An Analysis of Higher Education Accreditation. Part 3: The Case for Replacing Accreditation

While we have determined that commonly recommended reforms of accreditation would be largely beneficial, they really do not go far enough. Rather, we believe it is preferable to replace accreditation as the provider of quality assurance. Most of American economic life thrives well without accreditation—why not higher education?

We want to emphasize that “no completely satisfactory solution to the eligibility problem exists.” With that in mind, it should be acknowledged that some claim the status quo is the most desirable of the possible systems. The argument is essentially that there is no way to adequately provide quality assurance without wrecking the higher education system. Currently, the consensus needed to rely on a qualifications framework or a certification based system is lacking, so only direct government determination and involvement in colleges’ decisions could hope to establish and enforce adequate quality, but this would destroy university autonomy, diversity, and innovation.

If this were the case, it truly would be better to settle for the status quo, since it manages to somewhat limit the extent of diploma mills, doesn’t restrict institutional autonomy as much as direct government involvement would, and is cheap as well. However, this case relies on higher education’s lobbyists successfully fighting off governmental desires for accountability indefinitely, and is therefore unlikely to be a stable outcome, as evidenced by even its defenders descriptions of it as “schizophrenic” and “fragile.” Arguments for the status quo essentially give up on trying to nudge higher education’s ‘establishment’ (headquartered around DuPont Circle in Washington, D.C.) from accepting reforms that are in the national interest even though they might threaten the narrow interests of individual higher education participants.

Given the documented problems and the inherent instability of the current system, it is wise to seriously consider alternatives. Indeed, we believe that accreditation in its current form needs to be abandoned entirely. This conclusion follows from the following observations.

Accreditation Does Not Currently Provide Sufficient Quality Assurance

The first observation that leads us to believe that accreditation is in need of drastic reform is our assessment that it does an inadequate job in providing quality assurance. In their role as gatekeepers, accreditors are supposed to ensure that federal funds are used only at valid educational institutions. To do so, at a minimum, accreditors would need to establish appropriate measures of quality, certify the quality of colleges based on those measures, and provide the public with information on college quality. Accreditation does none of these things. In fact, accreditation lets “each institution or program [establish] its own goals and [select] its own metrics through which to assess them.”clxviii This is analogous to letting drug makers determine if new medicines are safe and effective—the outcome is not guaranteed to be bad, but there is nothing stopping it from being so. The bottom line is that accreditation does not define appropriate measures of quality, does not certify that colleges meet minimum levels of quality, and does not provide enough useful information to the public or policy makers to enable them to hold institutions accountable. It therefore fails to fulfill the quality assurance role that it has been assigned.

Limited Improvement. It would be remiss of us not to mention that accreditation has seen limited improvement along these dimensions in the form of a decline in inappropriate requirements, and a push for the establishment of measures for things like learning outcomes, but the progress has been unsatisfactory. It would also be remiss not to mention why we have seen this limited improvement. Inappropriate requirements have declined due to public reporting of embarrassing policies of accreditors, and the baby steps taken towards requiring student learning outcomes have also been spurred primarily by external pressure, most notably the 1992 and 1998 renewals of the Higher Education Act.

These reforms in theory required accreditors to demand learning outcomes from the nation’s colleges. However, as Leef and Burris document, schools “can satisfy the accreditation criteria by merely showing that they have adopted some program to assess their ‘effectiveness,’ without any independent verification that the program actually works.” They astutely conclude that “simply meeting one’s own goals is not equivalent to an objective demonstration of educational quality.”

