An Analysis of Higher Education Accreditation. Part 1: Evaluating Accreditation’s Performance

Accreditation in higher education originated as a means of communicating useful information about the quality of various institutions of higher education. Yet, over the past half century accreditation has evolved into a system for determining eligibility for the receipt of funds from third parties, most notably the federal government, but also in many cases state governments or private philanthropies.

If the nation were starting afresh on accreditation, we predict it would devise a radically different system than the one it has become over the past century. Would we have multiple regional accrediting agencies? We doubt it. Would the accreditors be private entities largely controlled by individuals themselves affiliated with the institutions that they certify? We doubt it. Would accreditation largely be “an-all-ornothing” proposition, where institutions are simply “accredited” or “non-accredited” with few distinctions in between? We doubt it. Would an accrediting mechanism be permitted where key elements of the assessment are not available for public review? We doubt it. Would accrediting that sometimes emphasizes inputs rather than outcomes be permitted? Again, we doubt it. In short, there are numerous characteristics of today’s system of accreditation that are subject to questioning and criticism.

Americans spend vast amounts of money buying houses, cars, and major appliances—yet none of these things are “accredited.” We have developed other means of providing information. For example, Consumer Reports, J.D. Powers and Associates, and Underwriters Laboratories all give consumers information and the products they are purchasing, and private home inspections by disinterested third parties help assure that real estate transactions truly represent what buyers and sellers expect. Why, then, do we “accredit” colleges and universities? There are legitimate reasons, but the presumption that current methods are optimal is misplaced.

The typical policy paper on accreditation does a fine job of detailing the history of the system and major issues that confront it today. It then usually concludes by sketching out some recommended reform. However, while it may point out a few areas in which the proposed reform would be an improvement over the current system, there is rarely any discussion about how such a reform is better than the alternatives, or what impact it would have in other areas.

This paper takes a slightly different approach. While throughout we do discuss some of the historical role of accreditation, our main focus is on evaluating the performance of the current system and evaluating possible reforms. Thus, it is suggested that readers have some prior familiarity with the history and practices of accreditation.

Part one presents our analysis of accreditation’s performance. Because its role and function in higher education has changed over time, we find it worthwhile to discuss the history of accreditation very briefly. We identify four eras of accreditation in order to assess both its effectiveness and its changing role over time. To facilitate our analysis, we have devised a rubric with which to evaluate accreditation and reform proposals. The first column lists the main categories that we feel the accreditation system should be evaluated upon, including quality improvement, quality assurance, and promoting the health and efficiency of the higher education system. The second column breaks some of these categories into more refined areas. Using this approach focuses the evaluation of the current system as well as proposed reforms on all of the most important dimensions and demonstrates how public policies addressing one issue can create or exacerbate problems in others. The scorecard also provides an abridged and illustrative summary of our analysis.

EVALUATING ACCREDITATION
A RUBRIC FOR EVALUATING ACCREDITATION

Part two of the paper identifies the most commonly suggested reforms of, and replacements for, accreditation. We analyze the likely impact of each reform, and briefly discuss whether it would be appropriate given the goals as have been discussed. The third part of the paper builds off the conclusions of the first two parts to make the case for replacing the accreditation system. The final part lays out our recommendations.

Part 1: Evaluating Accreditation’s Performance

The Four Eras of Accreditation

While we will not provide a comprehensive history, the structure of accreditation “is more historical than logical,”1 resulting in a series of “accidental transformation[s]”2 as more and more responsibilities have been placed upon it. As Robert C. Dickeson notes, accreditation today is like an overloaded “pack animal” that “has been burdened with expectations and duties far beyond either its design or its capabilities.”3 It is therefore necessary to quickly recap some of the highlights of the history behind accreditation. We’ve identified four main eras of accreditation: pre-1936, 1936 to 1952, 1952 to 1985, and post-1985. Although there is some ambiguity concerning the exact dates of the four eras, the dates generally correspond with the time in which accreditation took on a major new role.

Pre-1936: A Voluntary System to Inform the Public. Accreditation developed from a need in the late 19th century to define what a college-level education was and to distinguish institutions that possessed adequate capabilities for undertaking such studies. Prior to its development, there was no generally accepted criteria for what should be considered a college. Furthermore, there was widespread unfamiliarity with educational institutions beyond one’s own small geographic area. This lack of information combined to make it difficult for the better institutions to distinguish themselves and difficult for students to decide which institution to attend.

The better colleges thus formed regional, voluntary membership associations and established common definitions and admissions processes. In the early 20th century, these regional associations began to establish institutional standards, such as faculty size, length of educational programs, library size, and size of endowments which aspiring colleges were required to meet in order to gain accreditation. Accreditation decisions were based on information provided by the institutions themselves, a process that for the most part continues today. Accreditation soon became a marketable asset as a means of distinguishing colleges from the competition and provided a signal to the public that an institution was of high quality. This provided an incentive for colleges to voluntarily seek accreditation and for accreditors to maintain high standards.

This system would remain intact for the post-secondary education market throughout much of the 1930s as accreditation expanded its reach while the government continued to remain largely uninvolved in the sector. However, criticism of the accreditation process would begin to surface around this time as college officials began to complain that the quantitative, uniform standards used in accreditation were too rigid and superficial. Some critics said that the data gathered for accreditation decisions, while measurable, did not account for the diversity of institutions and their missions, placing too much emphasis on resource inputs and not enough on outputs. Many institutions believed that despite providing a high quality education to their students they were denied voluntary accreditation because, on paper, they did not measure up to these quantitative standards.

1936 to 1952: A Quality Improvement Role Is Added. Amidst growing criticism, one of the regional accreditors, the North Central Association (NCA), commissioned a report in 1936 that concluded that accreditation ought to be awarded based on a school’s “total pattern [presented] as an institution of higher education” and its ability to meet its stated educational mission.11 Following the report, NCA developed a qualitative approach that judged schools by their own institutional purposes, allowing for an institution that was deficient in one area, but with offsetting strengths in another, to still receive accreditation. The other regional associations soon followed suit in developing qualitative mission-specific accreditation evaluations which would eventually evolve into the self-study that remains the dominant process used for accreditation to this day.

By 1945, the North Central Association’s rhetoric had shifted from that of assuring high quality to that of “providing service” to its member institutions.13 During this time, accreditation increasingly sought to accomplish continued improvement in higher education rather than the rigid enforcement of universal standards.14 In doing so, a new mission for accreditation was added: In addition to sorting colleges by quality as before, it was now also supposed to help institutions improve.

1952 to 1985: A Quality Assurance Role Is Added. During the Second World War, Congress passed the original GI Bill in 1944, which provided veterans with financial assistance to pursue a college education at an institution of their choice, with the only limitation being that the institution be approved by its state education agency. As a result, very few restrictions were placed on where the veterans could spend the money, and there were reports of widespread abuse, resulting in heightened concern that too much of the money went to diploma mills that did not provide an adequate education. This led to a series of government investigations and Congressional hearings that, when the next GI Bill came about (the 1952 Korean War GI Bill), intensified the desire for an enhanced quality control mechanism to determine institutional eligibility.

This created something of a dilemma. While it was agreed that more quality control was needed, many in Congress and academia believed that the laissez faire attitude the government had historically taken towards higher education was wise, and that direct involvement by the government in determining institutional eligibility would jeopardize this traditional source of strength. A compromise was reached where the government would rely on the private accreditors to determine institutional eligibility. The 1952 bill required the Commissioner of Education, Earl McGrath, to “publish a list of nationally recognized accrediting agencies and associations he determines to be reliable authority as to the quality of training offered by an educational institution.” McGrath named the six current regional accreditation agencies to fulfill this quality control mechanism.

In addition to their prior roles, accreditation was now tasked with a quality assurance role as well. This marked the beginning of accreditation’s partnership with the federal government in monitoring institutional quality, with the accreditors acting as the gatekeepers to federal funds. It was during this time that accreditation as we know it today began to take shape.“Between 1950 and 1965, the regional accrediting organizations developed and adopted what are considered today’s fundamentals in the accreditation process: a missionbased approach, standards, a self-study prepared by the institution, a visit by a team of peers who produced a report, and a decision by a commission overseeing a process of periodic review.”

