by Dianne M. Cearlock, PhD, Chief Executive Officer
The year 2015 was notable as a period during which higher education accreditation was the target of criticism by the federal administration and lawmakers. While the criticisms were focused on regional or national accreditors of institutions, particularly those with “gatekeeping” privileges relative to student loans and grants, programmatic accreditors also felt the sting.
To review, NAACLS is a programmatic accreditor that accredits or approves post secondary programs in nine clinical laboratory careers. NAACLS is recognized (akin to accreditation) by the Council on Higher Education Accreditation (CHEA) but not by the U.S Department of Education (USDE). Withdrawing from USDE in favor of CHEA recognition occurred in 2001 when, after deliberation, the NAACLS Board of Directors decided that the regulatory burden of USDE recognition was becoming prohibitive and that the commitment of CHEA to education innovation better matched the character and needs of programs in the clinical laboratory sciences. With that change, NAACLS relinquished status as a “gatekeeper” for federal student loans and grants and was awarded recognition by CHEA.
As the costs of obtaining post secondary degrees or certificates has risen, the problem of mounting defaults on student loans has risen and has drawn increasing attention from the federal administration and lawmakers. Some college graduates have had difficulty obtaining employment that not only pays the bills for day-to-day living but also allows them to pay off their loans, and this problem was exacerbated by economic recession. Members of the public expressed concerns to lawmakers about the high costs of higher education when the “payoff” seemed too small compared to the time, effort, and expense of obtaining a higher education degree.
Increasingly the discussion of “quality” in higher education became solely focused on student outcomes in terms of employability and job placement. Legislators viewed regional and national accreditors as regulators of educational quality and, by extension, of the graduation rates of students and job success (or not) of graduates. And often their conclusion was that regional accreditors were failing in this role by continuing to accredit institutions with poor graduation and placement rates. This summer while calling for greater focus on student outcomes in higher education, Education Secretary Arne Duncan called institutional accrediting agencies “the watchdogs that don’t bark.” A particularly striking example cited by Under Secretary of Education Ted Mitchell was the crisis earlier this year of the Corinthian Colleges for-profit college chain that was still accredited by a national accreditor on the day it called USDE announcing its intention of filing for bankruptcy.
In October, the Obama administration announced plans for a new executive action on higher education accreditation to force accreditors to focus more on student outcomes when evaluating the performance of colleges and universities. On the campaign trail, Senator Marco Rubio called accreditation “a cartel” stating that “our higher education system is controlled by what amounts to a cartel of existing colleges and universities, which use their power over the accreditation process to block innovative, low-cost competitors from entering the market.” Scrutiny was aimed at how to regulate low-cost alternative ways of offering and obtaining job training/education such as Massive Open Online Courses (MOOCs) and other innovations, with traditional institutions and accreditors sometimes perceived as turf-protecting and resistant to change.
Various regional and national accreditors have reacted to these criticisms with at least nominal agreement that more focus should be trained on student outcomes to document educational quality, but there is not necessarily consensus as to how to define “quality” or what student outcomes are the most indicative of quality. Some regional and national accreditors appear to be receptive to devising strategies for the evaluation of the newer non-traditional methods of education delivery and even developing different forms of recognition for these educational offerings. As might be expected, though, there is skepticism as to the wisdom and efficacy of more federal regulation and control over post secondary education in the United States. A hallmark of the unique nature of accreditation in the U.S. has been the peer review process and the separation of federal bureaucracy from higher education. As well, accreditors have expressed concerns about a narrow definition of quality that appears to value only outcomes related to graduation and job placement rates and the ability of graduates to pay off their loans. These objections have sometimes been perceived as resistance to demonstrating accountability. Thus, federal government and accreditors are not necessarily on the same page and appear to be experiencing their winter of discontent.
Where is NAACLS positioned on these issues? From the NAACLS mission statement: “NAACLS provides leadership in fostering innovative educational approaches… is dedicated to peer review as the foundation of accreditation and approval… and demonstrates commitment to public service by setting standards for education programs of high quality in clinical laboratory sciences and related health professions. NAACLS will continue to be responsive to the needs of the public and the health care community.”
When revising the NAACLS Standards, adopted in 2012, the task force that was appointed to draft the Standards was charged with placing greater emphasis on student outcomes and reducing the “inputs” that programs must document. A key impetus of this shift was to foster creativity and innovation in the development and delivery of education by NAACLS programs across a spectrum of nine professions and a great variety of sponsoring institutions, their missions, and the stakeholders they serve. NAACLS’ dedication to peer review is reflected in the processes in place for program review. Self study reviews, site visits, and developing recommendations for accreditation and approval awards are all conducted by peer volunteers. NAACLS responsiveness to the public and the health care community are achieved by the commitment to quality education and respect for sponsoring institutions’ unique missions and the populations they serve. The Standards must be met for a program to be awarded accreditation or approval but NAACLS acknowledges that one size does not fit all.
The definition of quality, however, is not a one-note tune. Without doubt, graduate employability is a critical component for the achievement of quality. NAACLS has established benchmarks for student outcomes including certification pass rates, graduation, and placement rates. Failure of a program to meet the benchmarks triggers a requirement for an improvement plan which is then reviewed by peers. Peer feedback about the plan is provided to the program. Failure to meet benchmarks does not automatically trigger citations during the review process or result in accreditation probation or withdrawal. A key reason for this is that NAACLS is committed to program quality and continuous improvement and not merely regulation.
Achieving and documenting quality is so much more than a policing activity. Compliance with Standard II.A requires that programs establish missions and goals and systematic plans for self evaluation. These are unique to each program and its community. Standard II.B, in addition to the benchmarks already discussed, also requires documentation of attrition rates. Programs are encouraged to provide documentation of other measures of quality such as results of capstone projects, faculty feedback, exit or final examinations, exit interviews with graduates, student and graduate professional leadership, and impact of the program on local and regional healthcare. These measures are also unique to programs. Outcome measures must include feedback from students and graduates thus assuring input from stakeholders. Lastly, the results of assessment activities must be analyzed to demonstrate program effectiveness and reflected in decision-making and modification, when needed.
These requirements help programs to continuously change and improve, processes that NAACLS values and that keeps programs vibrant and able to consistently provide quality education for students. Graduates of quality programs are likely to earn professional credentials and successfully compete for relevant employment positions. That in turn helps serve the healthcare needs of the community.
The definition of quality is clearly not a one-note tune nor is accreditation merely a regulatory activity. While the federal government and regional accreditors experience their winter of discontent and those discussions continue, NAACLS stands by its mission, vision, and values.