Another effort to spur accreditation to examine student learning was launched in 2006 and killed shortly thereafter. As Peter T. Ewell summarizes, in the wake of the Spellings Commission report:

The U.S. Department of Education quickly moved to implement its recommendations on accreditation... First, the department employed negotiated rule making…to require accreditors to set specific ‘bright line’ standards of student achievement… In a second line of attack, the secretary directed the National Advisory Committee on Institutional Quality and Integrity (NACIQI)—the federal body responsible for approving accrediting organizations to act as gatekeepers for federal funds—to be more aggressive in pressing accreditors to examine student learning outcomes against defined objective standards… If fully implemented, the provisions of the 2007 negotiated rule-making process and the new posture of NACIQI would have significantly transformed the accountability role of assessment. But all of this was put on hold in the summer of 2007 when the Senate passed its version of the reauthorization act. Led by Tennessee Senator and former Secretary of Education Lamar Alexander, this bill explicitly prohibited the secretary from pursuing new regulations.

There are also some indications that the limited gains that have been achieved are being reversed, as accreditors again revert to a focus on improvement.

Why Aren’t there Adequate Measures of Academic Quality? Since it is clear that “any serious analysis of accreditation as it is currently practiced results in the unmistakable conclusion that institutional purposes, rather than public purposes, predominate,” we should ask why there are no useful measures of academic quality.

Perhaps it is simply not possible to establish meaningful measures when it comes to learning outcomes. Some argue that “for many [colleges] the student bodies are so different and the set of peer institutions so small that comparisons made for purposes of public accountability would be meaningless or misleading—and potentially harmful. Should these institutions compare their student achievement with that of peer institutions? Yes. Are the comparisons robust enough to be used for public comparisons and accountability? No.” While there is a grain of truth to this line of reasoning, it is undermined by the fact that professors and colleges manage to assess student performance for the purposes of assigning grades and computing GPA’s.

Another possibility is that the reliance on peer review encourages accreditors to ignore their role as gatekeepers, and continue to pursue their traditional role as advisers. Since accreditation is essentially run by the colleges themselves, there is a large dose of self-regulation involved. But “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.” Nor is it surprising that the system is “premised upon collegiality and assistance, rather than requirements that institutions meet certain standards (with public announcements when they don’t).”

Perhaps accreditors are essentially acting as a cartel, seeking to restrict entry into the sector without imposing too much of a burden on existing cartel members. This can be accomplished by defining and enforcing detailed standards that existing members can already meet, such as classroom space and library size, but that new entrants would find prohibitively costly. If this is the case, standards would not be imposed for anything that would impose more costs on existing colleges than on new entrants. While perhaps a bit too harsh, this theory could explain the presence of detail input requirements combined with the complete lack of standards for relatively straightforward things such as the definition of a credit hour and much more complex things such as learning outcomes. Note that the cartel theory does not explain why accreditation requirements continue to expand past the point necessary to keep out new entrants, though a public choice theory offers one plausible reason for that.

Regardless of the reason, the end result is that accreditation fails to deliver on the quality assurance front. We are left with a system that is described as “a hopeless mess,” and the “the Death Valley of the life of the mind.” It is a “crazy-quilt of activities, processes and structures that is fragmented, arcane, more historical than logical… [and one that] is not meeting the expectations required.”

Massive Federal Subsidies Will Continue

The next crucial factor driving our conclusion is that the federal government will continue to massively fund higher education through its financial aid programs. Federal spending for financial aid alone was $117 billion in 2008–2009, almost double what it was a decade ago in real terms.  With many, including the current administration, arguing that the country needs many more college graduates, there is little reason to expect the upward trend in this figure to reverse or cease.

A Different System of Quality Assurance Will Be Forthcoming

Given the fact that the current accreditation system does not provide adequate quality assurance and that the federal government will continue to heavily finance higher education, it seems reasonable to assume that at some point a new quality assurance mechanism will be imposed on higher education. This belief stems from the conclusion that the accountability movement is not a fad, especially in light of the growing public interest in higher education that is to be expected in any industry that is so heavily financed by the taxpayers.