Although the GI Bill established the quality assurance role for accreditation, the amount of federal funding for veterans was relatively modest by today’s standards, and temporary in nature. As a result, accreditation, while more attractive for colleges, was not entirely necessary to remain competitive. But with the passage of the 1965 Higher Education Act (HEA), accreditation would become a near necessity. For the first time, the federal government was establishing massive and permanent funding for higher education, and any school that wanted access to those funds had to be approved by the new gatekeepers: the accreditors. 

The massive and permanent expansion of federal funding would significantly change the dynamics of higher education. The federal government’s involvement in financing higher education created an incentive to try and “game” the system by establishing substandard colleges, since once a college becomes accredited, federal money would continue to flow in year after year. Some colleges started to succeed in gaming the system, a task made easier by the fact that the accrediting agencies continued to see their primary role not as certifying quality for the public, but as helping the institutions improve. The associated scandals, especially high student loan default rates, would help give rise to the accountability movement in the mid 1980s.

Post-1985: The Rise of the Accountability and Assessment Movement. Concerns about the apparent decline in the quality of education, in addition to rising student loan default rates and a growing number of allegations of fraud and abuse of the federal financial aid programs gave rise to the accountability and assessment movement. While accountability and assessment as concepts relating to higher education have been around for a long time, Peter T. Ewell dates their emergence as a serious public policy consideration to around 1985. This movement would produce new government initiatives aimed at both colleges and the accreditors which were designed to better protect the public’s investment in higher education.

A few voluntary changes by accreditors did not alleviate political pressure to eliminate instances of abuse and reign in growing default rates, failures that Congress at least partially attributed to accreditation. There was some consideration of severing the tie between accreditation and federal financial aid in light of the perceived failure of accreditation, but rather than taking this action, Congress responded with the 1992 HEA reauthorization that created new regulations for colleges and accreditors. There were limitations placed on distance learning, the maximum percentage of a college’s budget that could come from federal aid, and new quality assurance responsibilities for the accreditors, such as student learning assessment requirements.

To many observers, the regulations have proven largely ineffective in preventing fraud and waste of federal funding, with the for-profit sector receiving considerable criticism. At the same time, the accreditors have resisted attempts to make quality assurance their primary function, instead preferring to focus on institutional improvement.

This is where things stand today. The federal government views accreditation as a mechanism to provide quality assurance as a safeguard for its financial aid funding. The accreditation community has declared that its primary purpose is to promote continuous quality improvement. College officials have mixed feelings about accreditation, with some viewing it as a burden that offers little bang for the buck, while others view it as a helpful process that provides outsiders’ perspectives. Meanwhile, the public has grown increasingly critical of higher education and, to the extent that it is even aware it exists, of the accreditation community.

Quality Improvement

Helping academic institutions to continually improve was the first major function added to accreditation, and arguably remains its focus today. Traditional quality improvement tasks associated with accreditation include assisting in the setting of reasonable goals and strategies, helping establish evaluation systems, providing an outside perspective and providing constructive criticism.

The decentralized nature of accreditation, combined with a lack of transparency, makes it difficult to evaluate the system’s success in accomplishing its quality improvement goals. Nevertheless, it is possible to reach reasonable conclusions about the system’s performance over the years.

The quality improvement function is not applicable in the pre-1936 era. During this time, accreditation existed essentially only to distinguish colleges by quality, and the quality improvement role had not yet emerged as a major focus. After 1936, accreditors increasingly introduced and focused on the quality improvement function. While it is difficult to say with certainty, there is reason to believe that accreditation was largely successful along this dimension in the 1936 to 1952 era. Because the system was still entirely voluntary, the accrediting agencies were presumably providing sufficient benefits in terms of quality improvement to justify the costs to the member colleges.22 If they were not, rational college leaders would not have opted to expend the time and resources needed to gain and retain accreditation. Thus, prior to 1952, we are inclined to agree with Mills that there was “little question that accreditation…was valuable in the early years of [the twentieth] century” in terms of improving educational quality.

This reasoning is rendered moot for the later eras, as the accreditors were assigned the gatekeeper function in 1952, and especially once federal money for financial aid dramatically increased in 1965. Whereas in earlier years colleges would only take part in accreditation if the benefits (e.g. signaling quality and/or helping the institution) outweighed the costs, accreditation was now viewed as a near necessity, regardless of its benefits in these dimensions.

Nevertheless, it appears that accreditation continued to perform satisfactorily as a quality improvement mechanism in the 1952 to 1985 era. This is evident because accreditors were given remarkable freedom of action within their new gatekeeper role, and for the most part, they choose to ignore their new role and continue to focus on the improvement role, though some during this period argued quite vocally that accreditation did not facilitate the “pursuit of excellence” by institutions.

The rise of the accountability and assessment movement in the most recent era has resulted in accreditors coming under increasing pressure to emphasize their public accountability role. This has increasingly led to the development and enforcement of standards that emphasize compliance over consultation. One accreditor lamented the fact that many of those serving on committees have “imbedded in their minds the idea of accreditation as a compliance mechanism.” In our opinion, this has put considerable downward pressure on the performance of accreditors in the quality improvement role, though as noted before, it is difficult to evaluate how well accreditation actually performs due to the secrecy of the enterprise.

A decent argument can be made that accreditation is still successful in the quality improvement role. Some “college and university presidents identify accreditation as the key moving force behind strategic planning.” In addition, accreditation “provides an occasion for institutions and programs to engage in a sustained and serious process of self-examination,” with a CHEA survey indicated that 73% of those surveyed viewed “the opportunity to examine institutions and programs through self-study” as a benefit of accreditation, and that 53% viewed “gaining external feedback on performance that can be used for improvement” as a significant benefit.

However, a compelling case can be made that accreditation is not as successful in fostering quality improvement as it may have once been. This case rests on two main pieces of evidence.

The first is the numerous statements and actions by college administrators expressing the view that accreditation adds “little value to higher education.” “While accreditors view the accreditation process as an ‘investment,’ institutions often view it as a significant cost with little return on investment.” Some college leaders view the newfound compliance mentality as obstructing the improvement role. For instance some college administrators “often question an accrediting agency’s understanding of the specific circumstances at an institution or the depth of the agency’s commitment to the institution’s own goals.”

Overall, “many college officials believe they get little out of the standard process besides a stamp of approval. Administrators may spend years on a self-study to show that the college has met minimum requirements, only to see the document begin gathering dust within months of completion.” As Paula Lutomirski explained, “we produced this two-inch-thick document, and I don’t even have it on my shelf, because it’s not worth having.” This view is shared by many: “Former Rhodes College President James Daughdrill summed up the view of many college administrators when he said that accreditation is ‘an exercise in wasted time and money.’”

When given the opportunity to act on these views, college administrators do not hesitate to follow through. If an institution already has regional accreditation, while state licensing requirements do not require a specialized accreditation, some universities choose to forgo the latter. For example, some of the best teacher education programs “tend not to pursue NCATE accreditation at all.”

The actions of accreditors themselves serve as the second, and even more compelling, piece of evidence. A number of reforms that focus on enhancing quality improvement of accreditation have been initiated by accreditors in recent years. If the accreditation system was already performing its function well, there would be no reason for these reforms to be pursued.

For example, Sylvia Manning, the head of the largest regional accreditor, observed that “the compliance role is so onerous and so dominates the process that, in too many cases, colleges fail to get anything meaningful out of the improvement portion.” Similarly, Ralph Wolff, the head of the accreditor overseeing the Western states, wrote of a “developing sense on the part of institutions, especially the larger comprehensive ones, that all the investment in the accrediting process resulted in very little return on that investment or meaningful change. It became too often a time- and resource-consuming exercise to see if minimum standards were being met, and it had little lasting value.”

