An Analysis of Higher Education Accreditation. Part 2: Reforms of and Replacements for Accreditation

In this section, we will discuss several ideas for reform of the existing accreditation system, as well as several alternative systems that could potentially replace accreditation in the role of providing quality assurance.

Publishing Accreditation Reports

Requiring accrediting bodies to publish reports detailing their findings is one common reform option. Under the current system, accreditors do not make their assessments of universities publicly available. Generally, the information released only indicates whether or not an institution has received accreditation. Since nearly every college has accreditation, this is not very informative. Nor does it inspire confidence in accreditation decisions. In the words of one former accreditor, “The secrecy of peer review has actually become counterproductive in terms of credibility with the public.”

While technically private agencies, accrediting bodies are providing public functions, particularly as they pertain to publicly supported institutions of higher learning. In many states, open records laws and other legislation is designed to provide transparency in government. Large amounts of public funds are used, even at most private institutions, so the insistence on transparency through publishing reports seems well placed.

The more expansive goal of providing the public with information on the finances, operating procedures, external evaluation and learning outcomes is urgently needed in higher education, and the achievement of that goal would be greatly enhanced if accreditors would make more information available to the general public. Relatively independent assessments of the strengths and weakness of individual institutions would allow for more informed consumer and public policy decisions. As the system functions today, accreditation does very little, if anything, to assist either group in making informed decisions concerning higher education.

The main downside to increased transparency is that colleges would become less forthcoming in their dealings with accreditors. As David L. Warren, president of the National Association of Independent Colleges and Universities said, there are worries “that constructive criticism in the reports, designed to spur improvements, would be taken out of context in press reports and characterized as a major deficiency.” This leads “some accreditation officials to fear that more public disclosure will result in: an adversarial, rather than collegial, accreditation process; a smothering of trust critical to self-analysis; unwanted press coverage of school problems; and schools withholding information.” This could diminish the effectiveness of accreditors along the quality improvement dimension, since they cannot help colleges to address their weaknesses if the colleges are deliberately hiding them in fear of negative publicity.

In our view, the objection that publishing accreditation reports might embarrass the institution is overblown and is trumped by the great public benefit that publication would yield. Shouldn’t weaknesses in these institutions be exposed to public scrutiny? Since third parties—especially taxpayers—fund much of higher education, does not the public have a right to know how what are essentially governmental mandated observers assess these institutions?

Fundamentally, “Unless the system produces sufficient data in a transparent manner with the capacity to make public comparison of results with other practitioners, it will ultimately fail.” Requiring accreditation reports to be published would greatly increase transparency at little cost, especially if reasonable decisions are made about what is to be disclosed. 

Move Away from Binary Decisions

Another needed reform would be to move away from the binary yes/no judgment. The current system “works like a light switch—either it’s on or it’s off… Accreditors would greatly improve their worth to the public if they would delve into the strengths and weaknesses of colleges and universities rather than just scanning to make sure that they fit the general profile of acceptability.” In other words, no mechanism exists to signal the level of quality or to allow meaningful comparison among accredited institutions. Moving away from the binary yes/no decision would change that. For instance, institutions could be explicitly evaluated on a dozen or so categories, with accreditation requiring sufficiency in 8 or 9 and plans for improvement in the rest. Or, numerical rankings could be developed in various categories of inquiry, with a minimum aggregate score needed to be accredited.

One of the main benefits of this reform would be an increase in the information on college quality provided to the public. “If there were levels of accreditation, institutions would compete for honored spots,” and the winners of this competition would be easily identifiable. The additional information provided by a tiered accreditation system would lead to a better public understanding of standards and quality, and the different levels of accreditation would provide an important insider counterweight to external college rankings, such as those by US News and World Reports and Forbes. 

Indeed, we would argue that the importance of college rankings in consumer decisions is likely directly a result of the failure of accreditors to offer a meaningful alternative. People don’t want to know whether Slippery Rock State University is “acceptable” (accredited), but how it compares with comparable peer schools, and rankings such as those of US News & World Report and Forbes provide them with that information.

