New Directions for Higher Education: Q&A with Judith Eaton on Self-Regulation

Nearly a year ago, NEJHE launched its New Directions for Higher Education series to examine emerging issues, trends and ideas that have an impact on higher education policies, programs and practices.

Past installments of the series featured Philip DiSalvio, dean of the College of Advancing & Professional Studies at the University of Massachusetts Boston, interviewing: Carnegie Foundation President Anthony Bryk about the future of the credit hour; and Publisher Mark Kantrowitz about student debt; Lumina Foundation President and CEO Jamie P. Merisotis about Lumina’s commitment to enrolling and graduating more students from college; American Council on Education (ACE) President Molly Corbett Broad about the efforts ACE is making to raise educational attainment in the U.S. and around the world; AAC&U President Carol Geary Schneider on liberal education; Richard Arum, co-author of Academically Adrift: Limited Learning on College Campuses; Richard D. Legon, president of the Association of Governing Boards of Universities and Colleges (AGB), on the growing challenges facing higher education governance; and Matthew Sigelman, CEO of Burning Glass Technologies, a Boston-based labor market analytics firm, on the inextricable link between higher education and the economic well-being of New England.

In this installment, DiSalvio interviews Judith S. Eaton, president of the Council for Higher Education Accreditation (CHEA), the largest institutional higher education membership organization in the U.S. A national advocate and institutional voice for self-regulation of academic quality through accreditation, CHEA is an association of 3,000 degree-granting colleges and universities.

The context

Accreditation in the U.S. is seen as a system that provides quality assurance for higher education. Designed over a century ago as a voluntary non-governmental peer review process, its original purpose was to identify which postsecondary institutions should be considered colleges and universities.

Since the fifties, accreditation has been the legitimizing conduit in determining eligibility for federal financial aid. Since then, the federal government has relied on accreditation as reliable authorities on educational quality, essential to determining where students spend their financial aid money.

With billions of dollars invested annually in financial aid, the federal government sees its role as ensuring that the higher education institutions which the recipients of federal financial aid attend are of sufficient educational quality. Accordingly, the history of the past 20 years shows steadily increasing federal involvement in accreditation.

The reliance on accreditation as a gatekeeper to financial aid has come under increasing scrutiny with escalating external pressures to adopt more prescriptive assessment methods to satisfy demands for “accountability” and with calls for accreditation to function more as form of compliance—with law and regulations. The U.S. Department of Education through its regulatory power, and the Congress through legislation, have already placed a number of requirements on institutions of higher education that are ostensibly about quality.

The transformations taking place today in the higher education scene further complicate the role of accreditation. Meeting new expectations and demands and adapting to a government-defined role are just a few of the challenges facing accreditation today. Whether accreditation can keep pace with these challenges will have some effect on higher education institutions in the future.

Judith Eaton offers her views on the history, functions and issues facing accreditation today. As a proponent of self-regulation of academic quality through accreditation, Eaton argues that institutional autonomy and academic freedom are at risk when peer review becomes more limited and the federal government, through its regulations, gets more and more involved in the academic part of what colleges and universities do. Significant changes may be around the corner for accreditation and Eaton provides insights on how higher education leaders can prepare for those changes.

The interview

DiSalvio: It’s been questioned by some whether the current higher education accreditation system sufficiently guarantees the quality of education students receive at postsecondary institutions. What do you see as the major criticisms of higher education accreditation and is there any evidence to support such concerns?

Eaton: What we have currently is a lack of alignment between purposes and expectations. Accreditation was developed as a collegial process, using peer review with a primary focus on quality improvement. That collegial approach has worked for a great many years. While this approach has grown over the past 20 years, in the past five years, there has been, especially from the federal government and some states, an expectation that accreditation should function as a form of compliance with statutes and regulations. I’m referring to the requirements in the law as to what accreditors must do with institutions or programs in accordance with regulatory criteria outlined by the U.S. Department of Education. Institutions are required to document compliance with those regulatory criteria, and accreditors are obligated to consider such compliance when the institution is reviewed for initial membership or continued accreditation.