To their credit, both of the accrediting organizations mentioned above have been experimenting with new processes that seek to “separate ‘compliance’ from ‘improvement,’” with generally positive results. As UCLA’s Chand R. Viswanathan stated, “I had gone through accreditation previous times, and all you do is count the number of courses and what kind of requirements they satisfy… all these things are already worked out in an ongoing institution’… The new process, he says, focused on U.C.L.A. officials’ real concerns ‘and helped them reach their goals faster.’”

While some griping about the regulator by the regulated is to be expected, the loudly repeated statements about problems, as well as the actions that accreditors are taking to fix perceived weaknesses lead us to the conclusion that accreditation is doing an unsatisfactory job in the quality improvement dimension in the latest era. Again, that conclusion is tempered by the reality that much of the process of accreditation remains hidden. For an exercise in providing information, accreditation is mired in excessive secrecy and lack of transparency.

Evaluation: Quality Improvement. Prior to 1936, accreditation played no role in the quality improvement function for higher education. Starting around 1936, accreditation adopted a mission-based approach that began focusing on quality improvement. As this was prior to the involvement of any federal financing of higher education, submitting to accreditation remained a voluntary act on the part of the colleges. Given that accreditation continued to grow, we suspect that its performance in the quality improvement role was satisfactory in the years between 1936 and 1952. Even after the federal government took up a more active roll in providing student aid in 1952, accreditation seemed to continue to perform its quality improvement function satisfactorily for a number of years. Finally, when allegations of federal financial aid abuse and waste became widespread in the late 1970s and early 1980s, the government increased pressure on the accreditors to provide public accountability. Given the current views and actions of colleges and accreditors, we believe that one of the consequences of this pressure was to shift accreditors’ concerns from consultation to compliance, and that this harmed their quality improvement performance. We therefore conclude that accreditation’s performance in quality improvement has become unsatisfactory in the latest era.

HISTORICAL PERFORMANCE IN THE QUALITY IMPROVEMENT CATEGORY
HISTORICAL PERFORMANCE IN THE QUALITY IMPROVEMENT CATEGORY

Quality Assurance

For the last six decades, accreditation has been tasked with providing public accountability for federal spending on higher education. Federal aid has grown remarkably over the years, rising from $1.7 billion in 1963-64 to $116.8 billion in 2008–09 (in constant 2008 dollars), a real increase of 10 percent per year.40 By providing a quality assurance function, accreditation is supposed to protect society from wasteful spending on fraudulent educational programs.

Defining appropriate measures of quality and certifying that colleges have met some minimum standard of quality are necessary (but not necessarily sufficient) conditions for any system that hopes to reliably provide quality assurance. In addition, while it is theoretically possible to hold colleges accountable for their spending of public money without revealing much information to the public or policy makers, it is much more likely that a system with transparent processes and public reporting of results would be more effective in this regard.

Define (Appropriate) Measures of Quality

The determination of reasonable measures of quality is a minimal requirement of any system hoping to provide a quality assurance role. In keeping with the stated rationale of providing a public accountability mechanism, these measures should be related to what it is that public money is funding.

Prior to 1952, there was considerably less public money involved, so accreditors did not have a role in public accountability per se. Thus, this category is largely not applicable to accreditation in the earliest era. This is not to say that accreditors of this era did not define standards, but merely that they were not defined with public accountability needs in mind. It is also useful to note that of the standards that were adopted, the vast majority were quantitative measures of inputs and financial resources, with a few standards pertaining to degree requirements or outcomes. Since the accreditors of that era were mostly concerned with distinguishing among classes of institutions, these were useful measures. Colleges that could afford vast libraries, credentialed teachers, etc. were quite different from those that could not.

Once accreditation assumed the gatekeeper function in 1952, this criterion became very important in ensuring public accountability. The methods used were developed ad hoc, and for the most part, the accreditors reverted to a reliance on measures of inputs. To get accredited one basically had to mimic other colleges in terms of input usage. While it was perhaps understandable for the accrediting agencies to adopt superficial standards initially, when public funding was both limited and temporary, the new federal funding initiatives of the 1960s required much improved oversight. However, the accrediting agencies failed to deliver.

The main reason for this failure is that the system relies too heavily on colleges to self-regulate. For example 83% of the board for Middle States Commission on Higher Education is comprised of people that work for institutions that they then accredit. Similar numbers are just as pervasive in the other regional accreditors. The mere fact that accreditors were given the public accountability role didn’t change the fact that accrediting agencies were started by colleges to serve their own interests. One might even view accreditation as a “cartel” made up of various participants with the goal of restricting competition from non-members of the cartel. Ultimately, it’s not surprising that “a system that is created, maintained, paid for and governed by institutions is necessarily more likely to look out for institutional interests.” One of the ways in which they do so is by keeping standards low: “when the people who decide what constitutes academic quality will themselves be judged on academic quality, it’s no wonder that the bar is set low.”

It is undeniable that over the years, the accreditors have adopted some measures of quality; however, they have too often adopted inappropriate, and in some cases counterproductive, measures. There are two main problems with the accreditors’ measures.

First, many of their measures focus on the wrong things. Accreditation is obsessed with inputs. “For decades, universities and colleges have wanted to define academic quality in terms of resources: faculty scholarship and degrees, the depth and breadth of curricular offerings, and the presence of topflight laboratory, library, and like facilities,” and accreditors have been the willing enforcers of this desire. As Malcolm Gillis, president of Rice University lamented, ‘’the accreditors are not interested in what or how the students learn, but how many square feet of classroom space we have per student.’’ In addition, accreditors have from time to time imposed standards for non educational matters, such as course loads, professor salaries, and diversity. It should go without saying that just because a university spends enough money on libraries or research, or has “low enough” teaching loads does not guarantee that it is providing an education worth the public’s (or even the student’s personal) investment.

The second problem with the accreditors’ measures is one of omission. Measures simply do not exist for crucially important aspects of higher education. There is a complete lack of standards for fundamentally important aspects of higher education such as student learning and outcomes for graduates. There is “a growing consensus on the need to measure student learning. This requires defining what students should know and be able to do and providing evidence that this has been accomplished.” But “the regional accrediting commissions have historically refused to define minimum standards… The Regionals currently have no mechanism for assuring adherence to minimum threshold standards across the institutions they accredit.” As one faculty member observed,“we are so wedded to a definition of quality based on resources that we find it extremely difficult to deal with the results of our work, namely student learning.

Since 1992, accreditors have been required to collect evidence of student learning, but the college lobby has ensured that these are self designed assessments. Thus we are left in the peculiar position in which the “standards for accreditation, which vary by region, are based on an institution’s self-study of the extent to which the institution feels it has met its own purposes.” Needless to say, the government is not satisfied with this outcome. The Spellings’ Commission on the Future of Higher Education was highly critical of the system’s failure to provide “solid evidence, comparable across institutions, of how much students learn in colleges or whether they learn more at one college or another.” Even accreditors find this state of affairs unsatisfactory, with one accreditor complaining that “even though a focus on student learning assessment and outcomes needed to become more of a priority for us and institutions, we found that the ones we reviewed were repeatedly ‘just getting started.’” The lack of progress in this area is compelling evidence in favor of a fundamental restructuring of accreditation.

Gaining accreditation today is remarkably similar to gaining accreditation a century ago. While the list of inputs measured has changed somewhat due to technological and social developments, the core issue is essentially the same: is enough money being spent on a given list of inputs? The failure of this approach should be apparent if we acknowledge that the federal government is not providing in excess of $117 billion per year to American colleges just so we can make sure that libraries are big enough and that college professors have Ph.D’s. The government—as well as the taxpayers it represents—expects to see a return on its investment in the form of substantial gains in knowledge and proficiency in a student’s field of study.

The rationale for public funding of American higher education hinges on the promotion of economic growth and equality of opportunity, the enhancement of graduates’ job prospects and life satisfaction, and a belief that higher education leads to a more politically and culturally engaged citizenry. The existing processes that determine whether an institution is accredited and eligible for federal aid are inadequate at measuring an institution’s effect on any of these purported rationales.

