The Association for Institutional Research (AIR) has joined the American Council on Education (ACE) and more than a dozen other higher education associations in a comment letter on the U.S. Department of Education's proposed accreditation rule. ACE submitted the letter, dated September 16, 2026, in response to the Department's notice of proposed rulemaking, “Accreditation, Innovation, and Modernization: The Secretary's Recognition of Accrediting Agencies.”

The proposed rule, published in the Federal Register on August 20, 2026, would rewrite the standards the Department uses to recognize accreditors. It covers how institutions choose and change accreditors, what accreditors are required to do, and how the recognition process works.

The letter voices support for several provisions. Among them are added flexibility for institutions to change accreditors or hold more than one, steps to reduce cost and regulatory burden, a faster initial-recognition process, and continued Title IV funding during arbitration and judicial review.

The signatories also raise concerns. They question broad language that would let the Department deny a change of accreditor, a wide definition of affiliated trade associations, a prohibition on institutional representatives serving on accreditor boards, and a provision making peer review optional. They further flag new requirements on accreditors that they say exceed the Department's statutory authority, and they ask for 60-day comment periods on future rules rather than 30.

Accreditation shapes how institutions collect, report, and use data, so the outcome matters for Institutional Research and Effectiveness (IR/IE) work. The full letter and the proposed rule are linked below.