This has not happened essentially because colleges, who largely still control the accreditation process, do not want information released that would hurt them competitively. They perceive it in their institutional interest to minimize knowledge about the quality of the educational offerings of colleges. That, however, is clearly inimical to the public interest.

In addition, with a non-binary, more precise, evaluation system, accreditors would have a greater ability to sanction colleges and enforce minimum quality requirements. Under the current system, “Their decisions are so starkly up or down that, as a consequence, they hardly ever deny accreditation. As a regulatory tool, they are about as effective as a sledgehammer.” This would likely change if we had more distinct levels of accreditation that indicated different levels of quality.

It is possible that innovation would also be enhanced. An “experimental” category of accreditation could be made available that granted the students of promising new ventures access to financial aid, with the results of the new venture being evaluated for effectiveness after a set number of years. Since the results of the evaluation would not imperil the rest of the institution, new and existing colleges would be more willing to try new things.

The main drawback of such a proposal is that in the absence of reliable measures of student learning, accreditors would likely default to their input- and process-based criteria. Thus, a tiered system would likely evolve into a caste-like system where institutional expenditure is the main determinant of the type of accreditation granted, improperly giving the impression that some institutions are of higher quality merely because they spend more. This would increase indirect costs, as institutions would face another incentive to match the spending of colleges in the highest rated tier. 

Overall, this is a promising reform, even more so if combined with an emphasis on basing decisions on student learning or other outcomes. Moving towards some uniform national indicators of academic performance and measures of “value added” by the university experience would seem highly appropriate.

Increase Competition Among the Accreditors

Institutions have virtually no choice as to whom will do general institutional accreditation, as they are forced to use the agency in their region. The exception is the option to pursue national accreditation, yet this path has a stigma of being inferior. Some critics of accreditation have thus described the regional accreditation system as cartel-like, with each accreditor granted a regional monopoly with a guaranteed market for customers without having to provide much benefit. As a result, there is little to no competition between accreditors for the right to certify a college or university as eligible for federal student aid.

Allowing colleges to seek accreditation from any approved provider in the country would likely result in colleges soliciting bids from a number of agencies who would compete to provide accrediting services for each institution. This would likely enhance performance in regard to their improvement role since the exit option for colleges would give accreditors a greater incentive to provide useful advice and services.

Whether this competition results in better measures of quality is open to debate. Some believe it would likely result in “a troubling form of competition—competition for the lowest standards.” Others believe that “schools that wanted to differentiate themselves by virtue of their high standards, serious teaching, sound curriculum and so forth might seek out selective accreditors whose certification would be a mark of distinction.” It is likely that there is some truth to both of these views. One consequence is that there would likely be a decline in the certification of quality, as at least some accreditors would engage in a race to the bottom. However, the differentiation of accreditors would provide useful information, since accreditors who engaged in race to the top would offer a mark of distinction to member colleges. A good analogy would be academic journals. While there are certainly some journals with low standards, any given field has a handful of top journals with high standards, and academics publishing in those journals are distinguished from those that don’t.

Presumably, additional accreditors would enter the field and none would have a captive audience anymore. This implies that the system would not be as big of a barrier to entry and that we would see less suppression of innovating ideas by existing colleges. We would also likely see a reduction in indirect costs, as colleges moved away from accreditors that made unreasonable demands concerning the spending of institutional resources.

Alternatives to Accreditation

The above proposals for reform all essentially keep the current system in place and try to reform certain aspects of it. The proposals mentioned below deviate from those above in that they seek to have accreditation abandon the quality assurance function entirely. Quality assurance is then to be handled by some other entity, and accreditation would revert to its historical role of focusing on quality improvement.

