Higher Education Accreditation

A Background Primer

To understand higher education accreditation in the United States it is important to appreciate the values and beliefs that underlie it. The Council for Higher Education Accreditation (CHEA), the primary association and advocate for higher education accreditation and quality assurance in the United States, defines five core values of the American accreditation system:

Accrediting agencies and associations have developed criteria and standards based on these core values that serve as the foundation for the current system of accreditation. Member institutions must meet these standards to become and remain accredited. From these core values also flow the purposes and uses of accreditation. Serving both as a measure of quality and as a tool for continuous improvement, accreditation performs a variety of functions, including:

A Short History of Higher Education Accreditation and the Federal Government

As the number of educational institutions grew in the 1800s, it became increasingly difficult to distinguish between secondary schools, colleges, and their respective educational offerings.  Since at that time there was little government oversight of higher education, in various areas of the country, colleges and universities created voluntary, non-governmental organizations to provide standards for distinguishing themselves from secondary schools. The first of these organizations to form was the New England Association of Colleges and Secondary Schools in 1885.With with the founding of the Western Association in 1923, the nation was fully covered by six “regional accreditors,” each tasked with accrediting colleges and universities in their respective regions.

Although accreditation had existed in higher education since the late 1800s, the federal government had no interest in the process until the early 1950s. Prior to that time, the federal government provided limited financial assistance to institutions of higher education. However, beginning with the passage of the GI Bill in 1944 and continuing with the passage of the National Defense Education Act of 1952 and the Higher Education Act of 1965, the federal government increasingly began providing financial support for higher education. As federal financial support for higher education grew, so too did the interest of the government in preventing federal funds from going to little to no-quality providers of postsecondary education.

Beginning with the passage of the Veterans’ Readjustment Act of 1952 (also known as the Korean G.I. Bill), Congress determined it needed a system for ensuring some basic level of quality for institutions receiving federal dollars.  To meet this need, the federal government turned to the already existing system of accreditation to serve as the quality check for the flow of federal funds. This private, voluntary, non-governmental system of accreditation was the preferred choice of both the federal government and institutions of higher education. Using a non-governmental, private actor obviated the need for the federal government to oversee and judge the quality of institutions of higher education directly, something that would have been anathema to higher education, a community highly suspect of government intervention.

Under the Veterans’ Readjustment Act of 1952 the then U.S. Commissioner of Education was authorized “to publish a list of nationally recognized accrediting agencies and associations which he determines to be reliable authority as to the quality of training offered by an educational institution…”[3] This list was used by state approval agencies to determine the schools at which veterans could use their GI education benefits. When the federal government began providing financial support for college to students beyond veterans, Congress continued to rely on accreditation as a basic quality check for receipt of federal funds.[4]

With passage of the Higher Education Act of 1965, Congress deemed as eligible for federal funding an institution of higher education that was “accredited by a nationally recognized accrediting agency or association or, if not so accredited, is an institution whose credits are accepted, on transfer, by not less than three institutions which are so accredited, for credit on the same basis as if transferred from an institution so accredited.”[5],[6]  Carrying over this accreditation eligibility criteria into subsequent reauthorizations of the Higher Education Act, Congress cast the voluntary system of accreditation into the role of primary gatekeeper for federal funds to higher education. Although over the years Congress has added additional institutional eligibility criteria (e.g., standards for fiscal responsibility, cohort default rates) for access to student loans and grants under Title IV of the Higher Education Act, accreditation remains the key eligibility criterion for federal funding. 

The National Advisory Committee on Institutional Quality and Integrity

Although the federal government does not accredit institutions of higher education directly, it does approve accrediting agencies that it determines to be a “reliable authority” on the quality of the education or training provided by the institutions that they accredit.  In 1968, the Commissioner of Education created the Accreditation and Institutional Eligibility Advisory Committee to assist the federal government in developing criteria to review accrediting agencies and in designating accrediting agencies under the Higher Education Act. This advisory committee is today known as the National Advisory Committee on Institutional Quality and Integrity (NACIQI).

The functions and mission of NACIQI are laid out in the Higher Education Act. Specifically, NACIQI is to advise the Secretary of Education regarding:

Over the years, Congress has stipulated specific criteria in statute relating to the standards that NACIQI and the U.S. Department of Education must establish for recognizing an accrediting agency as a reliable authority on quality. In addition to specifying that accrediting agencies must have standards related to student achievement, faculty, finances, and facilities, the Higher Education Act also lays out required procedures for operations and the affording of due process to accreditors’ member institutions.[8]

NACIQI consists of eighteen members.[9] The Speaker of the U.S. House of Representatives appoints six members, the President pro tempore of the Senate appoints six members, and the Secretary of Education appoints six members.[10] Prior to the passage of the Higher Education Opportunity Act of 2008, NACIQI was a fifteen-member advisory committee with the Secretary of Education appointing all its members.  As required by statute, NACIQI meets not less than two times per years. Meetings are typically held in the spring and the fall and are open to the public.[11]

