Statement of Dr. Judith Eaton
President, Council for Higher Education Accreditation (CHEA)
presented before the
November 21, 1997
Good morning, members of the Advisory Committee, representatives of the US Department of Education, and other colleagues and guests. I am Judith Eaton, president of the Council for Higher Education Accreditation (CHEA). I assumed these responsibilities on September 1.
I am pleased to speak here today about four things: first, to introduce CHEA; second, to talk about its role in quality education and accreditation; third, to speak about cooperation between CHEA and the federal government; and finally, to make some observations about federal policies that affect private accreditation. My remarks will focus on broader policy issues, not the individual decisions on particular cases that are pending.
CHEA was established last year to embody a reform initiative; it is a work in progress. In the simplest terms, CHEA warrants quality and provides a public voice. CHEA recognizes organizations that accredit institutions where a majority of the institutions grant degrees. It also recognizes organizations that accredit programs where a majority of these are degree granting. Initially, CHEA "grandfathered" the recognition granted previously by COPA and CORPA. Many of you know a great deal about the origin of CHEA, but let me briefly mention why CHEA exists, and how it was started.
CHEA's mission is to serve students, institutions, accreditors, and the public interest by promoting academic quality, through recognition of higher education accreditation bodies and advancing self-regulation. CHEA's principal responsibilities are:
CHEA was founded in late 1996. Over the course of CHEA's first nine months an interim director laid the foundations for a healthy new organization. In my twelve weeks as president CHEA has reached out to all constituencies. This includes the specialized, national, and regional accreditation agencies and the colleges and universities recognized by these agencies. These two groups make up the CHEA participating organizations that pay dues to support council efforts. CHEA's outreach efforts also include higher education associations and leaders and thinkers in the higher education community. Such individuals have been highly supportive of CHEA; and they have been innovative and generous in their help. CHEA is seeking to involve government; our initial concentration is on federal officials in both the executive and legislative branches. My remarks here today are a part of this. We also anticipate involvement of state officials and some of their organizations as well.
CHEA does not have an easy job, but many people in key places embrace our goals, want us to succeed, and are willing to help. We have retained an excellent full-time, permanent staff and have relocated to permanent offices. We are defining a research agenda, and are continuing revision of our own standards of recognition. We are augmenting our successful initial communication efforts. We are striving to ensure our long-term capacity to achieve our ambitious, vital goals.
CHEA has a task force that has been working to revise its standards of recognition for accreditation agencies. (This is one of the areas where the work of COPA needed to be strengthened). A draft version will be submitted for consideration by the CHEA board in early 1998. The standards will be reviewed widely by the higher education community and among all interested stakeholders during the first half of 1998. We may choose to make revisions, based on this widespread community deliberation. If the Board adopts the new recognition standards in mid-1998, that would allow about six months for accreditation agencies to adjust to them before CHEA would grant its first recognition under the new standards in early 1999.
NACIQI can certainly appreciate both the importance and the challenge of this task. CHEA must adopt standards which advance high quality education, which consider educational outcomes, and which foster accountability. CHEA standards must help institutions to undertake deliberative changes that will improve their quality. And they must achieve a consensus within the self-governing accreditation community.
CHEA's research agenda may also be of interest to you. Distance learning, an area in which so many advances are being made so quickly, is sure to be a major area of CHEA-supported research. Accreditors already are meeting this challenge in several innovative ways. But the ability of accreditors to develop appropriate quality assurance procedures for expanding technologies and innovative delivery systems will be a central issue for determining the success of peer-based accreditation in the next century.
Many institutional and agency leaders want to streamline approaches and eliminate duplications in accreditation. CHEA has had fruitful discussions involving institutional leadership and the accrediting agencies. Increased efficiencies in the accreditation process would be a major service to both our institutional and agency members.
Your own committee or the Department of Education (ED) may have other areas of mutual interest to suggest.
Let me return, briefly, to a bit of CHEA history. In the early 1990s, many people inside and outside of the higher education community believed that the American system of private accreditation - the voluntary, peer-based self regulation which guided quality assurance - was critical to strengthening higher learning and to sustaining its vital diversity. But these same people were dissatisfied with some of the workings of accreditation, and wanted to improve them.
Congress expressed its views in 1992 by writing into law the so-called "Triad" of federal regulation, private accreditation, and state licensure and oversight. Congress wanted to ensure high quality programs under HEA Title IV and to protect the fiscal interest of the U.S. in student assistance programs. This same law created NACIQI, replacing its predecessor committee, and providing new duties. The law also created SPREs, which were shortly put aside as a misstep. The new law directed the U.S. Department of Education (ED) to take on new duties and codified - placed in statute for the first time - certain specific elements for ED to consider when it "approved" accreditation organizations. In November 1992, a new administration was elected. The Administration inherited the task of implementing the new HEA provisions that had been enacted prior to the election.
Support in the higher education community for strengthening accreditation and making it more useful in the new context of the Triad led to the self-termination in December 1993 of COPA --- the Council for Postsecondary Accreditation. COPA was the organization --- in some ways, but not in others that was the predecessor of CHEA. In 1994, national higher education associations and regional accrediting organizations initiated two years of intensive review and debate of how accreditation could be strengthened. In particular, they considered what form and mission for any new national organization addressing accreditation issues would be the most effective. Many of you participated in this process and remember well the relentless search for the elusive consensus.