A Quick Note on Quality Improvement. One recurring theme in the proposals below concerns enhancement in the quality improvement function. The reason for this is that accreditors are currently tasked with a role in fostering quality assurance, which they do not view as essential, and indeed view as a distraction from their true purpose, which they understand to be a focus on quality improvement. All of the proposed reforms below remove the quality assurance role that is currently in the hands of accreditors. Without being prodded by the government to focus on quality assurance and compliance, the accreditors could focus more exclusively on their role in quality improvement. This is both their preferred activity and is more in line with their capabilities and historical mission. In addition, by severing the tie between accreditation and federal funding, colleges would no longer be forced to endure anything accreditors decide to mandate. Colleges would only seek out accreditation if its benefits were greater than its costs. Therefore, we would expect to see progress in the quality improvement function for all of the reforms below.

The Market The first alternative system to accreditation as it is currently practiced would be to end the quality assurance role by cutting the tie between accreditation and federal funding, relying on the free market to provide public accountability.

A compelling case can be made for this proposal: The reason for linking the two at the time of the GI Bill was to protect against the squandering of federal funds on institutions that provided an education in name only. Experience has shown, however, that many accredited institutions now provide an education in name only. If accreditation ever served as a reliable proxy for acceptable educational quality, it no longer does.

Moreover, some believe that recent legislation has effectively already “removed their quality assurance role altogether, saying it is essentially up to the institutions to decide what ‘quality’ is, while accreditors are presumably left free to meddle, as they often do, in matters unrelated to educational quality.”154 In other words, accreditors to date have not performed the quality assurance role effectively, and Congress has mandated that they not at all do so. There is therefore little reason to continue to tie accreditation status to institutional eligibility.

What Would Improve? Cutting the tie between accreditation and federal funding would have a few advantages. Accreditation would once again be completely voluntary, and because accreditors would no longer have quasi-governmental power, they could no longer essentially force institutions to do what they wished. This would allow colleges to ignore inappropriate recommendations from accreditors. Institutions would therefore gain much more freedom of action, leading to improvement in the maintenance of institutional autonomy and diversity, a reduction in the suppression of innovation by existing colleges, a reduction in barriers to entry by new colleges, and a reduction in costs.

What Would Stay the Same? The definition of appropriate measures of quality would likely stay the same. The accreditors currently refuse to actually define what students should get out of college, and they largely do so at the behest of the colleges themselves. The colleges are supposed to individually determine what quality means, and removing the accreditors from the equation would not change this. The information provided to the public would probably stay roughly the same. While the current system does an abysmal job of providing the public with information, there is little reason to expect that to change. It is likely that we would see the emergence of a class of certifiers that distinguish schools along various criteria, essentially ranking the colleges. However, there is nothing stopping the emergence of organizations that could do this under the current system. Moreover, several major publications already publish rankings of colleges, so it is not clear how much more information would be provided by the implicit rankings provided by the new accreditors.

What Would Deteriorate? We would expect to see deterioration only in the certifying of quality. Some argue that letting the market perform this task would be acceptable:

The self-interest of students and parents reduces the problem of fraudulently low-quality education that the accreditation requirement was supposedly needed to prevent to one of de minimis proportions. If there were instances of educational fraud by institutions receiving federal funds, it would be better policy to ban them from receiving federal funds for a period of years than to compel all to participate in an accreditation system that has, in the view of some observers, more cost than benefit to educational institutions. That is the approach the government takes with the Food Stamp program. Rather than trying to limit Food Stamp use to approved stores, the government looks for cases of fraud and prosecutes them.

The market is indeed capable of performing the quality certification function for a vast array of products and services. For example, there is no need for a quasi- governmental agency to certify the quality of restaurants (there are health inspectors, but they only establish whether the restaurant follows health codes, they do not pass any judgment of the quality of food served). Consumers can go wherever they wish, and through a combination of direct experience with the product, communication with others that have direct experience, and independent third party reviews, make informed decisions about which product to buy. Restaurants that provide higher value can be expected to displace those that offer lower value. A similar mechanism is at work in “certifying” quality for any number of other products, from cars to magazines. If this same mechanism functioned with higher education, there would be no problem with relying on the market to certify quality. However, higher education has a number of relatively unique characteristics that complicate the issue. To begin with: 

It is virtually impossible to know the true quality of an undergraduate degree: the student purchases the service only once, participates in the provision of the service, the service provided is a capital asset, there is no secondary market for degrees, and the value of the degree may not be known for years after it is purchased.