In addition to receiving recognition from the U.S. Department of Education, the Council for Higher Education Accreditation (CHEA), a private non-government organization, also reviews and recognizes accreditors. CHEA was formed in 1996 by college and university presidents to “serve students and their families, colleges and universities, sponsoring bodies, governments, and employers by promoting academic quality through formal recognition of higher education accreditation bodies” and to “coordinate and work to advance self-regulation through accreditation.”[12]  Though many accreditors are recognized by both the U.S. Department of Education and CHEA, for purposes of student financial assistance, it is only recognition by the U.S. Department of Education that counts.

The Process of Accreditation

Standards are at the core of the accreditation process. As accreditation is a voluntary, member-driven process, the standards for accreditation are developed and established in collaboration between the accreditors and their member institutions. To be accredited, an institution agrees to submit to the standards of its accreditor. Although standards are established and agreed to by accreditors and their member institutions, to be recognized as an accreditor by the U.S. Department of Education, Congress has stipulated in federal statute that the standards must assesss an institution’s:

Additionally, for institutions offering distance or correspondence education, the Higher Education Act mandates that accreditors have standards that require institutions to verify that students who enroll for a course are the same students who complete and receive credit for the course. [14]

After receiving initial accreditation, institutions must be reevaluated for reaccreditation on a cycle of every few to every ten years based upon their accreditor and the type of accreditation. Additionally, over the course of an institution’s accreditation, accreditors continually monitor their member institutions.

As a membership organization, the activities of accrediting agencies are financed through annual membership dues that member institutions pay, as well as through fees assessed on institutions for the cost of the accreditation review.

The Evaluation Process

The key components of the accreditation evaluation process are:

Below is a one-year snapshot of accreditation judgments made by accrediting agencies in the year 2010-2011.[15]

Formal Accrediting Actions, 2010-2011

Types of Accreditors

Over the years, two types of accreditors have evolved – institutional accreditors and specialized/programmatic accreditors. Institutional accreditors evaluate institutions as a whole, determining, among other things if an institution has adequate administrative, fiscal, and human capacity to carry out its mission and goals. While an institution’s offerings in and oversight over its individual departments and schools are reviewed during the course of institutional accreditation, such academic departments and schools are not individually and separately reviewed.

Specialized or programmatic accreditors, on the other hand, evaluate a particular school, department, or program typically related to a given profession or vocation, e.g., medicine, law, funeral services, massage therapy. Although a number of states require students to graduate from a particular program with specialized accreditation for licensing purposes (e.g., medical school), for purposes of Title IV eligibility under the Higher Education Act, it is institutional accreditation that is the key.

Institutional Accreditors

There are two types of institutional accrediting agencies in the United States – regional accreditors and national institutional accreditors. Regional accreditors primarily accredit public and private nonprofit degree-granting institutions, though they do accredit a number of for-profit institutions as well. Among the national institutional accreditors are two broad types: (1) national career-related accreditors which mainly accredit for-profit career colleges and non-degree granting institutions, and (2) national faith-related accreditors which mainly accredit nonprofit religious and doctrinally-based institutions.

**Institutional Accreditation by Type of Institution[16]**

Currently, there are nine regional accrediting agencies and eleven national institutional accreditors. In addition to the regional accreditors, the New York Board of Regents is authorized under the Higher Education Act to serve as an institutional accreditor for Title IV purposes. New York is the only such state government agency authorized under law to serve in this capacity. The following institutional accreditors are recognized by the U.S. Department of Education:

More detailed information on the scope of recognition for each of the recognized institutional accreditors can be found at the end of this report.

Institutional Accreditors, Institutions, and Students, 2010-2011

In 2010-2011, 7,818 institutions of higher education were accredited. Regional accreditors accredited 3,050 institutions and national accreditors accredited 4,768 institutions. Although the national accreditors accredit more schools than the regional accreditors, the majority of students in the United States enrolled in accredited institutions are enrolled in regionally accredited institutions--in 2010-2011, of the over 24 million students enrolled in accredited institutions, 20.5 million were in schools with regional accreditation. The following charts provide information on the number of institutions accredited by each of the institutional accreditors and the number of students enrolled in those institutions.

 

Specialized/Programmatic Accreditors

Specialized or programmatic accreditors evaluate a particular school, department, or program typically related to a given profession or vocation. Specialized accreditors review a variety of fields from the arts and humanities (e.g., art, music, theater, dance), to personals services such as massage therapy, and to a number of health care related vocations (e.g., nursing, physical therapy, medicine).