Continuing to measure only the inputs used and processes followed by colleges does nothing to gauge the value added knowledge their students acquire or the post graduate success they achieve, and therefore cannot help provide meaningful public accountability. Thus, the accreditors have utterly failed to define appropriate measures of quality in both the 1952 to 1985 and the post-1985 eras.

Evaluation: Define (Appropriate) Measures of Quality. Prior to the federal government’s involvement in financing higher education, accreditation’s idea of setting measures of quality was essentially based on a set of inputs and a few processes. Although this helped to distinguish the haves from the have-nots in higher education, it did not serve a public accountability function, nor was it intended to do so. This criterion is therefore not applicable in the first two eras of accreditation.

However, accreditation became intertwined with federal aid beginning with the 1952 GI Bill, and it has continued to use similar standards, which have very little to do with student learning or outcomes. The accountability and assessment movements that began in 1985 have done very little thus far in motivating accreditors to define appropriate measures, including those to assess student learning, despite regulation pushing them in that direction. We therefore believe that accreditation has failed in the task of defining appropriate measures of quality for both the 1952 to 1985, and post-1985 eras.

Certify Minimum Quality

From a public policy perspective, “the overriding public interest in accreditation over the last 50 years has been defined in terms of protecting consumers as well as federal and state student grant and loan programs from flagrant fraud and abuse.” In other words, accreditation is supposed to protect the country from funneling money to diploma mills, or at the very least, accreditation includes “the process of determining the degree of quality which separates the acceptable from the ‘not quite acceptable.’”

By giving the accrediting agencies a gatekeeper role in determining institutional eligibility for federal funds, a system accustomed to sorting colleges and helping them improve “inherited functions sometimes beyond its scope and expertise.” The system nevertheless worked adequately at first, since there was a relatively small amount of federal money involved and the temporary nature of that money mitigated attempts to game the system. The lack of sustained federal funding, as well as the input standards that many diploma mills couldn’t afford, combined to allow the accreditation system prior to 1965 to do a fairly good job in marginalizing diploma mills. It should be emphasized that it was not that the standards set by the accreditors were well suited to ensuring a minimum quality for education, but rather that the input standards were often prohibitively costly for diploma mills (or any new college for that matter) to acquire since federal funding was limited and temporary.

But between 1965 and 1985, the certification role of accreditation saw deterioration relative to past performance. Federal monies were massive and permanent, giving diploma mills an incentive to enter the sector. Moreover, “rather than focusing on quality assurance for the public, which was what Congress intended, accreditors in fact view themselves as promoting institutional improvement, a role that the voluntary system initially fulfilled.” In spite of their new role as gatekeepers of federal funding, “accreditors do not think of their primarily role as federal agents.” As James T. Rogers, former executive director of one of the accrediting agencies said, “We’ve never liked to view what we’ve been doing as being regulators.” This was problematic, since they were the primary regulators of higher education.

Needless to say, since accreditors would “rather be advisers than policemen,” they have largely ignored their role in certifying a minimum quality. One former president of Brown University noted as early as 1960 that the “accrediting procedure does not protect us from wretched and fraudulent institutions.” Accreditors “do not endeavor to assess the quality of individual programs or departments... If the accreditation system does not even attempt to examine the educational quality of individual programs, what ground is there for assuming the ‘general quality’ of the institution?”

While there were obviously problems providing certification, we would argue that accreditation still deserved an unsatisfactory rating (rather than outright failure) on this measure in the 1952–1985 era due to its success (with help from direct government regulation) in marginalizing diploma mills in the earlier years. But the certification role of accreditors has deteriorated in the current era. Many observers complain that “accreditors have vague, widely varying standards and are reluctant to crack down on weak colleges.” This reluctance is largely due to the fact that eligibility for federal student aid is conditioned upon being accredited, so removal of accreditation would likely result in the death of the institution. Accreditors are so reluctant to take this step that “one looks in vain for instances where accreditation has been denied because of low educational value to students… Colleges and universities simply do not lose their accreditation because of a judgment by the accreditors that the curriculum is weak, the faculty poor and the students don’t learn much.” This reticence towards revoking accreditation has existed for more than fifty years.

To get a sense for how reluctant accreditors are to act, note that between 2003 and 2008, the percentage of community colleges being “sanctioned, or warned that their accreditation could be stripped, ranged from 0 to 6 percent,” and that “only one two-year institution [in California], Compton Community College, has ever lost its accreditation.”

Indeed, “On the rare occasion that accreditors do suspend or terminate an institution’s accreditation, it isn’t due primarily to educational concerns. Typically, institutions are sanctioned because of financial shortcomings,” as was the case with Southeastern University.64 Southeastern remained an accredited university for over two decades despite “perpetual dysfunction” and being “mired in obscurity, mediocrity, cronyism, and intermittent corruption.” As Kevin Carey put it,“Accreditation had come to mean evaluating yourself against standards of your own choosing in order to indirectly receive large amounts of free government money.” The result of which is “chronic failure at hundreds of colleges nationwide, obscure and nonselective institutions where low-income and minority students are more likely to end up with backbreaking student-loan debt than a college degree.” Southeastern finally lost accreditation in 2009, not for failing to educate its students, but for financial insolvency. However, for years the accreditors were reluctant to withdraw qualification and thereby deny student aid, since the university desperately needed the flow of cash to survive as an institution. Because nearly everything concerning accreditation is kept so secret, it is impossible to tell how many more Southeasterns are out there, how much federal financial aid money they are wasting, and how many students are victims of academic fraud. It is possible that Compton Community College was the only California community college to do an inadequate job educating its students, and that less than 6 percent of all community colleges are in danger of doing so. But this is unlikely, especially when one notes the constant warnings about the dangers of underfunding combined with the conventional wisdom that the sector has been underfunded year after year.

While accreditation is rarely denied or revoked for educational reasons, there are institutions that are denied accreditation, so we know that the accreditors are providing certification of something. Unfortunately, that “something” has little relation to the quality of education provided. For instance, a 2006 study by the former president of Teacher’s College at Columbia University concludes that accreditation has failed to provide even a minimum standard for quality of education programs, and even those standards which accreditors have set up to measure quality are “misplaced and outdated,” allowing programs with low quality to receive their stamp of approval. As Leef and Burris document, “The accreditation system is not based on an evaluation of the results of an institution, but rather upon an evaluation of its inputs and processes. If the inputs and processes look good, acceptable educational quality is assumed. It is as if an organization decided which automobiles would be allowed to be sold by checking to make sure that each car model had tires, doors, an engine and so forth and had been assembled by workers with proper training— but without actually driving any cars.”

The failure of accreditation to perform the certification function is increasingly apparent. In fact, the more experience one has with higher education, the less likely one is to believe that accreditation ensures meaningful educational standards. Respondents to the CHEA survey mentioned previously “who had attended college were more likely to think that educational programs must meet only minimal standards to be accredited… Those who had earned a degree were even more likely to believe that only minimal standards need be met.”

Evaluation: Certify Minimum Quality. As with the definition of appropriate measures of college quality, the certification of minimum quality was not a function of accreditation prior to 1952. Again, it was the emergence of federal funding for higher education, and the reliance upon accreditors to function as gatekeepers that changed this. While accreditation has never been designed to perform this role adequately, it nevertheless did a satisfactory job for the first decade or so of the third era. The numerous requirements for costly inputs were fairly effective in deterring diploma mills from entering the field in a time of modest and temporary federal funding. Once federal funding became permanent and massive, however, diploma mills had an incentive to game the system, and were able to do so because the accreditors continued to ignore their public accountability responsibilities and focus on the improvement role instead. We therefore rate their deteriorating performance from unsatisfactory in the era of 1952–1985 to outright failure in the current era.

Inform the Public

Another important public function of accreditation is to provide information on colleges to the public and policy makers as well as current and prospective students. There are two primary concerns in regard to public information. The first addresses whether colleges are sorted by quality (however defined) in such a way as to provide useful information. The second arose with federal funding, and asks whether the process itself is transparent enough to instill confidence in the decisions of the accreditors.

