Testimony to the
Subcommittee on Postsecondary Education, Training and Lifelong Learning
US House of Representatives
Remarks by Robert Glidden, President of Ohio University
and Chair of the Council for Higher Education Accreditation
July 29, 1997
I am here today to talk about accreditation in American higher education with a particular focus on the relationship between accreditation and the federal government. I will describe briefly the current law on accreditation in the Higher Education Act, and identify some suggestions for amendments to the law that we believe will improve it. I will then conclude with some comments about the Council for Higher Education Accreditation (CHEA), and our priorities for a changing agenda on behalf of accreditation over the next few years.
Accreditation is a nongovernmental process that is uniquely American, first developed by colleges and universities in partnership with schools over one hundred years ago. It is a process of quality review, assessment, and assurance of standards. As you know, we have a remarkably diverse "system" of higher education in this country-uniquely so in the world-comprising both public and private institutions with a wide range of types of missions, from national research universities and regional comprehensive institutions to liberal arts colleges and very small faith-related colleges to community colleges and vocational institutions. The genius of this system is that unlike other countries we do not have a mandatory national curriculum for colleges; we do not have a national ministry of education that regulates academic standards; and students are free to choose what type of education they can pursue dependent on their ability and willingness to work hard. Because it developed as part of this diverse set of institutions, accreditation is a flexible and adaptive process. Institutions that seek accreditation can do so from a wide range of types of accrediting organizations-from national bodies that are oriented to a particular type of institution, to regional organizations that encompass a wide range of types of institutions, to specialized associations that focus on a single discipline or profession.
Accreditation began as an entirely private, voluntary process, and although it is still a nongovernmental process, for which we neither request nor receive federal funds, in truth we can no longer claim that it is entirely voluntary. The relationship with government and the increasingly public and quasi-regulatory role that accreditation plays represent a major issue for us in higher education.
The federal government first began to rely on accreditation in higher education at the time of the GI bill, when the decision was made to let the marketplace of student enrollment choices determine where federal funds were spent. This was in contrast to a system either of direct grants to institutions, or federal standards to determine which type of education or training was a national priority for funding. When the Title IV student aid programs were authorized, the decision was made to maintain accreditation as one of the criteria for determining institutional eligibility to participate in the programs, along with state licensure and assurance that federal eligibility requirements were met. This network of accreditation, state licensure, and federal review became known as the "triad" of shared responsibility for program integrity.
Because accreditation became the ticket to public resources, it stopped being truly "voluntary" for many institutions, and began incrementally to take on a more governmental or regulatory role. The federal government over time strengthened its procedures for determining which accreditors were reliable authorities, through a federal recognition process that evolved from a procedural kind of review to one that increasingly focuses on review of academic standards and evidence of results. Although many changes began to occur in accreditation in the 1980's and early 1990s-including as an example a movement toward more focus on the assessment of student learning outcomes-there was not a comparable strengthening of accreditation's national public role. At the national level, in the Council for Postsecondary Accreditation (COPA), which was the "umbrella" organization for accreditation from 1975 to 1993, there was relatively little recognition of accreditation's public role, and too little effective communication with government. There was also not enough done within higher education to address growing institutional frustrations with accreditation-concerns that regional accreditors were ineffectual, or that specialized accreditation was too intrusive. Those frustrations grew, as did the desire to increase alternatives to accreditation. Pressure for more accrediting associations grew in some quarters, but at the same time the public and some institutions questioned the relevance and usefulness of accreditation.
At the same time, public perceptions of problems in the student aid programs grew, including reports of fraud in institutions that were accredited as well as evidence of student loan defaults. This led to Congressional oversight of the default problems, and accreditation came under fire from Congress as contributing to an accountability problem in student aid programs. As a result, in the 1992 reauthorization of the Higher Education Act, Congress made significant amendments to the law in the new "Program Integrity" section, which included much more stringent regulation of accreditation, authorization for the State Postsecondary Review program, and greatly increased federal eligibility and certification responsibilities.
The section of the law that addresses accreditation is Part H, subpart 2, where the Department of Education's authority to regulate accrediting organizations through its recognition process is included. The most important changes in the 1992 amendments affecting accreditation were a new federal treatment of academic standards, and an extension of oversight and reporting responsibilities for accreditors that replicate federal governmental activities. The effect of the changes means that the role of accreditation as a reviewer of quality has been fundamentally changed, with the federal government increasingly getting into the business of dictating standards of quality, while accrediting organizations are incrementally forced to duplicate administrative and reporting activities of the federal government.