All of these distort the information that prices signal in a well functioning market. Adding to the confusion is the non-profit or public status of most institutions, the principal-agent problem, peer effects, and college as a status good. All of these conspire to cloud informed decision making. We therefore have little confidence in the ability of the market to send the appropriate signals about college quality, at least beyond the extent that is currently in practice by popular college guides and rankings systems.

We would note, however, this is not truly an example of “market failure.” Markets operate efficiently when information on alternatives is widely available at low costs, and that is not true with colleges in large part because they conspire to NOT provide information that would be of great interest to consumers: information about educational services and even about those who are funding those services. 

If the market is unable to enhance informed decision making, then we are likely to see a significant deterioration in the certification of quality in higher education. For all of its flaws, accreditation is fairly effective at marginalizing diploma mills, and this result would be lost once the market was put in charge of certifying quality. In its place, we would likely see a free for all of fly by night schools trying to grab federal funding in a marketplace unable to distinguish among high quality colleges and diploma mills.

Would Such a System Be Appropriate? Overall, the importance of the quality certification role and the significant deterioration that we would expect to see leads us to conclude that this is not a desirable alternative. If at some point in the future, reliable measures of student learning are devised, this would allow for direct determinations of college quality to be made. It would then be feasible and appropriate to rely on the market. Moving to that goal should be an aim of policymakers. But until there are measures of student learning publicly available that allow for direct comparisons of colleges, relying heavily on the market is inadvisable.

The Government

Another alternative to the current accreditation system would involve shifting the quality assurance roles from the accreditors to the government. Some argue that “the federal government should not use accreditors as its proxies; it should establish its own set of criteria for Title IV eligibility and enforce those standards” This type of proposal has resurfaced throughout the post-1952 history of accreditation. One of the earliest pushes occurred in the early 1970s when the Newman Committee recommended a “comprehensive, uniform, government-controlled system of eligibility for postsecondary institutions.”

Such a government run system would be analogous to creating a Food and Drug Administration (FDA) for higher education. The federal government would be directly in charge of determining the effectiveness of educational practices, and would allow those that it approved of while disallowing those that it did not, all supposedly in the name of protecting the public.

What Would Improve? Given the underlying trends that gave rise to the accountability movement, it is difficult to imagine scenarios under which an FDA of higher education would not be expected to lead to a number of improvements in the quality assurance area. For starters, we would expect to see improvement in the definition of appropriate measures of quality. To the extent that accreditors have stressed evaluating student learning, it is often at the insistence of the government. It is highly likely that the government would continue to focus on devising methods of determining how much students learn. While the government would probably continue to rely too heavily on standards involving inputs, the additional focus on student learning would be most welcome.

We would also likely see improvement in the enforcement of minimum standards. Under the current system, accreditors are too reluctant to take away an institution’s accreditation. Comparatively, the political process shows much less restraint. Entire sectors have been known to come under attack, as evidenced by the most recent crusade against for-profit colleges. It is highly unlikely that diploma mills could be established or continue to operate for any significant length of time in such an environment.

Lastly, more information would be released under such a regime. Because they would not have a quality improvement role that relies on candid self-assessments, the government would not have as much potential to publish embarrassing things as the accreditors. Moreover, the government is accustomed to operating in a more transparent manner, and would not be as reluctant to release their major findings.

What Would Deteriorate? In contrast to the improvement we would see in the quality assurance functions, the health and efficiency of higher education would be dramatically hurt by an educational FDA.