Prior to the establishment of federal financial aid programs, accreditation was completely voluntary. Because it was not universal, having accreditation meant something. Those institutions that were accredited by reputable accreditors stood out as better than those that were not (or were accredited by a lesser accrediting body). This provided useful information for students, as it served as a signaling device and functioned as an early ranking of colleges. And because accreditation was largely a private affair, transparency was not really an issue in this period. Thus, in the earlier two eras, we conclude that accreditation did a satisfactory job of providing the public with information on college quality.

Once the federal financial aid programs became established fixtures of the educational landscape, however, accreditation’s performance deteriorated. The primary reason is that because accreditation is now so important to an institution’s financial survival, it has become near universal. In other words, “Once a badge of distinction, accreditation has now become so commonplace as to be of negligible benefit to either educational consumers or the institutions themselves.” For example, Harvard has the same accreditor as Central Connecticut State University, though one suspects that there is a large difference between those two schools (as suggested by the more prominent college rankings guides which consistently place Harvard near or at the top but do not even rank Central Connecticut State). Indeed, it is impossible to avoid the conclusion that “if students and parents were interested in trying to learn all they could about a college or university they are considering, the accreditation system is of little assistance to them.”

Increased federal funding also came with the new “expectation that accreditors should provide the public with information.” Accreditation has always been a rather private affair, and that hasn’t changed. What did change was that accreditors were given a public role as gatekeepers, and for the public to have confidence in the process there needs to be transparency. But the accreditors did not adapt to this new function, and largely insist on keeping nearly everything concerning accreditation secret.

The primary reason that accreditors resist transparency is that they are focused on the quality improvement role. In order to be effective in the quality improvement role, “accreditation has been designed to provide candid, confidential, critical feedback to institutions without embarrassing or endangering the institution—which would in turn discourage frank engagement with problems and challenges.” In other words, accreditors promise discretion to colleges in order to get the candid self-assessment necessary to improve these institutions. If accreditors were more transparent, it would create “a disincentive for colleges to speak openly with accreditors about their problems.”

Accreditors see little point in providing information to the public since they view their role as helping institutions improve regardless of their current condition. To the extent that informing the public makes institutions less candid, there is even more reason to resist transparency. As a result, virtually everything about accreditation continues to be shrouded in a veil of secrecy. Accreditation reports are kept secret, and the only information available to the public is whether the institution has or does not have accreditation. In the words of Milton Greenberg, “It is essentially a confidential process, which hides an institution’s advantages and disadvantages.” Even once an institution has ceased to exist, accreditors still refuse to disclose any information about it. We therefore conclude that accreditation’s performance in this category has deteriorated relative to its past performance, and believe that it has failed in the latter two eras.

Evaluation: Inform the Public. Providing information to the public is the category within the quality assurance function where accreditation has historically been strongest. While the process was not transparent, it nevertheless provided useful information, leading us to conclude that accreditation did a satisfactory job in the pre-1936 era. In the era from 1936 to 1952, accreditors became increasingly focused on the quality improvement role, which required discretion and secrecy so as to avoid embarrassing member colleges. While this would be a problem later on, accreditation was still a voluntary private affair, and still provided some useful information to the public. Therefore, accreditation was serving social purposes in a reasonably satisfactory fashion. Once accreditors were given the gatekeeper role for federal funding, virtually every institution in operation needed to have accreditation. This near universality erased the information on college quality that used to be provided by accreditation, while the focus on improvement ensured that the system was clouded in secrecy. Indeed, it is usually impossible for the public to discern whether real improvement occurs at all. We consider the accreditation system as largely a failure in this regard, since it neither provides useful information to the public, nor is transparent enough to give us confidence in accreditation decisions.

Promote the Health and Efficiency of Higher Education

While pursuing the quality improvement and quality assurance functions, it is desirable that the accreditation regime does not undermine higher education’s overall health and efficiency. It is of the utmost importance to preserve higher education’s historical sources of strength, including institutional autonomy and a wide diversity of institutional missions and practices. One of the strengths of American higher education, relative to the rest of the world, is precisely the large amount of real choices consumers have as to what institutions to attend. Similarly, research activity is no doubt enhanced by the diversity of centers for exploring problems, often leading to more creativity than is present in monolithic systems under one set of controls. 

It is also important that the efficiency of the sector not be undermined. Future progress depends upon fostering innovation, so it is important that accreditation does not suppress innovation by existing institutions, nor act as a barrier to entry for new ones. It is also important to not unnecessarily increase costs.

Preserve Historical Strengths

Maintain Independence/Autonomy of Colleges

One of the main reasons that American higher education is the envy of the world is that it has been free of governmental and political interference to a larger extent than the higher education sectors in other countries or even the K-12 education sector in this country. The importance of autonomy for institutions of higher education has been established in theory and verified by experience, and it has long been recognized that accreditation plays a crucial role in muting undue political pressures on higher education.77,78 In the words of A. Lee Fritschler:

Throughout history political involvement in the classroom has yielded negative consequences, including, most visibly, outright purges of faculty members and courses in Eastern Europe and prohibitions on teaching evolution in the United States. Less extreme but more prevalent are the bureaucratic excesses that result from political intrusion in the classroom; they are one of the things that account for the static higher education systems in many Western European nations.

Fritschler goes on to argue that “academic institutions perform best when government does not intervene in overseeing their core functions, namely definition of curriculum, teaching, evaluation of students, retention and promotion of faculty” since “one does not have to look back far in history nor farther than across the Atlantic to find examples where aggressive government intervention in the core functions has destroyed whole systems of higher education.” Fortunately, the general public grasps the importance of autonomy for institutions of higher education, with four out of five Americans saying that “the best way to ensure academic excellence is to make sure politicians don’t interfere” and registering “disagreement with the idea that government should control what gets taught in the college classroom.”

Prior to their gatekeeper role, accreditors really had no leverage over institutions, and therefore did not pose any threat to institutional autonomy. Also, there is at least one fairly prominent instance during this period when accreditors “helped to safeguard or restore the academic integrity of institutions subjected to political indignity” when accreditation was revoked after state officials excessively meddled with a school. Therefore, we’ve rated the accreditation system as doing an exceptional job of maintaining institutional autonomy in the eras prior to 1952.

Once given the gatekeeper role, accreditors essentially gained regulatory authority over colleges. They nevertheless shied away from abusing it, and from 1952 to 1985 the system largely preserved institutional autonomy. The accreditors themselves made few new demands, and the system continued to serve as a “buffer, keeping government at arm’s length from colleges and universities.” We therefore rate the accreditation system as performing satisfactorily in this dimension from 1952–1985.

In the current period, it is still true that the accreditors have been phenomenally successful in keeping the government from undermining institutional autonomy. But the accreditors themselves have often taken advantage of their position to do so. From the schools’ point of view, there is little difference between the federal government making demands under threat of withholding federal funding, or an accreditor making demands under threat of withholding federal funding. Everyone acknowledges that having the government prescribe missions or dictate how to achieve them would infringe on institutional autonomy, but very few seem to realize that there is just as much “danger to institutional autonomy and diversity among institutions… when institutional accrediting agencies prescribe missions or specific steps to achieve missions.” And yet “accreditors are free to impose standards that go beyond those Congress has mandated, using their leverage to push institutions toward any agenda they wish.” They have too frequently used their power as federal gatekeepers to “apply intrusive prescriptive standards and [enforce] ideological tests and other criteria unrelated to educational quality.”

Imposing Ideology. The concern for diversity stressed by many in the higher education arena apparently does not extend to the diversity of ideas. Much too frequently, accreditation has been used to establish and enforce ideological views. Two recent examples stand out. First, the National Council for Accreditation of Teacher Education (NCATE) “demands that schools of education assess the ‘dispositions,’ or opinions, of teacher trainees as a requirement for accreditation.” A second example is the Code of Ethics of the Council on Social Work Education (CSWE).

In both of these examples, students can be subjected to disciplinary punishment and academic sanction if they are not ideologically aligned with their professors. Indeed, the faculty at the Missouri State School of Social Work used the CSWE standards to subject students to “ideological ‘bullying’ (a term that both students and faculty used to describe the actions of certain professors), and producing a learning environment that reviewers called ‘toxic.’”