The focus of the Council for Higher Education Accreditation is primarily on federal policy and the thrust of that interest in accreditation in the form of “compliance vs collegiality” is attention on student learning outcomes, transparency and higher levels of student success. The large amount of emphasis on completion these days is much more than in the past. And when accredited institutions fail to fit expectations with regard to graduation, completion and job placement, the accreditation system is criticized as weak or as ineffective.

Higher education accreditation is struggling through this now. This can be seen with the federal government hearings and Senate debate in the area of for-profit higher education. For-profit institutions, no matter who accredited them–a very important point–were taken to task. For-profit higher education recruiting and marketing practices, their low graduation rates, and their high student loan defaults, were all criticized. We’ve seen it in all of the concern about what the federal government calls “gainful employment.” Questions are increasingly being asked about students obtaining adequate jobs. We’ve seen it in the ongoing criticism of the persistent increases in tuition, whether it be public or private higher education.

The government turns to accreditors and asks how this can happen. Whether all these expectations with regard to accreditation is appropriate is another story. We have a lack of alignment and that lack of alignment has produced serious criticism of accreditation.

DiSalvio: As a national advocate and an institutional voice for self-regulation of academic quality through accreditation, what do you see as emerging issues in accreditation and quality assurance?

Eaton: There are three vitally important issues related to self-regulation of academic quality through accreditation. The first and foremost issue is that of innovation and change. There are a myriad of examples of such changes including competency-based education and assessment of prior learning. At the same time, there are criticisms of accreditation in that accreditors are not adequately responding to innovation and change in higher education.

Another very big issue for accreditation is the question of rigor. How adequately demanding are accreditors? Note that accreditation was set up not to guarantee quality but to assure quality and to provide that at least a threshold of effectiveness is attained. Accreditation serves to assure that an institution keeps to its commitment of providing effective education and where there is a need for quality improvement, the institution is poised to take steps to improve. It was set up to assure that we had threshold effectiveness in higher education with a very important proviso that where you see less-than-stellar performance, there is a powerful commitment on the part of an institution to improve.

That goes back to the misalignment and the question of whether accreditation is doing a good enough job. There are a number of government officials, elected and appointed, in Washington D.C., and in other places around the country who say those thresholds need to be higher. Some of them say that there is inadequate amount information about how well a school is doing and that accreditation, in some instances, allows institutions that have serious problems to remain accredited for too long a time while they get better. That quality improvement approach, which was acceptable for a great many years, is now coming under question and accreditation must respond. I do think we need to take a look at the issues around rigor but don’t want to lose the essence of quality improvement in the context of that exploration. That is essential.

The third vital issue for accreditation is public accountability. To the extent that we are transparent and provide readily available and understandable information to the public about the performance of higher education takes us to what we know about an institution’s performance. What do we know about graduation? What do we know about students going on to advanced degrees? What do we know about successful transfer of credits? In some instances, but certainly not all, we need to know about successful efforts at employment with more transparency and more direct information about results. It is something we need to take on even more than we have in the past.

While we have made strides in all of these areas–innovation, rigor and public accountability—those are the vital issues that confront us today and we do need to do more.

DiSalvio: Can accreditation keep pace with these challenges?

Eaton: Accreditation can keep pace with these challenges because it is rich, it is deep and it is comprehensive. Furthermore, it is very responsible because it is professionals reviewing professionals. However, we have to accelerate the pace of change in accreditation despite a culture that is very deliberate. Someone once said higher education is a conservative with a small “c” enterprise. Why? Because there are so many things of value. The same thing is true for accreditation. But in today’s world, with the way things are changing, we need to accelerate our pace of change and do more—and do it more quickly.

A good example of this involves the issue of innovation. We have been saying to the accreditors that with these innovative changes going on in higher education today—such as open courseware, MOOCs, badges, competency-based education, companies providing higher education coursework—may be here to stay and may involve huge amounts of students. If that turns out to be the case, then who will be responsible for the external quality review associated with these offerings when they do not reside within the walls of a college or university? The answer right now is nobody. There may be internal quality review in these companies, but there is no external quality review. Should this be the job of accreditation? If so, how should it be done?