Both of the historical strengths of higher education we’ve highlighted would be badly eroded. Institutional autonomy would be greatly circumscribed if the government was the ultimate judge of what constitutes a valid education. Rather than maintaining or encouraging diversity, every institution would be pushed towards a common politically popular vision once a set of universal standards were in place. In other words, an FDA for education “would represent the ultimate in centralization, standardization and uniformity.” 

The efficiency of higher education would be further impaired as well. Government agencies are notorious for being unable or uninterested in innovating. In the few areas where they succeed in encouraging innovation it is either by giving grants to largely unmonitored private parties (through agencies such as the NSF or NIH) or by studying methods of achieving a known goal (such as NASA or Defense projects). Neither of these is appropriate for higher education. Innovation by existing universities would likely be stifled, and innovative new colleges would be even more disadvantaged, caught in a catch-22 of not being allowed to operate until they have demonstrated their effectiveness while not being able to prove their effectiveness without being allowed to operate.

Lastly, such a system would likely be much more costly than is currently the case. The direct costs would certainly rise, as the volunteers in today’s system were replaced by government bureaucrats. Indirect costs would likely go up as well, as the government would likely have more onerous paperwork and reporting requirements. It is possible that costs would decline if the government reined in “recommendations” that required spending more money. However, the history of the budgets of government runs programs renders this highly unlikely.

Would Such a System Be Appropriate? Overall, installing an FDA for higher education would make our system much more like those found in Europe, whose colleges are typically subject to much greater government control. A minimal level of educational quality could be assured with greater confidence, but the higher education sector itself would be much more uniform, stagnant, and ineffective, similar to the current state of the public K-12 education system.

It should be noted that “there is no fear of federal interference more often expressed than that of the government imposing some ‘one size fits all’ standard for quality.” There is virtually unanimous agreement among those in the academy that direct government involvement of this type is to be avoided with many observing that “the DOE has made clear that it is not a good judge on issues of academic quality, and the prospect of its telling others how to promote academic quality is grimly amusing.” This leads to the conclusion that “the risks of going down the road of bureaucratic federal intervention in teaching and learning are far greater than the likely benefits.”

We are in complete agreement with the academy on this score. While we find the improvement in the quality assurance role to be a significant benefit of an FDA-like system, it comes at too high a cost in terms of higher education’s overall health and efficiency. Relying on the government to perform the quality assurance role currently tasked to accreditors would be too much like curing the disease by killing the patient.

A Centralized Accreditor

Accreditation is said to be an example of regulatory capture, which occurs when the supposedly regulated gain control of the regulatory process. Accreditation was started, funded and maintained by colleges, and is staffed largely by college employees, so it is perhaps not surprising that “any serious analysis of accreditation as it is currently practiced results in the unmistakable conclusion that institutional purposes, rather than public purposes, predominate.”

To address this problem, another proposal seeks to install a more centralized accreditor that is less beholden to the universities. There are two main variations of this proposal. The first is to create one national accreditor. The other seeks to recreate for higher education the regulatory structure of the financial sector. In the financial sector, the Securities and Exchange Commission (SEC), a government agency, has the authority to set accounting standards. However, for the past few decades, they have relied upon a private organization, the Federal Accounting Standards Board (FASB), to set the standards.165 A similar arrangement could be used in higher education, with the Department of Education or some agency tasked with determining institutional eligibility (or for recognizing accrediting agencies), but relying on a private organization to actually make the determination. Under either the sole accreditor or FASB model, the government would exercise more but not complete control over the accreditation system. At the same time, the institutions would exert less control. The best way to think about the likely implications of this reform would be if the accreditors were less constrained by institutional pressure, and more constrained by governmental pressure.

We predict that the ultimate effects are likely to be in the same direction as under the previous government model, but of lesser magnitude, since the centralized accreditor would be subject to more pressure from the institutions than the government would be.

What Would Improve? The new accreditation system would either voluntarily choose to focus more on the quality assurance aspects, or would be pressured into doing so by the government. This would yield improvements in adopting more appropriate measures of quality. It remains the case that some current and past accreditation officials were the main impetus in moving towards measures of outcomes and student learning, however reluctantly others have followed. The enforcement of minimum quality criteria would also likely see improvement. A centralized accreditor would be less reluctant to shut off funding for substandard colleges.