Above the Law. Accreditors have also at times imposed standards that would require institutions to break the law. The American Bar Association, which accredits law schools, told colleges that “a constitutional provision or statute that purports to prohibit consideration of gender, race, ethnicity, or national origin in admissions or employment decisions is not justification for a school’s non-compliance” with the Association’s diversity requirements. There is something deeply troubling in the willingness of the organization that oversees the training of those who are tasked with upholding the law encouraging others to ignore the law when it suits them. Fortunately, not everyone was caught up in such muddled thinking, with the American Law Deans Association retorting that “the accrediting body inappropriately inserts itself into the internal affairs of the institutions it accredits… and does so in a way that forces homogeneity, and conversely stifles innovation and diversity, among law schools.”

Interfering with University Governance. It is worthwhile to remember that accreditation is just one of the three hurdles that a school, whether prospective or established, generally must satisfy. The other two are “federal certification of financial and administrative capability” and “state licensing or approval to operate in a state.”90 In the course of licensing colleges, especially public colleges, states generally insist on various mechanisms such as Boards of Trustees or Regents to ensure that adequate oversight and consideration is given to public concerns. These “trustees are the ultimate fiduciaries of a college or university. Their outside experience and perspective constitute an important check on the senior administrative insiders who to a great degree run both the universities and the accreditation agencies.”

Unfortunately, the check on university administrators has been hampered as “accreditors have extended their reach in ways that inappropriately intrude upon governance and trustee oversight.”  Some examples:

  • “The Western Association of Schools and Colleges (WASC)… initiated in 2006 a review of leadership and board activities at the University of California… Far from promoting the public interest, accreditors forced the regents and chancellors to devote precious time, not to mention taxpayer dollars, responding to their meddling and inaccuracies.”
  • “The Southern Association of Colleges and Schools… standards insist that the President—and not the board—is in charge when it comes to major pieces of the academic enterprise.”
  • “In a case involving Auburn University… The regional accreditor sanctioned the board in 2003 for meddling in administrators’ affairs and put the school on a one-year probation for what The Chronicle of Higher Education reported was ‘trustee meddling in the university’s administration and for a lack of commitment to the accreditation process.’ The sanction was lifted only after three outside investigators found no basis for the penalty and trustees signed a personal statement of commitment to the accreditation process.”

 

These examples raise the important question of why “federally approved accreditors—who, almost without exception, are university administrators and faculty members whose interests may conflict with those of engaged trustees—have the power to second-guess boards, boards that have the ultimate legal responsibility for higher education governance?” To be sure, it is sometimes true that trustees become engaged in day-to-day operations of an institution in a manner that potentially undermines institutional improvement. Nonetheless, on the whole trustees play a potentially important and useful role of overseeing institutional affairs, and acts that weaken their ultimate authority are potentially quite worrisome. 

For these reasons, we believe that the accreditation system has performed in less than a satisfactory fashion in terms of maintaining institutional autonomy in the most recent period.

Evaluation: Maintain Independence/Autonomy of Colleges. Prior to the federal government’s involvement in the financing of higher education, accreditation was completely voluntary and had no regulatorylike powers over institutions. Before 1952, accreditation was therefore exceptional in preserving institutional autonomy. Between 1952 and the beginning of the accountability and assessment movement in 1985, accreditation continued to perform satisfactorily in this function, as the agencies imposed few demands on institutions and served as a buffer from governmental interference in their affairs. Since 1985 though, accreditors have too often utilized its position as gatekeeper to exert regulatory-like power over institutions to impose non-education related mandates, reducing institutional autonomy. Accreditation must be judged unsatisfactory for its negative role in terms of maintaining institutional autonomy in the post-1985 era.

It is worthwhile to note that these issues contribute to a brewing legal battle, as accreditors have essentially been given governmental power but are not currently subject to restrictions on their actions. As Jeffrey C. Martin points out, “A serious First Amendment problem arises in recognizing an agency and giving it authority over federal student aid eligibility that it then uses to infringe an institution’s academic freedom.” He argues that the “changes to accreditation have made it more likely “that the decisions of accrediting agencies constitute ‘state action’ subject to constitutional strictures.”

Maintain Diversity of Institutions and Missions

Another traditional source of strength for American higher education has been the diversity in both the types of institutions and their missions. Having options between vocational or liberal arts schools, residential or commuter institutions, faith-based and non-religious colleges and a plethora of other differences both gives the student more choices about what type of education to pursue, and also allows the schools to develop the different practices and policies that allow them to more capably accomplish their missions.

Accreditation’s performance on this dimension mirrors that of the autonomy dimension, and for the same reasons. In the earlier eras, accreditors did not have much leverage over colleges, since the system was entirely voluntary. They were given some power in the 1952 to 1985 era, but for the most part did not use it, as they still viewed their primary role as fostering quality improvement. As pressure was brought to focus on quality assurance, accreditation took a stronger regulatory stance, and some accreditors have used their power to curtail diversity among institutions.

While homogenization is arguably not the goal of accreditor actions, it is nonetheless the outcome as “some accrediting associations have adopted biased and intrusive review criteria that infringe upon institutional autonomy and self-governance. The ultimate result has been the homogenization of American higher education.”98 Colleges with alternative missions can be punished for being different. Take, for instance, Thomas Aquinas College:

[The college] was threatened with a loss of accreditation due to the fact that its avowedly Catholic, traditional orientation had no room for the multicultural courses that its accreditor, the Western Association of Schools and Colleges, was prescribing at the time (1992). The ‘Great Books’ curriculum at Thomas Aquinas was the very key to the school’s mission—so much so that there were no elective courses at all… president Thomas Dillon chose to complain that, ‘In the name of advancing diversity with-in each institution, [proponents of diversity] are imposing their own version of conformity and threatening true diversity among institutions.

This threat brought forth considerable criticism of the accreditor. Then President of Stanford, Gerhard Casper, “argued that the Commission was ‘attempting to insert itself in an area in which it has no legitimate standing,’” and former Education Secretary Lamar Alexander “concluded that it was not appropriate for an accreditation agency to wield what amounted to federal power in a manner that threatened academic freedom and diversity among institutions.”

Another avenue in which the diversity of institutions is being curtailed is for-profit colleges. The regional accreditation agencies have historically been hostile towards profit-seeking colleges, leaving them to rely on national accreditation to gain access to federal funds, with the former type of accreditation often being prohibitively expensive and risky to pursue, and the latter often viewed with much skepticism. Because the accreditation process is such a significant barrier to entry, some for-profit companies have resorted to buying struggling non-profits in order to acquire their accreditation. Many in the higher education community do not approve of this practice and have suggested that “accrediting agencies should block” this from happening and that such actions should trigger “a full accreditation review.” The accreditation community appears to have begun listening to such advice, as the Higher Learning commission recently refused to transfer Dana College’s accreditation to a group of investors because the accreditor speculated that the owners would alter the school’s mission, effectively forcing the closure of the 126 year old private college. While it is somewhat refreshing that the accreditation community believes that it should prevent some colleges from having accreditation, it is distressing to realize that this belief has very little to do with student learning or graduate outcomes, but rather focuses solely on the presumed implications of the tax status of the provider.

Evaluation: Maintain Diversity of Institutions and Missions. Our evaluation of accreditation in maintaining diversity in missions among institutions mirror those for the autonomy dimension: exceptional in the pre1936 and 1936 to 1952 eras, satisfactory in the 1965 to 1985 era, and unsatisfactory in the current era. In both cases, the reason for the deterioration is the same. Prior to 1952, the accreditors lacked the leverage to influence colleges in unacceptable ways. They were given that leverage in the 1952 to 1985 era, but did not wield it for the most part. More recently, some accreditors have occasionally used their power to try and curtail diversity among institutions by insisting on non-educational requirements that reduce institutional diversity.

