Institutional Research, Accreditation, and the Next Reauthorization

Is accreditation support in your job description?  

The role of IR in accreditation was a frequent theme at the 2013 Forum in Long Beach. Nearly two dozen concurrent sessions focused on accreditation. Emphasis on the topic was further reinforced by the opening keynote speaker, Ralph Wolff, President of the Senior College Commission of the Western Association of Schools and Colleges. 

Ralph challenged AIR members to place ourselves front and center in every aspect of accreditation, especially in bringing meaning to higher education with effective storytelling that uses data. 

Commissioned research on the position descriptions of AIR members also highlighted the close connection we have to accreditation processes. Fred Lillibridge’s study Defining IR: Identifying Work Tasks, Describing the Field, and Establishing Baseline Comparisons revealed more than 200 IR tasks associated with accreditation. 

What’s the future of IR work in accreditation?  

Judith S. Eaton, President of the Council for Higher Education Accreditation (CHEA), recently presented her ideas in an essay about the next Higher Education Reauthorization Act. You can read the full text of her essay below, and share your thoughts and questions.  

Accreditation and the Next Reauthorization of the Higher Education Act
Judith S. Eaton
Inside Accreditation with the President of CHEA, Volume 9, Number 3, June 3, 2013 (reprinted with permission from CHEA)

With the U.S. House of Representatives initiating hearings in April 2013 and seeking comment on the Higher Education Act (HEA) by August 2013, we know that reauthorization is here. We are on a road to change, however long this may take. The accrediting community is entering this road with some concern and apprehension that the federal government has already established a strong role in academic decision-making, challenging peer review and diminishing self-regulation. Congress and the U.S. Department of Education (USDE) enter this highway with clear expectations of the role they want accreditation to play, equipped with significantly expanded tools for direct oversight of the accreditation process as well as colleges and universities.  

What will this reauthorization mean for traditional accreditation and its 60-year partnership with the federal government? Will this relationship, once characterized by deference to academic expertise in judging academic performance and public confidence in self-regulation and peer review, be coming to a close? Or will the reauthorization be an opportunity to reframe the accreditation-federal government relationship such that the ideals and value of accreditation can be sustained?lead1.JPG

The major features of the government's current expectations of accreditation and quality have been before us for some time. Quality is defined as compliance with federal law and regulation in relation to employment, graduation, consumer protection, transparency and affordability. Needed innovation in higher education requires government direction and assistance, including federal review of institutions even after accreditation review.

For quality in colleges and universities, the government is relying on tools such as Web-based interactive data sets, College Navigator and College Scorecard, that enable students and the public to compare admission requirements, tuition, available student aid, retention and graduation rates as well as employment after graduation. For the operation of accrediting organizations, USDE is relying not only on more expansive law and regulation, but also a Guide for Preparing/Reviewing Petitions and Compliance Reports.1 The 82-page Guide, initially developed in 2010, has come to function as a detailed checklist required of all accreditors, emphasizing compliance with federal regulation - rather than peer-based review - as needed to judge quality.

How We Got Here

The federal government has not always approached quality and accreditation in this fashion. The current perspective is grounded in a 2006 U.S. Secretary of Education's Commission on the Future of Higher Education report that was strongly critical of colleges, universities and nongovernmental accreditation. Accreditation was called upon to provide more robust public accountability, to strengthen the rigor and thoroughness of its reviews, take responsibility for what were characterized as higher education's limitations in serving students and serve lead2.JPGas a catalyst, not a barrier (as alleged in the report) to educational innovation.

Some of the commission's criticism became part of the foundation for the 2008 reauthorization of HEA. In the name of perceived inadequacies in accreditation, additions to the law included expanded federal oversight of academic areas such as transfer of credit, enrollment growth and distance learning, penetrating the arena of academic activity that had traditionally been the province of academic faculty.