Specific examples of those changes and some of the problems with them are:
1. Standards: The standards that accreditors must review are now in statute, and the USDE has authority over how they can be written. Those standards include not just measures of quality, such as standards on faculty, curriculum, student learning outcomes, student services, recruiting and admissions, facilities, equipment and supplies, but extend to review of Title IV standards, including compliance with federal regulations and student loan defaults. Not only does this obligate accrediting organizations to duplicate what the federal government does, and make institutions do the same thing twice, but it establishes the legal precedent of giving the Department of Education authority to regulate academic standards for higher education, using the vehicle of Title IV. The current administration has refrained from using this authority, but the precedent and the potential for an expanding policy role for the Department of Education remain a problem.
2. Procedures: Accreditors must now show the USDE not just that they are doing the job of monitoring quality and maintaining standards, but they must also conform to many monitoring and oversight mandates, including mandatory unannounced site visits of all vocational programs and site visits for all new sites. These procedures are expensive, and do not add information or insight about institutional effectiveness. In addition, accrediting organizations must collect data that duplicates reports already being sent to USDE on financial and administrative standards and Title IV, including default rates. Those measures of institutional capacity are important, but they are already covered under USDE's own eligibility and review procedures.
The problems with the 1992 amendments, and the considerable blurring of federal and private quality assurance, caused pressure to build within higher education that contributed to the demise of COPA and brought about the creation of the Council for Higher Education Accreditation (CHEA), the organization that I represent. One of CHEA's highest priorities is to work cooperatively with government, to maintain a partnership between accreditation and the federal government, but at the same time to reinforce and protect the important differences between what can and should be done through nongovernmental means and what should be done by government. We have developed recommendations for amendments to the Higher Education act to support that goal-these recommendations are summarized in the attachment to my testimony and have previously been submitted to you.
I will conclude with some comments about CHEA -- its goals, source of authority, and emerging agenda. The Council is a non-profit organization of higher education institutions. Established in 1996 through a national referendum of degree-granting colleges and universities, it is a national voice for voluntary self-regulation through accreditation. Participation is voluntary and in its first year, 1996-97, 97% of the eligible colleges and universities supported CHEA with membership dues. Our goal is to serve students and their families, colleges and universities, and the public, by being advocates for accreditation, by working to strengthen accreditation through increased communication and cooperation, experimentation and innovation, and by strengthening our capacity to work cooperatively with government. CHEA has not attempted to be an all-encompassing organization of all postsecondary institutions-at least as we get started, CHEA membership is limited to degree-granting colleges and universities, and we will recognize only those accrediting associations that accredit predominantly degree-granting institutions or programs. We recognize that we cannot replace what the federal government can and must continue to do with its public regulatory role of accreditation, but we hope to complement that process in order to address a strengthened capacity and role for quality assurance through nongovernmental means.
We plan to accomplish our work by:
granting official recognition to higher education accrediting organizations that are objective, fair, and rigorous but even-handed; that adhere to an ethical code of good practice; and that demonstrate that they contribute to academic quality assurance and quality improvement through their standards and the way in which they implement them;
serving as an accreditation information clearinghouse for the public, decision makers, institutions, and accrediting organizations themselves;
being an advocate-providing a consistent and persuasive national voice-for accreditation as an essential component in American higher education;
fostering studies and discussion aimed at improving accrediting practices, including finding ways to make accreditation both more efficient and more effective; and
providing a balance among the interests of the institutions, the professions, and the public by mediating accreditation disputes.
CHEA hopes to enhance the usefulness of accreditation through research, experimentation, and professional development. The first goal is to advance the value and contributions of accreditation in higher education in America. CHEA plans to enhance the usefulness of accreditation by sponsoring a number of specific projects that address the salient problems and issues associated with accreditation in higher education. One such initiative was bringing together chief academic officers of institutions and executive directors of specialized and professional accrediting organizations for an invitational conference on enhancing the usefulness of accreditation. This proved to be highly successful and demonstrated the high degree of cooperation and collaboration possible within these communities.