Promote Efficiency

Higher education, similar to other economic activities, needs to be efficient in order to remain viable. Regardless of how much of a benefit higher education provides, if the costs to achieve those benefits are prohibitively high, the higher education system will be ultimately unsustainable. To be effective, accreditation should not suppress innovation, serve as a barrier to entry, or impose unnecessary costs.

Don’t Suppress Innovation by Existing Colleges

As tuition costs continue to soar, higher education is in dire need of innovation that can help lower costs. Many observers have suggested that higher education has remained resistant to the productivity gains experienced in most industries through the use of modern technology. In promoting an efficient higher education system, accreditation should not suppress innovations that have the potential to improve productivity.

Because accreditation was so new when it first emerged, many of the established colleges were essentially grandfathered in. Moreover, standards had yet to be developed that would restrict their freedom of action in any meaningful sense. Thus, prior to 1952, the accreditation system gets high marks for not restricting innovation by existing colleges.

From 1952 to 1985 there was an increase in the responsibilities placed on accreditation by the government as well as an increase in the need of institutions to obtain and retain accreditation. These concurrent trends placed enormous pressure on accreditors (in the form of a desire for consistency as well as to protect themselves legally) to adopt a quantitatively verifiable framework for assessing schools. Unfortunately, the only quantitative aspects of higher education that were easily verifiable tended to be inputs and processes. But if accreditation dictates the inputs to be used, and the manner in which they are to be used, then there is little room for institutions to innovate along these dimensions. Indeed, such requirements can be so “micro managing as to suffocate creativity [and] innovation, which is what is beginning to happen.”

It is true that there are large swaths of higher education in which institutions are free to experiment and innovate however they see fit. But it is equally true that there are some areas where they are not free to do so. Part of this is attributable to a bias towards the status quo on the part of accreditors. Because accreditors must themselves be federally recognized (or “accredited”, as it were) they are afraid of losing that recognition. Brittingham notes that “recognition as a regulatory system is not friendly to experimentation by accreditors with new ways of doing business; any change an accreditor considers potentially threatens its federal recognition.” While this bias towards the status quo is certainly understandable on some level, it nonetheless leads to a system that sometimes suppresses innovation. This tendency towards the status quo is also evidenced within institutions themselves, as college administrators at times stifle innovations by faculty or others within an institution by claiming (spuriously) that such action would threaten their accreditation.

A prime example of accreditation stifling innovation is illustrated by engineering accreditation (performed by the American Board of Engineering and Technology, or ABET). A number of employers and educators had grown unsatisfied with the education being delivered in the nation’s engineering schools, and set about reforming old programs and designing new ones to improve the quality of education. But “institutions that attempted to develop more flexible and innovative programs were increasingly harassed in accreditation reviews and were forced to make their curricular requirements more restrictive to avoid loss of accreditation. ABET had clearly become a stumbling block to reform”107 and the agency “could well be characterized as a protector of the status quo.”

Dissatisfied employers and colleges pressured ABET to reform and to focus more heavily on gauging student learning. Such a shift would, incomprehensibly, put it at risk of losing federal recognition as an accreditation agency. Thus, “ironically, ABET… voluntarily withdrew from the recognition system because it wanted to focus more directly on student learning outcomes and concluded it could not follow that path the way it wanted to while maintaining federal recognition.”

Some continue to insist that accreditors do not suppress innovation, pointing out that there are processes by which innovative programs can be implemented. What they often fail to mention is that these same processes often throw insurmountable obstacles in the way. For instance, the time required by one accreditor “for an innovative program to be approved is eight years.” This quite clearly is an example of “a process that lends itself to maintaining the status quo”civ while pretending to be open to innovation.

Wherever accreditors have set standards or requirements, institutional innovation has been suppressed. A university cannot try a creative new approach to providing access to library materials if the accreditor insists on doing things the traditional way. Consider for example the Council on Social Work Education (CSWE). They have numerous “accreditation requirements related to faculty, student development, curriculum, and innovative programs.” Carol S. Drolen argues that these requirements “deter curriculum innovation” and that “in addition to the very real possibility that this standard infringes on academic freedom” it also potentially reduces educational quality since “it very likely deters faculty in some situations from using the texts or instructional strategies of their choice, specifically ones that are the most creative and innovative.”

Evaluation: Don’t Suppress innovation by Existing Colleges. In light of the evidence mentioned above, we view accreditation’s performance on the dimension of not suppressing innovation by existing institutions as deteriorating from exceptional (pre-1952), to satisfactory (1965 to 1985), to unsatisfactory in the post-1985 era.

Don’t Be a Barrier to Entry for New Innovative Colleges

New colleges are an even more important source of new ideas for improving higher education and one of the best ways to disrupt the status quo. Ensuring that new and innovative colleges can be established requires that the quality control mechanism is not used as a barrier to entry.

When accreditation was completely voluntary, the barrier to entry problem had not yet developed. Accreditors could of course deny a college their accreditation, but since that decision was not tied to any federal money, the extent to which this discouraged new colleges was negligible.

From 1965 to 1985 we believe that accreditation was reasonably satisfactory in this regard. The system started out reasonably hospitable to different and new institutions (as long as it wasn’t for-profit). Even the traditional bias against for-profits was not insurmountable. When accreditors were first given their gatekeeper role, there were some “vocational, unaccredited schools for which there were no accrediting associations… [so] governmental officials had encouraged their development. For example, William Goddard, an owner of several well-known profit-making schools, organized the National Association of Trade and Technical Schools after such encouragement.”

Those days are long past however. The combinations of misbehavior by some schools (especially forprofits), and the shift towards an emphasis on compliance in accreditation reviews have created a hostile environment for new colleges. Many now argue that “the existing accrediting regime… hinders new institutions from entering and innovating” and “educational innovators say the process is inflexible and discourages creative approaches.” Accreditation now functions as a barrier to entry, keeping new institutions with innovative ideas from participating in the field.

Part of the problem is a “built-in catch-22 for innovators and entrepreneurs — you can’t be accredited (get access to public money) until you have proved yourself in advance. You can’t prove yourself in advance—prospectively—unless you are accredited.” The difficulty of obtaining accreditation for a new institution has led many for-profit companies to buy struggling not-profit colleges just to inherit their accreditation. Entrepreneur Michael Clifford has suggested that regional accreditation has a fair market value of around $10 million to an acquirer, as that is the amount that it would take to start a regionally accredited college, a “process that could take up to ten years and has only a 50-50 chance of success.”

But even supposing the barrier to entry issue was resolved, there would still be a major problem. Accreditation focuses so heavily on inputs and processes that even if new institutions were allowed to enter the field, they would be severely restricted in terms of what they could actually do. The system has evolved in such a way that it largely prescribes what inputs institutions should use and how they should use them. In other words, accreditors, while tasked with certifying the ends, have instead mandated the means to be used while almost completely ignoring the ends. But if the inputs that must be used and the way in which they are used are predetermined, that severely restricts the ability of new colleges to innovate. This “severely limits the advancement of new models of higher education” leading one observer to conclude that “accreditation today is the biggest barrier to innovation and change in higher education.”

Consider, for example, the case of StraighterLine, a company that offers a number of introductory courses. The company has an innovative business model that hosts traditional course material online, and arranges for online tutors to be available to students whenever they need help. This saves on the most costly resource used to provide an education—an instructor’s time. This allows StraighterLine to offer courses for a fraction of the cost of a standard college. However, the accreditation process restricts StraighterLine from selling its services directly to students, since only institutions, not courses, can be accredited. As a result StraighterLine is forced to partner with traditional universities, who often charge much more for the course.

Evaluation: Don’t be a barrier to entry for new innovative colleges. Accreditation did not serve as a barrier to entry for new innovative colleges prior to 1952 because it did not have the power to prevent entry. In the 1952–1985 era, accreditation performed satisfactorily in this regard. The expansion of higher education in this era forced accreditors to be lenient when it came to the standards for entry. However, in the period since 1985, accreditation has too often become a barrier to entry. It remains too embedded in its traditional measures of institutional quality to allow innovative ideas to gain momentum in transforming higher education from an inefficient system of the paper-based past to the modern and productive information-age economy. We therefore consider accreditation as performing unsatisfactory in this area.