Efforts to expand federal influence over accreditation accelerated as a new administration took office in 2009. Crucially, the 2009-2010 negotiated rulemaking (government consultation with constituents as part of establishing new or revised regulation) resulted in a federal definition of "credit hour," the fundamental building block of curricula, to be enforced by accreditors. This meant that faculty no longer have full responsibility for determining the credits associated with courses and programs. This action positioned the federal government to influence college and university curricula throughout higher education.

A 2012 report from the National Advisory Committee on Institutional Quality and Integrity (NACIQI), the group of academic, policy and public leaders assisting the U.S. Secretary of Education in making judgments about the federal recognition of accreditors, advanced two vital recommendations for action that further expanded the government's role. First, the report deemed quality assurance - not only quality - to be a federal interest. Second, the report viewed it as desirable at least to explore common standards across all accrediting organizations, especially for regional accreditation. The first action justifies the USDE role in directing the operation of accrediting organizations. The second action can establish a foundation for government judgment about academic quality based on the same national expectations for all colleges and universities.

With the convening of a new Congress and the annual State of the Union in 2013 came an unusual and notable mention of accreditation. The document accompanying the State of the Union was explicit, that if traditional accreditation could not meet expectations, then "a new, alternative system of accreditation" could be developed, presumably by the federal government. In April, the administrations proposed 2014 budget reinforced this view by calling for "quality validation systems run by independent parties" focused on college completion or "third-party validation systems that identify competencies, assessments and curricula for specific fields."

The last seven years, then, have left us with accrediting organizations subject to greater oversight and regulation, greater government engagement of academic issues, data sets that provide the opportunity for government judgment about quality and talk about alternative accreditation systems. We enter reauthorization with government now playing a more decisive role in making judgments and setting expectations of academic quality than at any time in the past.

Reauthorization Options

As of now, the most likely result of the next reauthorization is continued expansion of legislation and regulation that sustains government control. This means more direct government authority over the operation of accrediting organizations - their standards, policies and processes. It means the continued growth of federal review of individual institutions, in addition to accreditation. It means the federal government expanding its influence in the defining and judging of academic quality.

For institutions and accreditors troubled by this development, we need to make a compelling case for an alternative scenario: a streamlining of the current federal review of accrediting organizations, perhaps using the current federal interest in reducing regulation overall. This would include diminishing the extent and detail of oversight of accreditation and rethinking the distribution of responsibilities between accreditation and USDE such as oversight of student aid. This response would be an effort to re-establish the practice of "holding higher education and accreditation accountable for quality" that used to prevail between the federal government and accreditation and ending the prescriptiveness and granularity of current federal practice when it comes to accreditation and the quality of colleges and universities.

Beyond reacting to what is before us, institutions and accreditors also need to energetically make a powerful public case for the many accomplishments of the accreditation and academic communities in providing sustained, robust leadership for quality and appropriate accountability. The evidence is there but not adequately marshaled or deployed.

The academic and accreditation communities place enormous emphasis on student achievement, have focused intently on a completion agenda, are embracing innovation and have made huge strides in transparency and student protection. But we would not know this from reading opinion leaders in the education and general press. We would not know this listening to Congress and USDE. Perhaps this is because, at the same time, we affirm our commitment to intellectual development as well as economic development, just as we remain committed to the effectiveness and value of peer review, academic freedom and responsible institutional self-determination. While we accreditors and academicians understand that the combination of peer-based quality review and appropriate accountability provides the greatest benefit to students, we have yet to persuade significant others.

Alternatively, accreditors may decide "enough is enough" and depart the gatekeeping relationship with the federal government. Is this option realistic for accreditors of institutions? What would the end of the partnership mean for colleges and universities? Approximately half a dozen programmatic accreditors have done this over the past ten years. These organizations have determined that they do not need the federal partnership to serve students and society.

Finally, we need to anticipate yet additional steps that government may take. This might include the development of a federal accreditation system as briefly described in the State of the Union document and the 2014 budget, either alongside traditional accreditation or in its place. This system could involve primary emphasis on examination of institutional performance through, e.g., graduation rates, retention, transfer, employment and affordability, with student aid tied to performance. The tools presently available to government might expand to include (1) bright-line expectations of threshold institutional performance, (2) institutional reporting on performance and (3) triggers if performance does not meet bright line expectations. Federal review of institutional performance would augment or replace traditional accreditation focused on academic quality.