We would also expect an improvement in the quantity and quality of information available to the public. A centralized accreditor would still probably insist on non-disclosure for as much as possible, especially information concerning self-studies and improvement efforts. But the government’s huge financial interest in higher education, and the resulting pressure to be more transparent and focus more on the quality assurance role would give the centralized accreditor both the motivation and the means to release more meaningful information about colleges. Moreover, because standards would be more consistent, institutional comparisons would be easier to make.

Somewhat counterintuitively, we would expect costs to decrease. The direct costs of setting up a national accreditor, or a national accreditor of accreditors would be higher than under the current system. But the indirect costs would be lower, since specialized accreditors would be marginalized. Specialized accreditors are a major source of higher costs in higher education, and reducing their power to “recommend” additional spending in their field would yield significant costs savings.

What Would Deteriorate? Just as with the governmental model, we would likely see deterioration in the health and efficiency of higher education under a centralized accreditor. While a centralized accreditor would be more attune to institutional concerns regarding autonomy and diversity than the government, they could suppress the freedom of action of colleges just the same. As Judith S. Eaton says, such a system would “undermine the strength and diversity of U.S. higher education.” Moreover, the lack of other accreditors with which to compare actions would make it less likely that unduly restrictive actions would be noticed and addressed. The FASB model for recognizing accreditors comes out better than the national accreditor in this regard, since it theoretically allows for multiple accreditors, analogous to the existence of multiple ratings agencies within the financial sector. But it should be noted that under such a system, all the different accreditors would be pushed in the direction of uniformity.

By centralizing quality control, the new system would also reduce the ability of new and existing colleges to innovate. Under the current decentralized system, there are escape hatches – just because one accreditor refuses to allow some innovative new practice doesn’t mean that they all will. But when there is only one accreditor (or if they all make similar decisions because they are all accredited themselves by one organization), than there would be no such escape hatch. Such a scenario would be dangerously analogous to direct governmental control.

Would Such a System Be Appropriate? A national accreditor or an accreditor of accreditors would not be appropriate, except as the only viable alternative to the federal government acting as accreditor. A national accreditor would be better than a government accreditor, but not by much. Similarly, an accreditor of accreditors following the FASB model would be a bit better than either, but is still “an unlikely model for precise emulation” since “FASB, to be successful, insists on one-size-fits-all standards, an anathema to higher education.”

A national accreditor or a FASB for higher education would either continue to ignore the quality assurance role in order to focus on the improvement role, or (more likely) would be pressured by the federal government into focusing more on it. Regardless, innovation and the health and efficiency of higher education would likely suffer. Therefore, we don’t recommend this as an alternative to accreditation. 

Measure What They Learned or What They Can Do

Under the current system, measures of inputs and processes are used as proxies for quality. The final set of alternatives involves fundamentally changing that. There are two main variations. The first involves measuring what students learn, the second involves measuring what student can do.

The idea of measuring what students learn is most commonly associated with what is called a qualifications framework. Modeled on a quality assurance mechanism common in Western Europe, a qualifications framework would seek to determine what students should learn (in each degree or in general), and then evaluate whether the students actually learned it, usually through the use of qualifying exams.

The idea of measuring what college graduates can do is most commonly associated with the concept of licensing or certification. Under this scheme, exams would be used to assess the competence of graduates on things that they would be expected to know or be able to do. For instance, in order to become a certified accountant, one must past the CPA exam that attempts to measure one’s mastery of accounting practices.

Determining institutional eligibly under these alternative proposals is straightforward—only those programs or institutions that do a sufficient job in increasing student performance on these exams would have access to federal funding.