After one proposal was put aside, a second proposal - the present CHEA - was submitted to an unprecedented referendum among college and university presidents. Ninety-four percent of the more than 1,600 presidents participating in the referendum affirmed CHEA. (Those of you who have chaired meetings of deans, presidents, or faculty will appreciate the difficulty in obtaining this high level of consensus after two years of strenuous debate.) A board of directors was selected and first met in July 1996.
As the higher education community was turning its attention to accreditation following the enactment of 1992 HEA amendments, so NACIQI was reshaping itself for a revised role. The statutory functions of NACIQI had been revised. Two of your several statutory functions are of the primary interest to CHEA: your advising the Secretary of Education on standards for accreditation agencies (as they are now listed in the HEA statute) and your advising the Secretary on relationships within the Triad.
The Triad proceeds on the basis that private organizations grant accreditation while ED (with NACIQI advice) grants institutional eligibility and certification. These are distinct activities with distinct purposes, but they are somewhat parallel. Accreditation by private groups, ED certification of institutions, and state licensure (as the third "leg" of the Triad) each represent a different path to the same superordinate goal: high quality education and a sound investment of public monies. Like the Advisory Committee and the leadership of ED, CHEA cares about accountability and educational outcomes. Because CHEA and ED/NACIQI have a shared goal, mutual interests, and parallel paths, I urge that we forge a sound working relationship.
My purpose today is not to determine the particular means of our cooperation, but rather to open the dialogue on how we might help one another. Some possibilities include consultation in areas of mutual interest, notice of formal actions, or joint activities in public communication and policy seminars. Perhaps the Advisory Committee has its own suggestions as to how we might collaborate. CHEA would welcome such ideas.
One issue on which we might share views is the pending reauthorization of the HEA, in which Congress likely will revisit the Triad issues particularly with regards to SPREs. While it is perhaps unfortunate that the delay in OMB clearance prevented the Administration from completing and promulgating its formal and final proposals regarding Title IV and accreditation issues, the delay appears to be an opportunity. It allows additional time for the Advisory Committee to exercise its statutory functions, under Subsection (C), paragraph 1, "to advise the Secretary with respect to establishment and enforcement of the standards of accrediting agencies"; as well as paragraph 7, which deals with relationships among the Triad.
Let me make two observations about the Triad; first no one thinks its perfect; second, no one has invented a superior system. So I stress that we should strive to make it work as well as possible. Considerable evidence suggests that it does work well; the most recent evidence is the ED announcements last week on five years of continued improvements in student loan default rates.
A guiding principle of the CHEA position is that the various tasks of accountability within the Triad should be assigned clearly and unambiguously to the proper parties. Issues of determining educational quality are better left in the hands of private accreditation organizations, while issues of the public interest in financial and administrative activity should be given to the government to settle and to enforce. That is the only way the Triad will work well: with each element doing what it does best and following its natural functions.
CHEA believes that the 1992 law does not follow this principle. The listing in the HEA statute of the ED standards for approving accreditors is excessive in its reach. This belief is shared by the 21 other higher education associations in their joint, consensus recommendations to the Congress on HEA reauthorization. We believe that the statutory list of standards for ED approval of accreditation agencies or associations, as revised by Congress in 1992, places a federal official in an inappropriate role. It does so by insisting that accreditors demonstrate to ED that they assess and enforce standards on institutional administrative compliance activities already covered by the two governmental legs of the Triad. These administrative compliance activities traditionally have not been a part of accreditation and are not primarily educational in their nature.
We support retaining in the statute the initial elements of this list, which are clearly academic in nature. These elements are the heart of good accreditation practice. They include requirements that accreditors must assess areas including curricula, faculty, facilities, support services, and admissions. But CHEA and the 21 other associations suggest that the list should no longer include accreditors assessing areas such as institutional default rates, tuition and fees, and audit reports. These latter areas are the proper domain of government activity focused on compliance. CHEA urges that the Triad be strengthened by assigning clear and distinct roles to each of the three sides. The Triad demands three parallel paths to participation in Title IV programs. The Triad is inefficient when it is demands unneeded duplication. And the Triad is ineffectual when it demands from an organization tasks which are better performed elsewhere.
(The aforementioned list of 12 standards that accreditors must assess in each institution appears in paragraph 5, subsection (a) of Section 496, addresses federal approval of accreditation agencies. CHEA would be happy to provide specifics on this and its other legislative proposals should they be helpful to your Committee.)
NACIQI members possess vast experience in accreditation and related issues. Your service on the committee demands enormous dedication to the review of submitted materials and careful sifting among evidence and sometimes conflicting viewpoints to render judgments on approval of accreditors. CHEA commends you for this important service to students, institutions and the public interest. Given your special and privileged viewpoint on the functions - and the limitations - of federal activities, we urge you to emphasize that the federal role in higher education should not be stretched too far.
Since HEA was last reviewed in 1992, a new and bipartisan consensus has emerged in our country regarding deregulation and the role of government at all levels. Using a phrase from the Clinton administration, people want government that "works better and costs less.” Congressional leaders elected in 1994 have certainly emphasized decreased regulation, and have put forward many reform supported by both parties and the Administration to reduce the governmental control in areas where the voluntary activities of private groups can do a task better accomplished the task.
You know well that the independence and diversity of the colleges and universities in our country are basic reasons for their success. All over the world, nations are trying to emulate the American model of higher education, even as international students continue to "vote with their feet" by coming here to pursue their studies. Strengthening each element of the Triad, with federal attention on compliance and accreditation attention on quality of education, is a vital means of sustaining American higher education as the world leader in our increasingly competitive global society.
Thank you for the opportunity to speak with you this morning. I would be happy to answer any questions.
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Last Modified: December 8, 1998