# # #

The reauthorizations of 1992 and 1998 had a powerful effect on colleges, universities and accreditation. The many changes that resulted did not, however, alter the fundamentals of the operation and aspirations of accreditation. The reauthorization initiated in April, building on 2008, may emerge as pivotal: This will be the reauthorization that determines whether and to what extent traditional accreditation is to be sustained.  

1 This review, known as "recognition," is required of all accrediting organizations that function as "gatekeepers" or reliable authorities on academic quality, providing access to federal funds. Recognition reviews must take place at least every five years.



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Total Comments: 11
Meg posted on 6/13/2013 8:35 AM
This is a must read. Dr. Eaton has done an excellent job at describing the current situation as well as how recent events have gotten us here.
Emily posted on 6/13/2013 8:57 AM
Thank you for all of the links to the original sources- it's extremely helpful!
Nancy posted on 6/13/2013 9:14 AM
Working at an institution that is just starting work on the Self-Study for accreditation, this is a very sobering article. I've passed this on to our administration to be sure that everyone really knows how high the stakes are today.
Marlene posted on 6/13/2013 9:42 AM
Very informative piece! Appreciate the insights on the upcoming reauthorization from an accreditation expert's viewpoint.
Sharron posted on 6/13/2013 11:16 AM
This article gives IR practitioners important contextual information for why attention to metrics has been -- and will continue to be -- so critical.
Teri posted on 6/13/2013 1:01 PM
Timely article, especially given that the House Education and the Workforce Subcommittee on Higher Education and Workforce Training held a hearing this morning on "Keeping College Within Reach: Discussing Program Quality through Accreditation". To view the archived webcast and witness testimony, go here:
Eric posted on 6/13/2013 2:09 PM
After serving in various types of IR related positions over the past decade at a public university, a private liberal arts college, and now a community college, it is clear that IR plays a foundational role in accreditation. Just yesterday I was contacted by one of the health programs with a request for assistance in their self-study for an upcoming professional accreditation report. Thank you for publishing this!
Terry posted on 6/13/2013 2:34 PM
Documenting quality is probably the most difficult task facing an institutional researcher. Quality doesn't strictly correlate with measurable. It's not a discrete data point. It's time for us in the IR field to start sharpening our qualitative analysis toolsets.
Bruce posted on 6/13/2013 5:25 PM
Best summary to date...and so hope it does more than spark a written conversation. Instead, may we have a strong professional cadre to carry us forward on all sides.
Evelina posted on 6/14/2013 9:41 AM
Excellent piece! I fully concur with Nancy's position - I also work at an institution just starting self-study and I am passing along this article to our administration. This is an excellent resource to keep us focused on the "big picture".
Jo posted on 6/14/2013 2:58 PM
This article presents the rationale for the importance of Institutional Researchers and Assessment professionals teaming together to frame and measure student learning successes. Higher education has not done an adequate job in presenting evidence of student learning on all levels; of telling our stories. We are now positioned to explain or defend student learning success based on a very limited set of predictors such as first-time, full-time freshmen student retention and completion measures. For elite institutions these metrics report very favorably, for all other institutions there is a gap that alludes to institutional ineffectiveness. Expanding the paradigm of measuring student learning and leveraging these metrics against external expectations for student achievements is necessary to reaching consensus on the quality of education which is occurring across the many venues of postsecondary education. Institutional researchers teaming with assessment professionals have the potential to play a crucial role in expanding the frameworks whereby success is currently being measured. I find that often there is so much potential for combining knowlege and evidence supporting student learning which is left uncultivated. Yes, higher education institutions have a responsibity to insure that we are fulfilling our missions; and we have a responsibility to all stakeholders. There must be genuine conversations between those who seek to govern and those who operationalize the educational processes. We must move beyond arguments posturing academic freedom versus governmental controls...the conversations should include intentionality and genuine thoughts about cultivating student learning in the 21st century.