Federal Policy Events and Reflections on the Accreditation–Government Relationship: Four Points

August 20, 2007

These remarks were delivered by CHEA President Judith Eaton at the Annual Meeting of the State Higher Education Executive Officers on July 19, 2007 in Chicago, IL.

The major federal policy events of the past 18 months or so—reauthorization of the Higher Education Act underway since 2003, the 2005-2006 Secretary of Education’s Commission on the Future of Higher Education and the 2007 negotiated rulemaking on accreditation—all have profound consequences for the accreditation–federal government relationship.  These events are still in play, with reauthorization far from over and activities related to the Futures Commission continuing. This is, however, a convenient time to pause and ask what we have learned thus far. I take away four major points about the impact of what is happening on our future relationship with the federal government. The points are about the voices of accreditation, fault lines, preferred perceptions and the price of credibility.

The Voices of Accreditation

It has been clear throughout these past months that there is no single accreditation response from the 81 Department of Education- or Council for Higher Education Accreditation (CHEA)-recognized accreditors, or even the 60 CHEA-recognized accreditors, about these experiences and the vital issue of the accreditation–government relationship

On the one hand, it is fairly easy for accreditors to speak with one voice at the level of principle and certain core beliefs. At 30,000 feet, we would find common ground in relation to:

    • The importance of institutional autonomy,
    • The need for institutional mission as a key driver of institutional judgment about quality and
    • The value of academic freedom.

We would even agree about the importance of addressing accountability.

On the other hand, our characterizations of what counts as autonomy, the role of mission and academic freedom—the specifics—would vary greatly.  The agreement at 30,000 feet pretty much evaporates as we descend to, e.g., 5,000 feet.

Accreditation is no different, in this regard, than any other part of higher education. Just think about faculty meetings, the various associations to which we belong or state meetings that involve different types of higher education institutions—how often do we agree on important policy issues in these settings? And, when there is agreement, how often is it only at a higher level of conceptualization and not at a level closer to application?

I take away from recent federal events that there is, quite appropriately, a range of accreditation responses in the federal policy arena. To expect this rich and diverse community to routinely “speak with one voice” is to be both foolish and disappointed. Accreditation has a number of voices.

Fault Lines

The complex of recent federal events has made prominent some key fault lines within higher education, within accreditation and between our two communities. The fault lines are not new; we are aware of them and have worked around them for a long time. However, events placed a great strain here, emphasizing their presence.

There is a fault line within accreditation, with the for-profit sector more comfortable with quantitative data and more prescriptive standards as measures of quality and regional and programmatic accreditors sometimes only a bit comfortable and other times not comfortable at all with using these data and standards.

There is a fault line among institutions, with public institutions generally more accepting of at least some additional accreditor or federal control and many private institutions less likely to be comfortable here.

There is a fault line between accreditors and institutions – with some accreditors seeking greater influence to control or set academic standards and institutions claiming that accreditors lack this authority.

The issue of fault lines came home to me forcefully in one negotiated rulemaking session where, at one point, some accreditors took the position that they have a primary role in determining levels of quality performance, apparently setting aside the interests of institutions and programs they review. It came home to me forcefully in reauthorization, when at least one Washington association head wanted language in the recently passed Senate bill to assure that regional accreditors could not set standards of achievement for institutions.

I take away from recent events that longstanding fault lines in our communities have resurfaced and we are better off acknowledging them, working to understand and respect our differences.

Preferred Perceptions of Accreditation

We have many preferred perceptions and fond beliefs about accreditation. Recent events make clear, however, that reality is a bit more complicated for us.

There is the preferred perception that accreditation is voluntary. In reality, an institution is highly unlikely to be both successful and unaccredited. Institutions need accreditation.

There is the preferred perception that accreditation is nongovernmental. In reality, accreditation, as part of being valuable to institutions, must endure significant government regulation and act at least part of the time, as an agent of the government—both formally and informally. This is a result of the federal recognition process and the gatekeeping role that accreditation plays.

There is the preferred perception that accreditation is owned by institutions. In reality, accreditation has also become, over the years, its own force  and sometimes operates independently of institutions. It can be a source, from time to time, of some conflict and even resentment from institutions—a circumstance that is not unusual for any regulatory body such as accreditation.

There is the preferred perception that accreditation has threshold standards that apply to all institutions equally. In reality, it is a challenge for some accreditors to answer  “When is 'good' good enough?” and explain how each institution can set its own expectations of success and virtually all institutions meet accreditation standards on an ongoing basis.

I take away from recent events that our preferred perceptions that accreditation is voluntary, nongovernmental, owned by institutions and has threshold standards are increasingly difficult to sustain.

The Price of Credibility

Finally, recent events strongly suggest that the future credibility of accreditation rests on our willingness to take on some difficult assignments.

As a first assignment, we need a frank reappraisal of whether and how to sustain our gatekeeping relationship with the federal government going forward. As any number of accreditors have pointed out over the years, we may be faced with a situation in which this role is so much at odds with our primary thrust of quality improvement that gatekeeping is hollowing out accreditation as we know and value it. How can our credibility be sustained under these circumstances?

As a second assignment, we need an even stronger response to calls for public accountability. Gatekeeping aside, we need to internalize that, more than any other single factor, what we do about accountability will drive the future credibility of accreditation, as well as confidence in our work. We are talking here about accountability for, e.g., evidence of student achievement, transparency, a willingness to engage comparability and ranking issues.

As a third assignment, we need to address enhanced rigor of undergraduate education, whether through individual institutional methods, something like the Collegiate Learning Assessment or Measure of Academic Proficiency and Progress, the work of the Association of American Colleges & Universities, capstone experiences or other undertakings. Absent a significant role in strengthening the quality of undergraduate education to meet future domestic and international needs, our credibility is at risk.

I take away from recent events that the future credibility of accreditation rests on our capacity for success with these difficult assignments, especially our success with public accountability.


In summary, even with events still a work in progress, a good deal has happened at the federal level in the last 18 months or so. As a result, we need to acknowledge and respect that accreditation is a complex community and there is no single response to important policy issues. We need to acknowledge and work with the fault lines within and between the higher education and accreditation communities. We need to compare our preferred perceptions about accreditation with the complex reality of current circumstances. We need to accept that our future credibility rests on our success with difficult and sobering assignments immediately ahead of us: reappraisal of gatekeeping, greater investment in public accountability as well as attention to the importance of more rigorous undergraduate education.