For purposes of eligibility for Title IV grants and loans, only institutional accreditation is required. However, in a few cases a programmatic accreditor may also serve as an institutional accreditor in the case of a specialized or vocational institution that is freestanding and whose operations are wholly separate and independent from any other accredited institution with a broader educational mission and offerings.

In addition to recognizing accreditors for purposes of Title IV of the Higher Education Act, the U.S. Department of Education also recognizes programmatic/specialized accrediting agencies for purposes of participation in programs administered by other federal agencies.[17] For example, to participate in certain loan programs administered by the U.S. Department of Agriculture, students must have graduated from a veterinary school accredited by the American Veterinary Medical Association. For that reason the U.S. Department of Education also recognizes a number of programmatic accreditors whose accreditation is required for federal purposes outside of Title IV of the Higher Education Act.

The following specialized/programmatic accreditors are currently recognized by the U.S. Department of Education:

More detailed information on the scope of recognition for each of the recognized specialized/ programmatic accreditors listed above can be found at the end of this report.

In addition to the specialized/programmatic accreditors listed above that are recognized by the U.S. Department of Education, there are other specialized/programmatic accreditors recognized by the Council for Higher Education Accreditation (CHEA). Most accreditors recognized by the U.S. Department of Education are also recognized by CHEA. However, some programmatic accreditors are recognized solely by CHEA. By law, the Secretary of Education may only recognize agencies and associations that accredit institutions or programs that are required to be accredited under the Higher Education Act or another federal statute.[18] Thus, some programmatic accreditors, though they might want, may not be recognized by the U.S. Department of Education by law. Examples of these specialized accreditors recognized only by CHEA include the Accreditation Council for Business Schools and Programs and the American Library Association Committee on Accreditation.

Current and Emerging Issues in Accreditation

As the cost of college has skyrocketed and as the federal government’s investment in student aid has increased dramatically, rising to $174 billion last year alone, policymakers and others have begun to ask what students, the government, and taxpayers are getting for such a large investment. Although many indicators point to the United States as a leader in higher education research and innovation, other indicators paint a less stellar picture of performance. Annual government statistics indicate that less than 60 percent of students who start a bachelor’s degree program  complete a degree within six years, and for low-income, minority, and non-traditional students these six-year completion rates are even lower. Additional surveys and studies also indicate that in many instances students learn very little while they are in college.[19]

Since these statistics represent students attending accredited institutions, some have asked what accreditation is doing to ensure academic quality.  Given accreditation’s role as the “gatekeeper” for the federal student aid system, the system’s ability or inability to ensure a basic level of quality is of concern to many.

As the primary criterion for federal funds eligibility, it is well accepted that the loss of accreditation is more than just a loss of a simple designation.  In the overwhelming majority of cases, an institution’s loss of accreditation would result in forced closure since few institutions could afford to operate without federal funding. For this reason, some argue that accreditors rarely remove accreditation from a member institution. Policymakers, also understanding the repercussions of the loss of accreditation, have built into law a series of due process requirements that accreditors must afford an institution prior to the loss of accreditation. Often these measures result in years of delay in administrative action, even for schools providing little to their students. Because of these tendencies towards inaction, some have argued that the only way for accreditation to serve as a real means for quality control and improvement is to sever the tie between accreditation and eligibility for Title IV funds. [20] Most in higher education, however, oppose severing the accreditation-Title IV tie fearing the system the federal government might put in its place as a quality gatekeeper for federal funds.

Additionally, over the years many have argued that the peer-review model and membership-driven basis of accreditation in the United States is rife with conflicts of interest thus stymying any true quality control efforts. Further, for most of its history accreditation has been a process carried out primarily behind the scenes with little transparency and understanding for the public. 

Recognizing growing public concern over accreditation and quality, two high-profile reports have recently been issued for improving accreditation and addressing many of the complaints raised about the current system.  In April 2012 NACIQI, at the request of the Secretary of Education, released a report entitled Higher Education Act Reauthorization: Accreditation Policy Recommendations. [21] Later that year, the American Council on Education’s National Task Force on Institutional Accreditation issued Assuring Academic Quality in the 21st Century: Self-Regulation in a New Era.[22] While both reports recommend retaining the accreditation-Title IV link, the two reports do make make other recommendations including:

It remains to be seen how many of these recommendations for improvement will be made to the U.S. system of accreditation. Any changes to federal law and accreditation are most likely to be made during the next reauthorization of the Higher Education Act. Although that Act is scheduled to be reauthorized in 2013, almost all federal education statutes are now many years behind schedule for reauthorization.  Nevertheless, in the absence of reauthorization, a number of changes to accreditation can still occur outside of changes to federal law. As just one example, to address the concerns about lack of transparency in accreditation, the Western Association of Schools and Colleges- Senior Colleges and Universities now posts all its institutional accreditation reports on its website.