We must grapple with that issue now and not sit back and simply say that innovation in higher education is happening and we will only concern ourselves if asked. We need to be more purposeful. We need to be more intentional. I don’t mean to say that accreditors ought to make decisions that institutions make. I only mean that if we are going to have this whole non-institutional set of activities, we need to be talking about and assuring quality improvement as well.

DiSalvio: Should the current accreditation and federal government relationship and the role of federal recognition be re-thought when we talk about accreditation?

Eaton: Yes. The misalignment and the issues we have been discussing are at the heart of the federal government’s belief that it has to expand regulatory oversight of accreditation.

This has been an ongoing debate over the past several years, especially since the Spellings Commission. If accreditors are going to play the role of being part of the pathway of funding eligibility of institutions, federal scrutiny of accrediting organizations is inevitable. However, this has become extraordinarily burdensome, tiresome and expensive and needs to be reined in. It is not unusual, for example, for an accreditor in the course of trying to meet the obligations of a federal review to upload 300, 400, 500 documents for the federal government to review.

Keep in mind that there 93 different criteria that accreditors have to meet every five years. When the relationship first started with the federal government, accreditors had six basic obligations. Today, there are 10 pages of law with 28 pages of regulation and 88 pages of sub-regulatory guidelines that inform accreditors on how to do their work. That is overkill, in my opinion.

There are two things that need to be done about this. First, we need to clarify what the federal government’s responsibility is and what is the accreditor’s responsibility is. The way the law reads, accreditors are supposed to be “reliable authorities” with regard to the quality of education—not about financial aid, not about loan defaults, and not about any law or regulation to which the federal government wants to subject an institution. If you observe what accreditors have to do today, they are required to go well beyond the educational quality issue. Currently, the accreditors are taking on more and more burden with non-academic issues. At the same time, the federal government through its regulations, is getting more and more involved in the academic part of what colleges and universities do. For example, witness the federal definition of the credit hour.

Secondly, we need to step back and have a fresh start. I like what Sen. Lamar Alexander says about a fresh start. We need first to clarify roles and responsibilities and to streamline the regulatory process. Accreditation stands between higher education and billions of dollars of federal funds a year. Of course, accreditation must be accountable but regulations must be streamlined. We must step back, consider what is really needed and what we are trying to accomplish. We certainly do not need 93 criteria, 88 pages of sub-regulatory guidelines and 28 pages of regulations.

DiSalvio: What is on the horizon for higher education accreditation and how can higher education leaders prepare for changes in accreditation as they continually seek to enhance quality and service for students?

Eaton: The emerging big event is the reauthorization of the Higher Education Act. The act, even with its one year extension, ends in September of 2014. Of course, the Congress can extend the law further if it wishes. We do not know when members are going to start working on the reauthorization but have been told there will be some writing early this year.

I can come up with a scenario where we would not see a reauthorization bill until after the next presidential election. However, we know it’s on the horizon. We also know that if we do nothing, we are on a path for more regulation with the federal government taking a much more active role in judging quality. Emblematic of that active role is the intention of the U.S. Department of Education to develop a rating system that rates colleges in terms of providing a good value—in accordance with President Obama’s often cited principles of access, affordability and outcomes. There have also been discussions coming from the executive branch that we need an alternative validation system for innovations in education because accreditation is a barrier to innovation.

What academic leaders and higher education policymakers must understand is that there is a powerful effort to move it in the direction of compliance versus collegiality. Doing so will be harmful to institutional autonomy because institutions will be controlled more by law and regulation. It will be harmful to our mission-driven institutions because with a central authorizing department judging benchmarks of quality, there will be a move toward standardization. This raises serious questions about academic freedom and will make peer review more limited.

It is essential we do not lose peer review and institutional autonomy and academic freedom and mission. Those vital elements in our nation’s higher education enterprise have defined us and have made the U.S. higher education system one of the strongest and most effective in the world.

College and university presidents, provosts and deans and the entire higher education community must make sure people understand the issues and challenges facing accreditation and they must share those concerns with federal and state legislators. The fundamentals of our higher education system are at stake.





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