Don’t Impose Unnecessary Costs

Any system that serves the purposes that accreditation does will have costs associated with it. When evaluating the current system, it is useful to distinguish between direct and indirect costs. Direct costs include line items such as membership fees, site visits, evaluation and in-kind expenditures to prepare for the process. These costs are generally relatively low. In addition to the direct costs, there are indirect costs that follow from the actions necessary to comply with accreditation recommendations. These recommendations often encourage money to be spent in order to satisfy the accreditation committee. These costs are “borne by the institutions themselves” and can be substantial.

Direct Costs. One of the greatest advantages of our current accreditation system is that as far as direct costs are concerned, it is dirt cheap, and always has been. In 1998, “the average total expenditure by public four-year institutions was $63,000.” If the system actually achieved all its stated goals, this would be considered a phenomenally cheap mechanism of improving and assuring quality.

The reason it is so cheap is that it relies heavily on faculty and administrator volunteers. In 2007, the regional associations “relied on 3,580 volunteers”from the colleges “compared with only 129 full-time staff.” While there are legitimate questions raised by such a heavy reliance on volunteers from the very colleges being accredited, that does not change the fact that the direct costs of the system are incredibly inexpensive.

The only real issue concerning the direct costs of accreditation is the fact that many institutions have to deal with many different accreditors. Indeed, about a quarter of survey respondents complained of the burden of “responding to the needs of multiple accreditors.” While this concern should not be dismissed lightly—for example, “A medical school may be examined by 40 or 50 separate accrediting agencies,”—the overall conclusion remains that accreditation is relatively inexpensive in terms of direct costs. However, these low direct costs have not prevented some university administrators over the years from complaining about how much time, money, and energy are wasted each year by excessive reliance on personal visits of accrediting teams.”

We therefore give accreditation relatively high marks in all periods for keeping direct costs low.

Indirect Costs. The indirect costs that universities face are the costs of complying with accreditors’ recommendations. Unfortunately, “Accreditors have a tendency to recommend actions by schools that will require them to use scarce resources to little or no purpose.”cxviii These often entail significant opportunity costs, diverting funds from better alternative uses. Prior to 1952, accreditors couldn’t force colleges to spend money because the associations and membership were voluntary. If an accreditor imposed a requirement that the institution disagreed with, the college could simply choose not to seek accreditation from that organization.

As so many other things, this changed once the accreditors were given gatekeeper functions. Accreditor “recommendations” would henceforth be viewed more appropriately as demands, and “few if any accreditation visits will end without some ‘suggestions’ for improvement that may affect the campus budget for many years.” 

Unfortunately, the “accreditation process rarely lends itself toward efficiency, productivity improvement, or ‘cost cutting.’” In fact, many of the accreditors’ demands drive up college costs while having a tenuous impact on the education provided.

The examples below are just some of the more blatant instances of accreditors recommending changes that indirectly drive up costs.

Demanding Lower Teaching Loads. The number of courses that professors teach in a term is referred to as their teaching load, and it can clearly affect the quality of teaching. Too many courses will leave professors with insufficient time for preparation, office hours, grading, and advising. Professors are also often expected to perform other duties, such as conducting research and serving on administrative committees. It seems quite clear that the universities, departments, and professors are in the best position to determine the appropriate teaching load based on all these factors, but accreditors have been known to interfere and demand lower course loads. For example, “Campbell University in North Carolina was placed on probation because its standard faculty teaching load was 15 hours per week. The accreditor insisted that 12 hours was the maximum acceptable load.” Complying with such a demand would require hiring many additional faculty members, which would obviously drive up the costs for the college.

Demanding Teachers Possess Certain Credentials. While there is little doubt that professors need to be knowledgeable about the subject material in order to be effective teachers, it does not follow that every instructor must possess a Ph.D or even a Master’s degree. As William James observed over a century ago, “Is not our growing tendency to appoint no instructors who are not also doctors an instance of pure sham? Will any one pretend for a moment that the doctor’s degree is a guarantee that its possessor will be successful as a teacher?” Nevertheless, “Accreditors’ recipe for educational inputs often includes the idea that colleges should employ individuals who hold ‘appropriate degrees’… Restricting hiring to individuals with these credentials may not lead to better teaching, but is virtually guaranteed to drive up costs.”

Demanding Excessive Planning. Leef and Burris note that “accreditation teams have a predilection for recommending ever more planning by schools.”131 The incentive for accreditors to demand more study of issues like campus safety or diversity, regardless of the previous level of study, simply to provide cover for themselves. This excessive planning can entail the diversion of money and leadership effort away from potentially more appropriate uses.

While the examples listed above apply to most accreditors, by far the worst offenders in demanding spending with little regard to institutional circumstances or goals are the specialized accreditors. These are the accreditors that evaluate specific programs or fields, and they often come to the conclusion that the institution is shortchanging whatever field they represent. This is unsurprising, given that “specialized accreditors often attempt to benefit faculty members in particular disciplines—at the expense of broader institutional needs.”  As John V. Lombardi, the president of the University of Florida complained, “They blackmail us… If they say your department of astrophysics needs 12 spaceships and you have only 10, you had better get the other two… You take the money from the history department because it doesn’t have an accrediting lobby to protect it.”

Specialized Accreditors. “The most egregious example” of a specialized accreditor acting in the interests of the field rather than the institution is the American Bar Association. “Many of the ABA accreditation rules have only gossamer connections to the quality of legal education,” but that hasn’t prevented the ABA from insisting on all types of requirements that while costly to satisfy, yield no educational benefit. Many of these requirements “have a laser-like focus on the perquisites of being a law professor—down to specifying the number of square feet in each faculty member’s office.” In the 1990s, the ABA went so far as to dictate the salaries of law professors until the Justice Department wrangled a consent decree directing the ABA “to concern itself with academic quality instead of resources.”

Because of the incessant calls for more resources in their particular area, the specialized accreditors are largely “viewed as a guild designed to protect the guild.”136 In the words of Jon Provost, “you can get a fair picture of the world of specialized accreditation by imagining 250 or so would-be ABAs, each carping for a finer grade of ivory in its part of the tower.”

This is problematic, since the “misplaced priorities” of accreditors often results in “driving up costs or reallocating (or misallocating) institutional resources.” For instance, Peter Magrath, former president of the University of Missouri recalled when “the accrediting committee from the American Bar Association insisted that we should have a new building. The problem was that you had people making decisions about the use of university resources who didn’t have an overall perspective.” They were insisting on a new building without knowing if that was in fact the best use of the university’s scarce resources.

All too often, the outcome of accreditation in general and specialized accreditation in particular is to pressure colleges to spend more money, often inappropriately. As one accreditor acknowledged, “To read [accreditation] reports in which time and again, teams called for institutions to spend more money— often for physical facilities, libraries, or faculty—but hardly ever were these recommendations connected to improving the outcomes of the learning experience. We assumed that this result would occur but never verified that the changes had had this effect.”140 Spending on inputs is continually encouraged, and “peerinstitution analyses… showed that each new expenditure was ‘appropriate’.” Yet at no point is it explained how the additional spending will improve student learning nor are any actual effects evaluated after the spending occurs. Needless to say, this relentlessly drives up the cost of college without improving learning.

Evaluation: Don’t Impose Unnecessary Costs. The costs of accreditation can be broken up into direct and indirect costs. The direct costs of accreditation are, and have always been, low. Prior to 1952, the indirect costs were low as well, since membership was voluntary. Since then, however, the indirect costs have become a more pressing problem. The tragedy is that colleges are currently required to spend massive amounts of money on things that have never been shown to lead to higher student learning.

Because the vast majority of accreditation’s costs are of the indirect variety, they are given more weight in our evaluation. We conclude that accreditation deserves high marks before 1952, merely a satisfactory evaluation for the 1952 to 1985 era, but an unsatisfactory rating in the post-1985 era.

 Part 2: Reforms of and Replacements for Accreditation

 Part 3: The Case for Replacing Accreditation