These two approaches have a big advantage over the current system. Instead of measuring inputs and processes, and assuming that they lead to desirable learning outcomes, the outcomes themselves are the measure of quality. The main drawback is that this requires appropriately defining what is to be learned or expected of graduates and devising assessments that can measure learning or skills along those dimensions. Thus, these reforms are contingent upon being able to design an appropriate content, certification, and/or licensing exams that are widely accepted as both: a) testing for the appropriate knowledge and skills; and b) accurately distinguishing those that are knowledgeable/skilled from those that are not.

This is currently impossible for most broad categories. As one skeptic put it, “Let us imagine that professors of engineering around the world have been called together by government regulators to produce a single test or curriculum that will encompass every field of study within the engineering discipline… It would be a bureaucratic nightmare to come up with a definition of the field, or fields, to develop a test for all students and grade them on that test.”170 But even for a broad field such as engineering, there is already such a test, the Fundamentals of Engineering exam. Administered by the National Council of Examiners for Engineering and Surveying, the exam is used by many state licensing boards.

Moreover, the chance of developing a successful exam increases as the topic of study gets narrower. So while it is highly unlikely that a suitable exam for something like the bachelor’s in business administration (B.B.A.) could be designed, it is conceivable that one for a subfield like accounting could be. In fact, there already is an exam, the Uniform Certified Public Accountant Examination, for accountants. The bar exam for lawyers is another well known and widely used certification exam, and the Chartered Financial Analyst certification is becoming more common for financial analysts. Such qualifying exams are in widespread use in Western Europe.

Essentially, the basic idea behind these two alternatives to accreditation is to develop a CPA or bar exam for other disciplines. Any number of organizations could devise these types of exams, from existing test makers like the College Board and ACT, to field based organizations such as the American Economic Association, to foundations like Carnegie, Lumina, and Gates, or even quasi-independent government agencies like the National Science Foundation, not to mention completely new organizations started for the explicit purpose of designing such tests.

The performance of a program’s students on the exam(s) could then be used as a measure of the quality of their educational offerings. Programs that do not sufficiently increase their graduates’ performance on these exams could have their eligibility for federal funding terminated. 

For simplicity’s sake in evaluating the impact these alternatives would likely have, we have grouped these proposals together because they tend to lead to improvement and deterioration in similar ways, though the magnitudes can vary.

What Would Improve? To begin with, we would see massive improvement in the definition of appropriate measures of quality. No longer would we need to rely on proxies of quality, like input usage. Rather, there would be a direct objective measure of a program’s quality, namely, the extent to which it increases students’ performance on the qualifying/licensing/certification exam. It should also be pointed out that adjusting for the quality of students admitted is fairly straightforward, and doing so would avoid biasing measures of success in favor of more selective institutions.

We would also see massive improvement in the certification of minimum standards, as quality would be defined in terms of meeting some minimum standard of educational value added. Revoking eligibility of programs that did not improve their student’s performance (or do not improve it enough) would provide clear certification that eligible programs meet some minimum standard. One big advantage of this approach is that accreditation decisions can be reached at a much lower level than the level of the entire institution. For example, an institution could be accredited to offer degrees in accounting and early American history, but not in chemical engineering, all based on their students’ performance on the relevant exams. Accreditation could even be offered at the course level, again, presuming a suitable exam could be devised.

This would drastically reduce the importance of any one accreditation decision, which would be beneficial. It is inconceivable that a large institution like the University of Texas would lose accreditation because of subpar performance in one field. This, of course, allows for subpar performance to persist. Making accreditation decisions at a lower level would allow for the termination of accreditation for only those areas with subpar performance without endangering the rest of the institution.

We would also see massive improvement in the information provided to the public. With an objective measure of student performance, it is fairly straightforward to determine the relative quality of education provided by each program. If program X and program Y start with similar students and teach in similar ways, but program Y’s graduates score higher on the certification exam, it is safe to conclude that they are providing a superior education. Since the performance of each program’s students on these exams would be publicly available, students, parents, and policy makers could make much more informed decisions. Magazines and newspapers would regularly publish pieces detailing not only what programs provide the best education, but also which ones provide the best value (cost adjusted quality).

