and that things will be taken care of as soon as possible.

Respect the Reviewers’ Time

If you have flexibility in preparing your accreditation report, possibly your biggest challenge will be balancing the needs for thoroughness and conciseness. On one hand, you must include in the report everything that the accreditor expects, clearly documenting compliance with every requirement under review, with pervasive rather than spotty documentation. On the other hand, accreditation reviewers are typically volunteers with day jobs. While they want to give your report the careful attention that it deserves, there is a limit to how much time they can spend. Your task is to craft a report that is simultaneously thorough and concise, comprehensive yet succinct.

Use a brief introduction to orient the reviewers. The reviewers may never have heard of your college or may have only a passing familiarity with it. Give the reviewers an overview of characteristics of your college that they need to know in order to appreciate the accreditation story you are sharing. Share things like your college’s size, scope of program offerings, and locale. Include here a brief summary of any practices that might be considered outside the higher education mainstream, such as a non-traditional governance structure or faculty reward system, and any recent developments, such as leadership turnover, new programs or campuses, and financial challenges. Keep this section brief; use links or cross-references to later sections of the report to provide more thorough information.

Cull irrelevant information. I have seen reviewers visibly annoyed at having to wade through useless information. You do not want annoyed reviewers! Include only those documents or evidence that are essential to demonstrating your college’s compliance with the requirements at hand. Avoid “data dumps” of everything that seems remotely applicable, limit appendices to germane evidence, and cull out all irrelevant documentation. As discussed earlier in this chapter, report only those improvements that clearly flow from evidence that, in turn, flows from key goals. In some cases, excerpts, summaries, or representative samples—but not isolated examples—of evidence may suffice. Documentation of board actions, for example, might consist of the text and dates of relevant actions, rather than the full minutes of the meetings at which those actions were taken.

Make the case for compliance up front. Do not simply say “Appendices 1 through 25 demonstrate our compliance with the assessment requirement,” making the reviewers pore through your supporting materials to figure out on their own whether you have sufficient evidence to demonstrate compliance. Present your own analysis of the appendices; the reviewers should need to refer to the appendices only to verify your analysis.

Connect the dots. The cultures of quality are not discrete, and neither are accreditation requirements nor the many things your college is doing. Accreditation reports, therefore, rarely fall into simple linear narratives and can thus be a challenge to organize. A successful first-year-experience program, for example, may provide evidence of compliance with accreditation requirements on an integrated curriculum, student support services, assessment of student learning outcomes, and retention. Make sure the reviewers can easily see appropriate interconnections and interrelationships among the cultures of quality. Build in plenty of cross-references among sections of the report to remind the reviewer that Issue X was discussed more thoroughly back on page 4 and that Initiative Y will be discussed more thoroughly on page 11.

Keep your report an easy read, following the suggestions in Chapter 16. Here are some additional suggestions:

  • Find a writer or editor whose strengths are organization and business or technical writing. You want a report that is “tight and right,” not a flowery exposition.
  • Help reviewers easily find the supporting documents they are seeking either by using hyperlinks or by giving supporting documents intuitive, self-explanatory names and a clear numbering system.
  • Watch out for jargon and acronyms that the reviewers might not understand.
  • Ask willing board members and someone at another college to read your draft report and advise you on how easily they digest it.
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