by Dianne M. Cearlock, PhD, Chief Executive Officer
NAACLS recently received a few inquiries regarding external recognition of accreditors by the Council on Higher Education Accreditation (CHEA) and the United States Department of Education (USDE). Fifteen years ago, the NAACLS Board of Directors voted to pursue CHEA recognition and to voluntarily withdraw from USDE recognition. This decision was made following vigorous and substantive discussion by the Board, along with extensive data-gathering by NAACLS on the impact the decision could have on programs and students, and the effects on the NAACLS Standards and policies. Much of the discussion centered on the future direction of accreditation, the impact of accreditors acting as Title IV gatekeepers, and the intersection of NAACLS’ mission with external recognition. (The announcement of the Board’s decision and a review of the discussion and factors involved are available at www.naacls.org in the NAACLS News archives, Volume 74.)
Today, the future direction of higher education accreditation is a much debated topic as Congress takes up re-authorization of the Higher Education Act. The Senate Committee on Health, Education, Labor, and Pensions, chaired by Senator Lamar Alexander (TN), recently released a “white paper” entitled Higher Education Accreditation Concepts and Proposals. A number of emerging issues regarding accreditation are explored in the white paper, but perhaps not surprisingly, many of the factors discussed by the NAACLS Board in 1999 still resonate and have significance today for NAACLS’ mission, standards and policies, and external recognition of NAACLS as an accreditor.
Accreditation is a voluntary, non-governmental process to serve the public by evaluating higher education institutions or programs for the purpose of promoting quality and continuous improvement. The process employs peer review using established standards that are periodically revised for currency and relevancy. Although accreditation is not exclusively American, American higher education has uniquely embraced the process as a means of marrying quality in higher education with innovation while allowing the flexibility for the institution or program to achieve its mission and best serve its particular community. Key elements described in the NAACLS Mission are commitments to public service, quality educational programs, peer review, and promotion of innovation. Recognition of NAACLS by CHEA, though different than accreditation, has similarities. CHEA is the only non-governmental higher education organization in the United States that scrutinizes and affirms the quality of regional, faith-based, career-related and programmatic accrediting organizations. Recognition by CHEA, like accreditation, requires meeting established standards and serves the public by promoting high quality educational institutions and programs.
Recognition of accrediting agencies by the USDE is a little different. With USDE recognition, accreditation must serve a dual role as both a process for the improvement of educational institutions or programs and as “gatekeeper” for federal funds in the form of grants and loans. Beginning with the passage of the Korean War G.I. Bill in 1952 (which stipulated that veterans could use veteran education benefits only at institutions accredited by a federally recognized accrediting body) until now, the federal government has increasingly defined and added to the minimum standards required for governmental (USDE) recognition of accrediting bodies. As illustration (and as described in the “white paper”), the Higher Education Act Amendments of 1992, which defined what accreditors needed to review when determining quality, listed 10 standards that became 28 pages of regulation with 88 pages of sub-regulatory guidance and 93 specific criteria for recognition. It could be strenuously argued that a large portion of that regulation was in support of the gatekeeping rather than quality function of accreditation. Today, many involved in higher education question the wisdom of linking the pursuit of quality in institutions and programs with the gatekeeping functions. (For a brief history of the evolution of accreditation’s role in federal government through “gatekeeping”, please see the “white paper” mentioned above.) With these and other factors in mind, the NAACLS Board in 1999 chose to voluntarily withdraw from USDE recognition(when the period of USDE recognition was to end in 2001) and seek CHEA recognition.
The “white paper” entitled Higher Education Accreditation Concepts and Proposals describes four proposals for consideration in the Higher Education Act reauthorization process to reshape the role of accreditation:
- Refocus accreditation on quality. This proposal points out that many think that accreditation’s role in quality assurance changed over the years from an emphasis on quality to a compliance role not directly related to academic quality. As illustration, USDE recognition of accreditors requires the review of institutions’ or programs’ written plans for maintaining facilities and equipment, facilities and equipment that meet state safety codes, and evidence of compliance with Title IV (gatekeeping of federal loans, grants, and deferments) responsibilities. The current set of regulations requires the collection of much “input” data that does not necessarily translate to the meeting of benchmark outcomes. It should be noted that accreditors are required to review these elements for ALL the programs that they accredit whether programs act as gatekeepers or not. This proposal suggests that freeing accreditation’s responsibilities (and, by extension, its programs) from burdensome regulations may allow accreditors to focus on educational quality and outcomes. When NAACLS was beginning the multi-year process of developing revised and updated standards, the Board of Directors explicitly requested a lesser emphasis on inputs and greater emphasis on outcomes. The 2012 NAACLS Standards clearly reflect that directive.
- Permit flexibility and nuance in accreditation reviews. This proposal makes the case for differentiated reviews of programs. It suggests that for programs with histories of acceptable outcomes and “clean” reviews an expedited review process could be utilized thus freeing the accreditor to spend more time on programs that do not enjoy such histories. The 2012 NAACLS Standards allow a form of this flexibility with the increases in maximum accreditation and approval awards of 10 and 5 years, respectively, for programs meeting certain criteria.
- Encourage gradation, distinction, and clarity in accreditation status and reviews. Accreditation is frequently awarded in a “yes-no” manner with little or no attempt to distinguish between minimal compliance and true excellence. This proposal suggests that the public could benefit from “levels” of accreditation awards such as accredited (meets standards) and accredited with distinction (exceeds standards). At this time, NAACLS does not award gradations of accreditation or approval.
- Delink accreditation from institutional/programmatic eligibility for federal student aid. This proposal states that many believe that accreditation’s gatekeeping role has distorted accreditation’s original purpose and that the gatekeeping role has caused accreditors to be overly prescriptive, intrusive, and to sometimes usurp autonomy and meddle with institutional or programmatic governance and curricular issues. The proposal suggests ending the gatekeeping relationship between federal financial aid and accreditation and allowing accreditors to focus on educational improvement. In 1999, the NAACLS Board of Directors discussed the intersection of accreditation, federal financial aid, and gatekeeping and made the decision to delink NAACLS from gatekeeping responsibilities by voluntarily withdrawing from USDE recognition, thus allowing NAACLS’ focus to remain on improving the quality of programs in the clinical laboratory sciences.
It remains to be seen whether any of the proposals made by the Senate Committee on Health, Education, Labor, and Pensions in the “white paper” become enacted into law. The reauthorization of the Higher Education Act, if previous reauthorizations give us a clue, is likely to be a multi-year process with numerous opinions expressed and debated. It is also undeniably a political process that is likely to be affected by the 2016 elections. Recent trends in USDE recognition could continue, change dramatically, or fall somewhere in between. The NAACLS Board of Directors will continue to monitor the reauthorization process and the implications for NAACLS, its programs, and external recognition. NAACLS stresses public service, quality educational programs, and the promotion of innovation in its mission. That mission will continue to guide the Board in its decision-making regarding external recognition.