National Advisory Committee on Institutional Quality and Integrity Releases Draft Final Report on Accreditation

Publication Number 22 February 17, 2012

National Advisory Committee on Institutional Quality and Integrity Releases Draft Final Report on Accreditation

The National Advisory Committee on Institutional Quality and Integrity (NACIQI), the federal advisory body that provides recommendations to the Secretary of Education on the recognition of accrediting organizations, has revised its the NACIQI Draft Final Report on accreditation considerations for the reauthorization of the Higher Education Act.The draft final report was posted to NACIQI's Website on February 16, 2012.

In December 2010, Secretary of Education Arne Duncan requested that NACIQI develop accreditation-related recommendations, examining "what is working and not working" in the current system of recognition and accreditation. NACIQI released a draft report on October 18, 2011, offering various perspectives on accreditation and outlining a range of potential recommendations that the Committee might make (see CHEA Federal Update #20).

The draft final report maintains the link between accreditation and eligibility for Title IV funds and offers recommendations for actions in areas including the role of the federal government and state governments in quality assurance, the role and scope of accrediting organizations, data as an essential tool in quality assurance and in public information and the role of NACIQI as a federal advisory body.

NACIQI will meet by teleconference on April 13, 2012 to discuss the draft final report. A notice published in the Federal Register on February 17, 2012 includes information on how members of the public may provide comments on the draft final report. The deadline for teleconference registration or to submit written comments is March 16, 2012.

In remarks made on January 25 at the CHEA 2012 Annual Conference, Susan Phillips, Chair of NACIQI's Accreditation Policy Subcommittee, said that the committee expects to send final recommendations to the Secretary of Education in late Spring, 2012.


Under Secretary of Education Martha Kanter addressed the CHEA Annual Conference in Washington, DC on January 24, 2012. In her plenary remarks, Kanter addressed a range of accreditation-related issues including defining what a degree means, optimizing student performance and the development of competencies, the desirability of three-year undergraduate programs and college affordability. She noted that it is now important to "reimagine the role of accreditation" and added "We do not have a national system of accreditation, but we do have national interests."

On January 25, 2012, NACIQI Chair Jamienne Studley and NACIQI members Susan Phillips and Cameron Staples participated on a panel at the CHEA Annual Conference. The discussion addressed NACIQI's role in the recognition of accrediting organizations and provided an update on the committee's draft report on accreditation (see item above).


On February 2, 2012, the Senate Committee on Health, Education, Labor and Pensions (HELP) held a hearing titled "Innovations in College Affordability." Witnesses at the hearing were Martha Kanter, Under Secretary of Education; Kevin Carey, Education Policy Director, Education Sector; Charlie Earl, Executive Director, Washington State Board for Community and Technical Colleges; Robert Mendenhall, President, Western Governors University; and Carol Quillen, President, Davidson College.

During the question-and-answer period, Committee Chair Tom Harkin (D-Iowa) raised the issue of accreditation's gatekeeping role for federal funds such as student loans and Pell Grants and whether accreditation impeded innovative, lower-cost approaches to education. Committee members also asked questions to the witnesses about transfer-of-credit policies and their relationship to college affordability.


Two USDE negotiated rulemaking committees - addressing Teacher Preparation and TEACH Grant programs and Student Loan issues - began meeting in January, 2012 in Washington, DC. In Federal Register notices announcing the negotiated rulemakings, USDE listed accrediting organizations among constituencies having interests that are significantly affected by the topics proposed for both negotiated rulemakings.

"Negotiated rulemaking" is a process by which the federal government consults with key constituents as part of drafting or revising regulations that implement legislation passed by Congress (in this case, the Higher Education Act).

The negotiated rulemaking committee focusing on Teacher Preparation and TEACH Grant programs will address issues including the definition of "high quality teacher preparation program;" the requirements for institutional and program report cards on the quality of teacher preparation; the criteria used by states to assess the performance of teacher preparation programs; and the service and repayment obligations for TEACH Grant programs. The negotiated rulemaking committee focusing on Student Loans will address a range of topics - from changes to repayment plans to school enrollment status reporting requirements - related to three student loan programs: The William D. Ford Federal Director Loan Program, the Federal Family Education Loan Program and the Federal Perkins Loan Program .

Both negotiated rulemaking committees will meet twice more in Washington, DC. The negotiated rulemaking committee addressing Teacher Preparation and TEACH Grant programs will meet on February 27-29 and April 2-5, 2012. The negotiated rulemaking committee addressing Student Loan issues will meet February 13-17 and March 26-30, 2012.


The Texas Workforce Commission - the agency that regulates career schools and colleges operating in the state of Texas - sent a letter to USDE Secretary Arne Duncan on January 2, 2012, objecting that USDE has "taken the position that under Texas law a career school or college is required to operate and measure time in clock hours." The commission's letter notes that for USDE to establish the clock hour standard "as a default position for Texas career schools and colleges runs counter to Texas laws and rules."

USDE implemented new credit hour and clock hour definitions and requirements, as well as expanded state authorizations regulations, in program integrity rules that became effective on July 1, 2011. Earlier, higher education associations, including CHEA, and accrediting organizations worked together to draft and send letters to USDE asking that the definition of credit hour and the new state authorization rules be rescinded (see CHEA Federal Update #15). The new regulations have also been criticized by the Association of Private Sector Colleges and Universities that represents for-profit higher education institutions.