NACIQI's Draft Final Report: Continuity, Change and Challenge

Judith S. Eaton

The Draft Final Report of the National Advisory Committee on Institutional Quality and Integrity released this month describes a future for accreditation in which the federal government plays a greatly expanded role in judging the academic quality of institutions and determining how accrediting organizations are to operate. While higher education leaders, accreditation leaders and government officials may agree on such goals as enhanced academic quality and strengthened accreditation, we may disagree about the strategy to achieve the objectives. In contrast to the path of greater federal involvement proposed by the report, robust institutional and faculty leadership for quality and accountability builds on the strengths that have brought the higher education enterprise to where it is today and offers greater promise to students and society.

Background

Eighteen months ago, the U.S. Secretary of Education asked the National Advisory Committee on Institutional Quality and Integrity (NACIQI) to initiate a review and provide recommendations about the effectiveness of accreditation and its relationship with the federal government. The NACIQI report is to be used by the U.S. Department of Education (USDE) as part of its preparation for the next reauthorization of the Higher Education Act (HEA) in 2013 or 2014.

After initial deliberation, NACIQI held three public sessions throughout 2011 as well as soliciting written and oral comment on drafts of its thinking to date. As of now, a draft final report (February 8, 2012) of proposed recommendations is available. The committee’s timetable includes another public comment period and another public session by conference call on April 13, 2012, concluding the work of the committee by May 2012.

NACIQI plays a pivotal role in the life of accreditation. It is a national body advising the Secretary about the federal recognition of accrediting organizations. Federal financial support is available to accredited colleges, universities and programs, currently estimated at $175 billion annually. Institutions that seek federal funds must be accredited by a federally recognized accreditor. Members of the committee are leaders from higher education, business, the public and students.

The Draft Final Report

Three features dominate the report. They tell us a good deal about how accreditation will be viewed and how the federal government would like it to operate in the future. The first feature is the emphasis on continuity, the second is a call for change in the government role and the third is a challenge to core features of higher education and accreditation.

The report emphasizes continuity through framing expectations of accreditation that are similar to those that have been discussed in many federal venues during the last half-dozen years. It envisions a future role of accreditation as primarily focused on public accountability and consumer protection, with less emphasis on quality improvement. The second feature, the report’s call for change, significantly expands the role of the federal government in judging academic quality as well as establishing standards for quality. Government would determine what is important.

Finally, the third feature, challenge, has two dimensions. By calling for judgment of academic quality to be increasingly based on common definitions and common data, the report encourages a convergence of accreditation standards. This is a significant challenge to the decentralized structure of accreditation – 85 independent institutional and programmatic bodies – as well as the diverse, mission-driven enterprise of higher education itself. It calls into question whether characteristics of higher education that have been fundamental to its mission-driven success – institutional autonomy, peer review and academic freedom – can continue to be effective.

The report is a response to the changing context in which both higher education and accreditation currently operate, speaking to the responsibilities of government. Higher education is now a mass undertaking serving 20 million students and spending some $450 billion per year. It is essential to both individual and societal well-being and security. Colleges and universities are viewed as vital to the economy and the competitiveness of the country as never before. They are seen through a pragmatic, often utilitarian lens: What will a degree cost? What will it do for me?

Responding to the current climate, the report envisions a major shift of responsibility and authority for academic judgment from the academic and accreditation communities to the federal government – in order that government can be confident that accreditation is carrying out its responsibilities. Taxpayer funds are to be used for “acceptable educational activities.” It goes beyond the prior practice of holding the academy accountable and encourages future practice in which government-driven decisions about the quality of individual institutions and managing the operation of accrediting organizations play a larger role.

Feature 1: Continuity

The recommendations in the report represent the most recent in a series of now-familiar messages from USDE and the Congress about the expected role of accreditation in assuring higher education quality. The messages have come from bipartisan sources and, taken together, envision a national role for accreditation that is a considerable departure from its initial purpose.

These messages were first formulated by the 2005-2006 U.S. Secretary of Education’s Commission on the Future of Higher Education. The commission’s final report called for more robust public accountability from accreditation, characterizing it as weak, lacking rigor, failing to adequately assure quality and serving as a barrier to innovation.

The work of the commission influenced the 2008 reauthorization of HEA that resulted in federal law (1) addressing key academic areas such as transfer of credit, textbooks, enrollment management and distance learning and (2) significantly expanding the law’s requirements with regard to how accrediting organizations operate. This was followed by the 2009 and 2010 negotiated rulemaking that resulted in (1) further expansion of government authority with regard to credit hour, (2) a federal view of the role of the states in oversight of higher education quality, (3) controls on how institutions provide information to the public as well as how institutions pay some employees (incentive compensation) and (4) judgment of the success of institutions by examining the employment of graduates (gainful employment). Most recently, Senate hearings on for-profit higher education in 2010 and 2011 culminated in severe criticism of accreditation – its rigor, effectiveness and reliability to serve the public.