Institutional autonomy would also increase. Because eligibility decisions would be based on objective measures of output, there would be no need for restrictive input and procedural requirements. While the current system largely prescribes what inputs colleges should use and how they should be used, under the new system, colleges would be free to use whatever means they deemed necessary, so long as they produced results.

Along similar lines, some types of innovation would be encouraged. Specifically, existing and new colleges would be much freer to experiment and innovate with new ways of accomplishing traditional things. So while the outcome of teaching students calculus will not change, colleges would have the incentive and capability to try new ways of achieving that goal, for instance by altering the curriculum or teaching practices. New practices that proved to be successful would likely be noticed by other providers and quickly emulated, leading to a state of continual improvement through competition 

Our guess is that the indirect costs of the new system would decline. This follows from the observation that accreditors, especially specialized ones, would no longer be able to insist on costly input and procedural requirements, since eligibility would be based on direct measures of outcomes. Partly offsetting this is the possibility that costs could be driven higher by the enhanced comparison of colleges. The new system would, for the first time, give institutions clear guidance on which educational practices are most effective and pressure them into adopting them or face going out of business, similar to how market driven industries function. Whether this increases or decreases costs depends on whether effective practices are more or less expensive than current practices. Since the literature on the cost effectiveness of many current practices is inconclusive, and the learning outcomes of higher education have not been adequately studied, it is difficult to say what effect this would have on costs. The fact that the public would have measures of quality adjusted by costs, it may well be this system would foster greater price competition in higher education.

What Would Stay the Same? We would expect institutional diversity to stay roughly the same. The greater data availability on outcomes would facilitate comparisons and rankings. This would put much greater pressure to adopt best practices—defined as whatever the best performing colleges are doing. If the exam is truly testing the right things in the right ways, then this is arguably a good thing in the sense of increasing the effectiveness of our colleges. Nevertheless, this increased pressure to mimic the best colleges will tend to reduce the diversity within higher education. Offsetting this is that it is very likely that there are multiple ways to achieve a goal. It could be that certain educational practices are equally effective, or more effective for certain types of students. This would tend to increase diversity. Without more information, we assume that these forces will roughly balance out, leaving the diversity of institutions unchanged.

What Would Deteriorate? One area that would see deterioration would be innovation in the sense of creating new educational programs. The practice of evaluating colleges at the program or course level rather than the institutional level would make it more difficult to create a course of study in a brand new field or to develop a new program with a multi-disciplinary focus. Under the current system, an institution that already has accreditation is free to offer these types of programs. But granting approval at the program level requires that the field be well established enough for there to be consensus on both the content to be covered as well as an exam for evaluating performance. Neither of these conditions will be satisfied in a new or multidisciplinary field.

Lastly, the direct costs of the new system would be much higher than under the current system. Developing, administering, and continually revising certification exams would be much more expensive than relying on volunteers to conduct evaluations.

Would such a system be appropriate? The current system makes virtually no attempt to measure learning outcomes in a useful way, and either a qualifications framework or certification process would change that. By moving to a system based on student learning outcomes, we would see drastic improvement in all aspects of the quality assurance function. The health and efficiency of higher education would also generally improve, with the main exceptions being that radically new fields and innovation would face more obstacles, and the system might well cost more (however, higher direct costs associated with the accreditation procedures might be fully offset by greater efficiencies associated with increased price competition arising from greater information provided to the public).

The main problems with this model are a lack of consensus and practical issues. The qualifications framework and the certification alternatives require a consensus on what students should be learning as well as exams to measure learning or capabilities. Without widespread agreement on these issues, these proposals are impractical. We therefore largely support efforts to define a common core of knowledge that all students of an academic discipline should understand. The fact that Graduate Record Examinations and other tests are given in large numbers of disciplines makes us believe this problem could largely be overcome, but has not to this point because of inertia or opposition on the part of institutions.

 Part 3: The Case for Replacing Accreditation