There are legitimate concerns about the quality of higher education. Studies show a decline in student effort, and “employers often complain that the college graduates they hire have little proficiency in the most fundamental skills—the ability to write clearly, to understand written instructions, and to do simple math.” There is a growing desire to determine what students learn and know. But to date, efforts to do so have been blocked by a chorus of colleges and associations asserting that it would infringe on institutional autonomy. While this is a legitimate concern, “It is somewhat disingenuous for higher education to ask for—and receive—billions of federal dollars without expecting concomitant strings, conditions, reporting requirements and other forms of accountability that inevitably accompany appropriations.”

Many in the academy would prefer to maintain the status quo, but the status quo is unsustainable. “The assumption that pressures for change and accountability were motivated solely by partisan politics and would quickly fade with a new party coming to power has proved a very oversimplified view.” Accountability is a bipartisan issue. The public simply will not continue to provide billions of dollars without an adequate answer to the question of what we are getting in return. This is the fundamental driving force behind the accountability movement, and it is extremely powerful. Even the lead lobbyist for colleges felt “compelled to send a wake-up call to campus executives… we should expect college accreditation to come under significant scrutiny.”

Nothing that Resembles Accreditation Can Succeed

Given that a better mechanism of providing quality assurance likely will be installed, we can ask whether the existing system could be reformed or whether an entirely new system should be developed. Our analysis leads us to the conclusion that the current system cannot be reformed to provide the level of quality assurance that is necessary, for the reasons discussed below.

Accreditation Is Structured for Quality Improvement Rather than Quality Assurance Purposes. Accreditation was originally designed to pursue institutional purposes, but not public ones. The public purposes were added to its list of responsibilities haphazardly, and without changing nearly anything else about the system. There remains a high degree of collegiality in the accreditation system, as reviews are still primarily conducted by industry insiders and performed in a fashion that largely mimics that of their predecessors. It would be truly amazing if a system designed to facilitate quality improvement through peer review also happened to be able to provide the public’s accountability needs without fundamentally altering its mechanisms and/or processes. As one former accreditor stated, for accreditation to provide adequate quality assurance, it “will need to integrate into its work aspects of all of the other accountability programs as well as become a respected source of comparative consumer information about the quality of learning in colleges and universities. This is, to put it mildly, a fairly radical reconceptualization of how accreditation works.”

The most glaring example of how the system is biased toward the improvement role is the peer review process. The accreditation process involves a team of accreditors and volunteers reviewing numerous aspects of an institution, and the team relies heavily on a self-study from the institution itself. This may be effective if the goal is merely to provide constructive criticism and suggestions for improvement. However, if the goal is to provide quality assurance for the public, this is much less appropriate. Not only are colleges likely to attempt to hide problems when they are being judged rather than advised, but the peer review process is also subject to a significant conflict of interest. The review “teams cannot reasonably be expected to be independent arbiters of quality. Knowing that their own institutions will undergo accrediting review, there is a tacit interest in keeping standards low.”

In addition to the conflict of interest, there is a question of competence. Accreditors are tasked with providing assurances of college quality, yet “the experience of working in the academy, in itself, is deemed sufficient preparation for review team members to be able to ‘recognize quality.’” In part because of this, university leaders occasionally complain that “there are people out there who are making judgments on institutions without being well-prepared.” Others believe that “the great weakness in college accreditation is that it is sometimes done by people who are less expert than those whom they are supposedly overseeing.”

There are three reasons to suspect that accreditation staff and volunteers may not be up to the challenge of providing adequate quality assurance. First, universities themselves have become more complex, which makes establishing appropriate goals, strategies, and measures of success more difficult. Second, accreditation’s roles have also expanded to include the very different quality improvement and quality assurance roles, and some have reasonably suggested that “relying on volunteers to deliver consistently in these highly-specialized arenas is unrealistic.” Third, the more emphasis there is on compliance based “bean counting,” the harder it is to “recruit innovative, technically active evaluators from industry and research universities.”