The recognition of "sound and effective higher education accrediting bodies" is an important function that CHEA plans to perform. Although it is only one component of our overall mission, the recognition of accrediting organizations provides a service to accreditors, institutions, and the general public. The USDE does not recognize any accrediting group that is not required to determine Title IV eligibilty, but there are many other nonfederal uses for recognition, such as foundation or foreign government interests in U.S. higher education. CHEA therefore needs to stress service as well as focusing on educational quality and striving for effectiveness and efficiency. We have committed to reviewing and revising the recognition process to make it more useful.
Finally, CHEA has begun educational efforts on two important fronts. The first is among CHEA constituents of degree-granting colleges and universities and the accreditation community. The recent past of accreditation has been one of tension, conflict, and confusion. CHEA's first year has opened up new opportunities for dialogue and has seen a change in attitude and hope for the future of accreditation as we focus on addressing some of the major challenges of higher education with innovation and collaboration.
The other arena of education and communication that CHEA has only just begun is with the public: parents, students-here and abroad-and employers, who are interested in obtaining clear information about reliable sources of higher education. The Council for Higher Education Accreditation has established a world-wide web site, produced informational flyers, answered telephone and mail inquiries; and worked closely with the accrediting and higher education communities in communicating its role and the importance of accreditation.
We have also given considerable attention in our first year to enhanced relations with the federal government. While we believe that accreditation must be a non-governmental process, and that some of the most important of what we do is outside the Title IV eligibility and the gatekeeping "triad," we have learned that to ignore our public function is to do so at our peril. Some of the frustrations that led to the very prescriptive amendments in the 1992 law resulted from poor communication between accreditation and government. If government is to continue to rely on accreditation for quality assurance, and we feel it must, then we have an obligation to do more to assure public accountability for accreditation. We plan to do this by gathering information about how accreditation works, where it is effective, and how it can be improved, and then sharing this with government.
CHEA PRIORITIES FOR HEA AMENDMENTS ON ACCREDITATION
1. The essential achievements of the 1992 amendments, in reducing fraud and abuse in the Title IV program, and in significantly reducing defaults in the program, must be applauded and underscored. Changes in the law should ensure that program integrity is maintained through an appropriate sharing of responsibilities between accreditors, the states, and the federal government.
2. The blurring of roles among the federal government, the states, and accreditors is expensive, and confuses rather than helps focus accountability and performance between and among these actors. Clarifying the essential roles and responsibilities of the three parties to gatekeeping will be helpful in eliminating this problem. The framework for that should be:
· Federal government: protects the federal fiscal interest, through direct regulation of standards of administrative and financial responsibility.
· Accreditation: quality review, through the assurance that minimum academic standards are in place for institutions that seek to participate in federal programs.
· States: license or otherwise authorize postsecondary institutions to operate in their states.
3. Much of what is done by accreditation is not regulated by the federal government, and should not be. The limitations on the federal government's regulatory authority over academic matters must be clearly articulated in the law.
4. State authority to set standards for state institutions, and to license or otherwise oversee private institutions, must remain a state responsibility and should not be superseded by the federal government. The State Postsecondary Review Program should be deleted from statute, and replaced by a state licensure responsibility.
5. Additional amendments recommended:
· Delete the requirement that accreditors maintain duplicate standards for Title IV, defaults, measures of program length in credit and clock hours, and program length and tuition and fees. (Each of these repeats a federal standard.)
· Remove the requirement that accreditors perform mandatory site visits within six months for all branch campuses, and mandatory unannounced site visits of all institutions with vocational programs.
· Clarify that new instructional sites of existing programs are not "branch campuses."
· Clarify that public members of public institutional governing boards, and members of private boards of trustees, may participate as representatives of the public on accrediting agencies.
· Limit USDE regulatory authority over the content of accreditation standards by changing the word "approve" to "recognize" with respect to the USDE recognition function, and by language limiting the USDE's regulatory authority over higher education.
Robert B. Glidden became the nineteenth president of Ohio University on July 1, 1994, after serving for three years as provost and vice president for academic affairs at Florida State University. Previously, he had been dean of the Florida State University School of Music for twelve years (1979-1991), dean of music at Bowling Green State University (1975-1979), executive director of the National Association of Schools of Music (1972-75), and served on the music faculties of the University of Oklahoma, Indiana University, and Wright State University. He holds three degrees in music from the University of Iowa.
Dr. Glidden has served as president of the National Association of Schools of Music, member of the Board of Directors of the Council on Postsecondary Accreditation (COPA), and chaired the COPA Board from 1981 to 1983. He is presently chairman of the Council for Higher Education Accreditation.