Why is the report’s emphasis on continuity so important? Because it is a validation of the last six years of federal thinking about accreditation’s role. It signals that earlier, perhaps tentative views about expectations of accreditation have consolidated and strengthened. Familiarity breeds acceptance. Initial perspectives become future policy. Moreover, the ultimate impact of the messages is not a tinkering around the edges of accreditation, but a penetration of its fundamentals that is rapidly becoming the norm for future expectations.

Feature 2: Change

The report’s central premise is that to improve accreditation, greater government oversight and regulation are essential. Accrediting organizations are to be more directly managed by the federal government, including additional government judgment about decisions with regard to individual institutions and their accredited status and how accrediting organizations carry out their work. This is an expanded version of the longstanding federal interest in quality, a shift from expecting quality results to involvement in managing accreditation’s scrutiny of quality to achieve these results.

Suppose that a mythical institutional accrediting organization were to be formed and sought to be a federal gatekeeper. Suppose further that the advisory committee recommendations in the draft report actually became law or regulation. What would the structure and operation of a future accrediting organization look like?

Based on the current draft:

• A new institutional accrediting organization would still be a nongovernmental body, as all accrediting organizations have been to date. It could be self-regulatory, but in a new sense of the term: Self-regulation can take place only if it is subordinate within a robust framework of government regulation and is no longer an independent undertaking.
• The new body would be free to seek recognition as a national or regional accreditor. However, the report urges reconsideration of a regional structure for accreditation and reflects skepticism about the effectiveness of regional structures for the future.
• The new accrediting body would develop its standards for quality. However, where at one time the standards would have been left solely up to this new accrediting body and the academics establishing the organization, standards development would now be subordinate to multiple federal requirements about their content. These would include, for example, direction about approaches to student achievement and transparency.
• The new organization would develop its policies and practices associated with award of accredited status. However, where at one time the new organization would decide this on its own, this would now need to be addressed within the report’s call for differentiated levels of accredited status and accreditation review that is to be carried out with varying levels of scrutiny. This would be accompanied by a federal limitation on how the accreditor defined its key terms and the data used by the accreditor in its oversight of institutions.
• The new accreditor would decide how to provide information to the public. However, this would now need to be done in a manner that complies with the committee’s recommendations that accreditation reports are made public and that there is greater public participation on decision-making bodies.

Whether intended or not, the degrees of freedom enjoyed by accrediting organizations and institutions would diminish. Some of the authority and responsibility for quality once in the hands of academics and accreditors will now be in the hands of government officials.

Feature 3: Challenge

Of perhaps greatest significance in the report is the challenge to the leadership role of institutions and faculty in making judgments about academic quality. Accreditation, by virtue of being a self-regulatory activity, is supposed to reflect the best thinking of colleges, universities and faculties about the quality of higher education. We rely, after all is said and done, on the work of faculty and institutions to determine the content of curriculum, the award of degrees and the appropriateness of standards.

The job of accreditors is to affirm that this thinking takes place, that institutions and programs set appropriate goals, develop evidence that affirms that the goals are realized and keep their promises to students. Institutional and faculty decision-making are central to this process. With all respect, it is not intended that government officials play this role.

The report’s push for convergence means that to operate as an accreditor, the organization would first turn its attention to federal calls for “commonality across the quality assurance/eligibility enterprise” about student performance and educational practice. To the extent that self-regulation and peer review are sustained, they are practiced within a federal framework rather than independent of government oversight.

Higher education would have a “national” mission that overlays the diverse array of colleges and universities, perhaps diminishing valuable differences in educational opportunity. Will this overlay do harm to an enterprise that, although not perfect, has nonetheless served society well and continues to be robust and productive? Are we are replacing a peer-based, trust-based enterprise built on institutional autonomy, mission and academic freedom focused on academic quality and student learning with a combination of federal officials, members of Congress and politics as the primary determiners of the worth and value of higher education?

Is This the Future We Want?

While we need more attention to serving the public and the public interest and while both higher education and accreditation can do, should do and are doing more to address accountability for quality, it is questionable whether the shift in responsibility envisioned in the report is either desirable or needed. There is an alternative to the government-driven approach in the report, one that relies on the academic and accreditation communities themselves.

The path to even more effective accreditation is through institutions and faculty functioning as the primary sources of authority for academic judgment. Strengthening accreditation through the actions of the academic community means that both accreditors and institutions regularly provide evidence of student achievement. It means greater transparency about student learning and institutional performance. It means establishing and living up to expectations for the results of teaching and learning. It means the academy acknowledging its responsibility for evidence, to the extent that it is reliable, about the overall success or lack of success of students in the country’s colleges and universities. It means greater leadership for enhanced quality and accountability.

It is reasonable to question whether we need the continuity reflected in the report, a continuation of the narrative of government-imposed quality assurance of the past six years. It is worthwhile to ask whether change that results in a national structure for higher education atop the current and effective decentralized operation of institutions is needed or desirable. It is important to consider the appropriateness of a challenge that may limit higher education effectiveness, discouraging academic judgment and leadership.

The report’s efforts to shift the locus of authority for judgment of academic quality may be an unwise step that diminishes the benefits of higher education to students by putting government officials in charge of academics, using accreditors as administrative agencies for this purpose.