There is also the issue of how frequently accreditation reviews occur. Typically, accreditation is granted for a period of 10 years. Even accreditors view this as insufficient, with one commenting that “in one twoday visit every 10 years, we couldn’t assess all aspects of the institution, particularly large comprehensives and major research universities.” While such a long cycle may have been appropriate in the past, when accreditors where more analogous to consultants, that is no longer the case now that they are gatekeepers. “As one observer asks, ‘How can teams of 8 to 20 people (depending on the region) visit a large, complex institution every 10 years for two days of campus interviews and assure that those universities are properly accountable?’” The answer is that it is not possible.

Facilitating Improvement vs. Providing Accountability: An Irreconcilable Conflict. Most of the criticisms of accreditation “flow largely from the fact that higher education accreditation seeks to do two totally different things: ensure a minimum level of quality… and encourage individual colleges to improve themselves.” Because the required tools and temperament of these tasks are so different, there is an irreconcilable conflict between facilitating improvement and providing accountability. “For the improvement paradigm, [there] is a posture of engagement and continuous improvement that seeks to build a culture of evidence… For the accountability paradigm, the predominant posture is one of institutional compliance.” The former paradigm relies on subjective determinations made both internally and externally while the latter is reliant on objective determinations made by external groups.

Already, “The assessment pendulum has swung strongly in the direction of the accountability paradigm,” and this trend is likely to continue. When this happens, it leads to “creeping government controls, legal challenges, and growing tension between a focus on improvement and compliance with government requirements.” Many feel that the quality improvement role is undermined. As one accreditor put it, the emphasis on compliance 

led to institutional fatigue and 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. For smaller institutions, self-reviews often proved quite valuable, but even there the institutional investment was significant, and the question remained whether the value added was worth the investment made.

Sylvia Manning, head of the North Central Association, suggested that with the current accreditation process, “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.”

Thus, when accountability efforts reign, the improvement role suffers. But when the pendulum swings back towards improvement, the accountability role suffers. North Central has created new processes whose “most distinctive feature is that it would clearly separate ‘compliance’ from ‘improvement.’” Western has adopted a similar process, where “as long as you’re making improvement, you won’t get in trouble.” The problem is that “in their efforts to become more flexible, the regionals are abandoning their regulatory function.”

Some believe that it is possible to balance these two or that they are already in balance. But there is little support for that claim. Never in the history of accreditation has accountability been adequately provided, but we have nonetheless nearly wrecked their improvement mission in our futile efforts to squeeze accountability out of an improvement sponge.

Part 4: Our Recommendations

This paper suggests that accreditation is a complex process, trying to serve often incompatible objectives in inefficient ways determined more by historical accident than rational decision making. The system needs to be changed. Below are a few general observations and recommendations. First, any system of accreditation or certification must focus on quality control and improving matches of consumers and producers—matching students to the appropriate institution given their tastes, talents, and financial condition. This means a complete public disclosure not only of accreditation reports, but also of information about student outcomes. It is not unreasonable to have the accrediting authority, whoever that may be, require colleges to provide certain standardized pieces of performance and financial data in a uniform fashion.

Second, the current binary system where schools are either approved (accredited) or not-approved (not accredited) is unacceptable, and should be replaced by a system that provides vastly more indicators of quality in a far more nuanced fashion than the status quo. For example, schools or programs within institutions might receive an accreditation score between 1 and 100, with some pre-determined minimal acceptable level to be considered accredited, but where the numerical score provides additional information enabling consumers to compare institutions, see if they are marginally or solidly acceptable, etc.

Third, the existing accreditation system suffers from other major deficiencies that must be addressed in any reform. Most notably, accreditation today was largely created by institutions themselves to promote institutional self-interest, not the public interest, and this is reflected in conflict of interests between the accreditors and those accredited. Discipline-based accrediting similarly often is viewed by organizations representing various academic specializations as a means of enhancing resource provision for the discipline, rather than serving either institutional or broader public needs.