Appendix A: Institutional Accreditors Currently Recognized by the U.S. Department of Education

 

Appendix B: Specialized/Programmatic Accreditors Currently Recognized by the U.S. Department of Education

 

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[1] Adopted from An Overview of U.S. Accreditation by Judith Eaton, The Council for Higher Education Accreditation. Retrieved from http://www.chea.org/pdf/Overview%20of%20US%20Accreditation%202012.pdf and Accreditation and Recognition in the United States by Judith Eaton. Retrieved from: http://www.chea.org/pdf/AccredRecogUS_2012.pdf.

[2] Adopted from An Overview of U.S. Accreditation by Judith Eaton, The Council for Higher Education. Retrieved from http://www.chea.org/pdf/Overview%20of%20US%20Accreditation%202012.pdf & The U.S. Department of Education, College Accreditation in the United States. Retrieved from http://www2.ed.gov/admins/finaid/accred/index.html.

[3] Veterans’ Readjustment Act of 1952, Pub. L. No. 82-550, §253.

[4] The National Defense Education Act of 1958, Pub. L. No. 85-864, often considered the predecessor to the Higher Education Act of 1965, was the first federal statute to provide financial support beyond veterans to attend higher education.

[5] Higher Education Act of 1964, Pub. L. No. 89-329, §801.

[6] The provision allowing an unaccredited institution whose credits were accepted for transfer by at least three accredited institutions to be eligible was dropped in the 1992 reauthorization of the Higher Education Act. However, there are allowances in the statute that allow for new institutions with provisional accreditation from a recognized accrediting agency to qualify for Title IV student aid.

[7] Section 114(c) of the Higher Education Act.

[8] Section 496 of the Higher Education Act lays out the criteria for federal recognition of accrediting agencies.

[9] The current membership roster for NACIQI can be accessed at: http://www2.ed.gov/about/bdscomm/list/naciqi.html.

[10] Section 114(b) of the Higher Education Act. Of the 6 members appointed by the Speaker of the House of Representatives, 3 are to be appointed on recommendation by the House Majority Leader and 3 are to be appointed on recommendation by the Minority Leader. Similarly, of the 6 members appointed by the President pro tempore of the Senate, 3 are to be appointed on recommendation by the House Majority Leader and 3 are to be appointed on recommendation by the Minority Leader

[11] The webpage for NACIQI (http://www2.ed.gov/about/bdscomm/list/naciqi.html) contains information related to upcoming meetings and information on past meetings including transcripts from those meetings.

[12] Council for Higher Education Accreditation Mission Statement. For more information on CHE’s policies and procedures for recognizing accrediting agencies see: Recognition of Accrediting Agencies and Associations: Policy and Procedures by the Council for Higher Education Accreditation. Retrieved from http://www.chea.org/pdf/Recognition_Policy-June_28_2010-FINAL.pdf.

[13] Section 496(a)(5) of the Higher Education Act.

[14] Section 496(a)(4) of the Higher Education Act.

[15] Data from CHEA Almanac Online, 2011-2012. Retrieved from http://www.chea.org/2011-2012%20Almanac%20Online/index.asp

[16] Data from CHEA Almanac Online, 2011-2012. Retrieved from http://www.chea.org/2011-2012%20Almanac%20Online/index.asp

[17] Section 496(a)(2) of the Higher Education Act.

[18] A directory of all CHEA recognized accreditors may be accessed at: http://www.chea.org/pdf/2012_2013_Directory_of_CHEA_Recognized_Organizations.pdf.

[19] See for example Richard Arum and Josipa Roksa, Academically Adrift (Chicago: University of Chicago Press, 2011) and Mark Kutner, Elizabeth Greenberg, and Justin Baer_, A First Look at the Literacy of America’s Adults in the 21st Century_ (Jessup, MD: National Center for Education Statistics, 2005) http://nces.ed.gov/NAAL/PDF/2006470.PDF.

[20] See Alternative to the NACIQI Draft Final Report by Anne Neal and Arthur Rothkopf. Retrieved from http://www2.ed.gov/about/bdscomm/list/naciqi-dir/2012-spring/teleconference-2012/naciqi-final-report.pdf.

[21]Report to the U.S. Secretary of Education: Higher Education Act Reauthorization Accreditation policy Recommendations by the National Advisory Committee on Institutional Quality and Improvement Retrieved from http://www2.ed.gov/about/bdscomm/list/naciqi-dir/2012-spring/teleconference-2012/naciqi-final-report.pdf.

[22] Assuring Academic Quality in the 21st Century: Self-Regulation in a New Era by the ACE National Task Force on Institutional Accreditation. Retrieved from http://www.acenet.edu/news-room/Documents/Accreditation-TaskForce-revised-070512.pdf.

[23] The Western Association of Schools and Colleges – Senior Colleges now posts all its accreditation reports on its website. WASC-Senior is the first of the regional accreditors to have done so.