Fourth, we conclude that the current system is highly flawed and is better replaced than reformed. A replacement system would be far more outcomes-based than current accreditation. For example, a standardized national examination could be administered by respected national testing organizations in individual disciplines to certify competency not only of individuals but of institutions (institutions whose value added to student performance could be denied minimal accreditation approval and, under current arrangements, access to federal funding). In some instances, the examination approach may not work, but alternative approaches using disciplinary-based professional groups are available.

Fifth, given the importance of diversity to the strength of American higher education, the role of a single regulatory authority, most notably the federal government, should be minimized.

Conclusion

Our current system of higher education accreditation is broken. The system is mired in secrecy, delivers imprecise and largely unhelpful information, is clouded by possible currents of self-interest, restricts entrepreneurial initiative, is often costly to administer when all costs are considered, and is not sufficiently outcomes based. It does a poor job of conveying important information to those funding it, including the customers themselves (students) as well as major donors (governments, private philanthropists). Its relevance as a quality control and enhancement device is at best marginal. 

The complete elimination of accreditation is probably not possible or even desirable. For example, someone has to prevent government monies from funding completely fraudulent diploma mills. But this study outlines a series of different approaches to introducing a new system. One approach is clearly rejected: consolidating all accreditation into one government agency. This strikes us as a dangerous and unwise reform, excessively concentrating power and potentially endangering some of the historical strengths that accompany a decentralized higher education system. However, even without radical restructuring of the accrediting agencies themselves, new approaches to the accreditation process could give consumers more practical information on the strengths and weaknesses of institutions (not merely a binary “acceptable” or “non-acceptable” assessment), utilize new methods of ascertaining academic performance (e.g., national standardized tests), and be ultimately governed by persons far removed from those being accredited. In a world with better information (especially on learning outcomes) and transparency, accreditation could become more of a powerful and useful information device and less of an ineffective prescriptive, regulatory device. Market forces could take over some of the disciplining of poor or mediocre institutions in a more effective fashion than the current prescriptive approach suggests. A move in this direction is badly needed and grossly overdue.

References:

1. Robert C. Dickeson, “Recalibrating the Accreditation?Federal Relationship,” Washington DC: Council for Higher Education Accreditation, January 27, 2009.
2. Judith S. Eaton, “Accreditation’s Accidental Transformation,” InsideHigherEd, July 20, 2010.
3. Robert C. Dickeson, “Recalibrating the Accreditation?Federal Relationship,” Washington DC: Council for Higher Education Accreditation, January 27, 2009.
4. Elaine El-Khawas, Accreditation in the USA: Origins, Developments and Future Prospects. Paris, France: International Institute for Educational Planning, 2001.
5. Ibid.
6. James F. Bemis, “Regional Accreditation,” in Understanding Accreditation: Contemporary Perspectives on Issues and Practices in Evaluating Educational Quality, ed. Kenneth E. Young, et. al., Washington, DC: Jossey-Bass Publishers, 1983; El-Khawas, Accreditation in the USA: Origins, Developments and Future; G.C. Leef and R.D. Burris. Can College Accreditation Live Up To Its Promise? Washington, DC: American Council of Trustees and Alumni, 2002.
7. Elaine El-Khawas, Accreditation in the USA: Origins, Developments and Future Prospects. Paris, France: International Institute for Educational Planning, 2001.
8. G.C. Leef and R.D. Burris. Can College Accreditation Live Up To Its Promise? Washington, DC: American Council of Trustees and Alumni, 2002.
9. Peter T. Ewell, “Assessment and Accountability in America Today: Background and Context,” New Directions for Institutional Research, 2008.S1 (Autumn 2008): 7-17.
10. Elaine El-Khawas, Accreditation in the USA: Origins, Developments and Future Prospects. Paris, France: International Institute for Educational Planning, 2001, pp. 60-61.
11. Kenneth E. Young.“The Changing Scope of Accreditation,” in Understanding Accreditation: Contemporary Perspectives on Issues and Practices in Evaluating Educational Quality, ed. Kenneth E. Young, Charles et. al., Washington, DC: Jossey-Bass Publishers, 1983, p. 7.
12. James F. Bemis, “Regional Accreditation,” in Understanding Accreditation: Contemporary Perspectives on Issues and Practices in Evaluating Educational Quality, ed. Kenneth E. Young, et. al., Washington, DC: Jossey-Bass Publishers, 1983,
p. 169; Elaine El-Khawas, Accreditation in the USA: Origins, Developments and Future Prospects. Paris, France: International Institute for Educational Planning, 2001, p. 60–61.
13. Peter T. Ewell, “Assessment and Accountability in America Today: Background and Context,” New Directions for Institutional Research, 2008.S1 (Autumn 2008): 31–32.
14. Elaine El-Khawas, Accreditation in the USA: Origins, Developments and Future Prospects. Paris, France: International Institute for Educational Planning, 2001, p. 45.
15. G.C. Leef and R.D. Burris. Can College Accreditation Live Up To Its Promise? Washington, DC: American Council of Trustees and Alumni, 2002.
16. J.B. Lee and J.P. Merisotis, Proprietary Schools: Programs, Policies, and Prospects, ASHE-ERIC Higher Education Report no. 5, Washington, DC: School of Education and Human Development, The George Washington University, 1990.
17. Barbara Brittingham. “Accreditation in the United States: How Did We Get to Where We Are?” New Directions for
Higher Education no. 145 (Spring 2009), pp. 10–11.
18. Ibid., pp. 14–15.
19. Therese Rainwater, “The Rise and Fall of SPRE: A Look at Failed Efforts to Regulate Postsecondary Education in the 1990s,” American Academic, 2.1 (March 2006).
20. Peter T. Ewell, “Assessment and Accountability in America Today: Background and Context,” New Directions for Institutional Research, 2008.S1 (Autumn 2008).
21. Barbara Brittingham. “Accreditation in the United States: How Did We Get to Where We Are?” New Directions for Higher Education no. 145 (Spring 2009), p. 22.
22.An alternative conclusion is that it was the signaling role that colleges found valuable.
23. Henry C. Mills, “The Effects of Accreditation Procedures,” Journal of Higher Education, 31.6 (June 1960):312.
24. Henry M. Wriston, “The Futility of Accreditation,” Journal of Higher Education, 31.6 (June 1960): 328.
25. Ralph Wolff as quoted in Virginia B. Smith and Joni E. Finney,“Redesigning Regional Accreditation: An Interview with Ralph A. Wolff,” Change, May–June 2008.
26. Robert C. Dickeson, “The Need for Accreditation Reform,” 5th Issue Paper for The Secretary of Education’s Commission on the Future of Higher Education, unknown publication date.
27. Peter T. Ewell, “U.S. Accreditation and the Future of Quality Assurance,” CHEA, 2008.
28. Council for Higher Education Accreditation, “2002–2003 CHEA Survey of Degree-Granting Institutions, Accrediting Organizations, and Higher Education Associations,” The CHEA Chronicle, May 2003.
29. Peter T. Ewell, “Assessment and Accountability in America Today: Background and Context,” New Directions for Institutional Research, 2008.S1 (Autumn 2008).
30. Vickie Schray,“Assuring Quality in Higher Education: Recommendations for Improving Accreditation,” 14th Issue Paper for The Secretary of Education’s Commission on the Future of Higher Education, unknown publication date.
31. Jeffrey C. Martin, “Recent Developments concerning Accrediting Agencies in Postsecondary Education,”
Law and Contemporary Problems, 57.4, Private Accreditation in the Regulatory State, (Autumn 1994), 121–149.
32. Ben Gose, “A Radical Approach to Accreditation,” The Chronicle of Higher Education, November 1, 2002.
33. Beth McMurtrie,“Accreditors Revamp Policies to Stress Student Learning,”The Chronicle of Higher Education, July 7, 2000.
34. G.C. Leef and R.D. Burris. Can College Accreditation Live Up To Its Promise? Washington, DC: American Council of Trustees and Alumni, 2002.
35. Anne D. Neal, “Dis-Accreditation,” Academic Questions, 21.4, (December 2008).
36. Sylvia Manning, as reported by Doug Lederman, “More Meaningful Accreditation,” InsideHigherEd, April 22, 2009.
37. Ralph Wolff as quoted in Virginia B. Smith and Joni E. Finney,“Redesigning Regional Accreditation: An Interview with Ralph A. Wolff,” Change, May–June 2008.
38. Doug Lederman, “More Meaningful Accreditation,” InsideHigherEd, April 22, 2009.
39. Beth McMurtrie,“Accreditors Revamp Policies to Stress Student Learning,”The Chronicle of Higher Education, July 7, 2000.
40. See College Board, “Trends in Student Aid 2009”; Authors calculations
41. Robert C. Dickeson, “The Need for Accreditation Reform,” 5th Issue Paper for The Secretary of Education’s Commission on the Future of Higher Education, unknown publication date.
42. Anne D. Neal, “Dis-Accreditation,” Academic Questions, 21.4, (December 2008).
43. Alan E. Guskin, “Reducing student costs and enhancing student learning,” Change, July–August, 1994.
44. William H. Honan, “Some Say Accreditation Is Out of Control,” The New York Times, November 11, 1998.
45. Vickie Schray,“Assuring Quality in Higher Education: Recommendations for Improving Accreditation,” 14th Issue Paper for The Secretary of Education’s Commission on the Future of Higher Education, 2006.
46. Geoffrey Alderman, “Advice for U.S. on Accreditation,” InsideHigherEd, June 24, 2009.
47. Alan E. Guskin, Reducing student costs and enhancing student learning, Change, July–August, 1994.
48. Robert C. Dickeson, “The Need for Accreditation Reform,” 5th Issue Paper for The Secretary of Education’s Commission on the Future of Higher Education, unknown publication date.
49. U.S. Department of Education. A Test of Leadership: Charting the Future of U.S. Higher Education. Washington , DC: U.S. Department of Education, 2006.
50. Ralph Wolff as quoted in Virginia B. Smith and Joni E. Finney,“Redesigning Regional Accreditation: An Interview with Ralph A. Wolff,” Change, May–June 2008.
51. Vickie Schray,“Assuring Quality in Higher Education: Recommendations for Improving Accreditation,” 14th Issue Paper for The Secretary of Education’s Commission on the Future of Higher Education, 2006.
52. Dewey B. Stuit, “Improved Methods of Accreditation,” Journal of Higher Education, 31.6 (June 1960): 317.
53. Vickie Schray,“Assuring Quality in Higher Education: Recommendations for Improving Accreditation,” 14th Issue Paper for The Secretary of Education’s Commission on the Future of Higher Education, 2006.
54. Anne D. Neal, “Dis-Accreditation,” Academic Questions, 21.4, (December 2008).
55. Barbara Brittingham, “An Uneasy Partnership: Accreditation and the Federal Government,” Change,September–October, 2008.
56. Beth McMurtrie,“Accreditors Revamp Policies to Stress Student Learning,”The Chronicle of Higher Education, July 7, 2000.
57. Ibid.
58. Henry M. Wriston, “The Futility of Accreditation,” Journal of Higher Education, 31.6 (June 1960): 327.
59. George C. Leef and Roxana D. Burris, Can College Accreditation Live Up to Its Promise?, a report from the American Council of Trustees and Alumni, 2002.
60. Ben Gose, “A Radical Approach to Accreditation,” The Chronicle of Higher Education, November 1, 2002