Peer Review Under Fire?

The critics like to call it “the fox guarding the henhouse” while we in the accreditation business like to call it “peer review.” It is a long-standing cornerstone of our accreditation system that has always been a “given.” But it has come under increasing scrutiny in recent years.

The news earlier this week of the “sudden departure” of Albert Gray, the leader of ACICS, cannot have come as a surprise to anyone who has been following developments in higher education. ACICS – the Accrediting Council for Independent Colleges and Schools – is the institutional accreditor that oversaw so many of the troubled for-profits, most notably, the 91 campuses of the now defunct Corinthian Colleges, Inc.

In a grilling by Senator Elizabeth Warren (D, MA) last summer, Dr. Gray tried to defend the lack of action on the part of ACICS even as complaints, charges of fraud and investigations into Corinthian were mounting. He noted that the accreditor could do little in the face of unproven allegations. I felt some sympathy for him because we often face that challenge of balancing due process for our programs with our duty to protect students.

Nonetheless, earlier this month a letter went to the US Department of Education from a dozen state attorneys general calling on the Department to revoke its recognition of ACICS, a move that would cut off access to federal funding for thousands of students in hundreds of institutions accredited by the embattled agency.

In that letter, the state attorneys general focused, among other things, on the composition of ACICS’ board and committees, saying that its leadership raised “serious questions about potential conflicts of interests and therefore ACICS’ ability to impartially evaluate those and other schools.” In a recent report by Pro Publica, it was noted that “at least two-thirds of ACICS’ commissioners since 2010 have worked as executives at for-profit colleges while sitting on the council. And at least one-third of the commissioners came from colleges that faced heightened scrutiny, including investigations by state attorneys general and federal financial monitoring.” In other words – peers!

While this brouhaha is over federal funding and institutional accreditation, we have all heard the charges often lobbed at programmatic accreditors – “the guild” out to promote its own professions rather than assure quality programs. But a recent video produced by the Council for Higher Education Accreditation (CHEA), a series of interviews with college presidents, reinforces how deeply ingrained is the principle of peer review [ http://www.chea.org/videos/AccredIntvSeries-Presidents-and-Chancellors.asp]. It is our duty to demonstrate through our own processes that we are, in fact, in the business of quality assurance, which happens to be best assessed by the experts in the professional discipline – the peers!

And the Beat Goes On - Accreditation Under Fire Again, Yet, Still

These days it seems as if everyone in Washington - from the White House to the Congress to the many "think tanks" - have ideas about how to improve, expand, amend or abolish accreditation! A recent "ASPA Digest" from the Association of Specialized and Professional Accreditors did an admirable job of summarizing much of what is currently going on. For anyone involved in higher education and accreditation, it is well worth the time to read. For your convenience, here is a link to the document: ASPA Digest January 29, 2016

What Price Quality?

There has been a lot of press lately about the skyrocketing cost of higher education (and the corresponding rise in student debt). One of the “culprits” that proponents of deregulation love to point to is the burdensome expense of regulation. This issue was brought to the forefront earlier this year when the Chancellor of Vanderbilt University testified before Congress that Vanderbilt spends $11,000 per student on complying with federal regulations and accreditation costs.

That figure was immediately picked up and cited over and over again by anti-regulation folks in Congress.  Senator Lamar Alexander (R-TN), in an op-ed piece in the Wall Street Journal said, “In one year Vanderbilt University spent a startling $150 million complying with federal rules and regulations governing higher education, adding more than $11,000 to the cost of each Vanderbilt student’s $43,000 in tuition." The implication, of course, is that if the federal regulatory burden went away, Vanderbilt’s tuition would be reduced by $11,000 per student. But it isn’t quite that simple!

In an article posted on August 3, 2015, InsideHigherEd.com pointed out at least one major flaw in the numbers being cited by Vanderbilt:

“Of the $146 million the university spent that year on compliance, according to its calculation, $117 million went toward complying with research regulations. Research at a major institution like Vanderbilt – which received $473 million in federal funds for research in 2013 and is one of this biggest conductors of federal research in U.S. higher education – is mostly faculty driven. And the federal government picks up part of the tab for compliance, with additional funding to cover the overhead costs of university research.”

Now comes a follow-up study that expands on the one cited earlier this year. This one looked at data from 13 institutions and through extrapolation, it concludes that collectively they spend $27 billion a year complying with federal regulations. Of course that $27 billion is the headline but when totals for research activities and other federal regulations governing all businesses get subtracted, what remains ($11.1 billion) is said to be specific to complying with federal regulations related to higher education and is estimated to include $6 billion for accreditation – $3 billion for regional and $3 billion for programmatic.

Of course this new report is already causing controversy and the numbers will be “sliced and diced” as the political battle between pro and anti regulation proponents unfolds. But any way you look at it, there’s no question that regulation and accreditation cost money. But rather than looking just at costs, it will be important that policy makers look also at the benefits. And it will be our job to make sure that they understand the value of quality assurance through accreditation.

“Establishment Goes Alternative”

That was the title of an interesting article which I urge you to read in the August 14, 2015 issue of Inside Higher Ed (www.insidehighered.com). The article was reporting on a “new prototype” of education that is a joint effort of seven “brand-name universities.”

While recent years have seen all kinds of prototypes using competency based education, online learning, direct assessment and the ever-popular MOOCs, one of the things that makes this effort stand apart is the breadth and the prominence of the entities involved. The Georgia Institute of Technology, Northwestern University, the University of Washington, the Davis,  Irvine and Los Angeles campuses of the University of California and the University of Wisconsin have all joined together to form what they are calling the “University Learning Store.” The dean of continuing education, outreach and e-learning at the University of Wisconsin Extension describes it as an idea to “create an alternative credentialing process that would provide students with credentials that are much shorter and cheaper than conventional degrees.” These “microcredentials” could be in “soft skills” such as communication or critical reasoning, or in more technical areas. They could be earned by entry-level employees or even by senior level folks who want to improve their knowledge/skills in a particular area such as budgeting.

As I read this article, I couldn’t help but be struck by the fact that this concept makes accreditation irrelevant. They anticipate that these credentials would be cheap enough that financial aid wouldn’t be necessary – thus eliminating that need for Title IV eligibility that comes with institutional accreditation. There is one reference to the fact that it “is not clear at this point whether the project would pursue credit bearing credentials [because] that would require accreditation approval, which can be labor intensive to secure.”

Of course, none of these innovative efforts will have much impact on allied health education any time soon. Licensure and certification requirements alone make it difficult to think about “microcredentials” or other such massive changes to the way we educate our entry-level workforce.

But this is yet another indication of the current state of higher education and the issues we are all facing. Employers are telling us that they need a better trained workforce, students (and parents) are telling us that the cost of a college degree is too high, resulting in crippling debt, and federal policy makers of both parties are telling us that they are determined to make changes.

This is a good time for CAAHEP to be launching its Public Policy Committee and our planned activities to both educate policy makers and to keep our communities of interest informed about these critical issues. Stay tuned…

 

Accreditors Breathe a Sigh of Relief!

Most of you probably remember the news from January 2014 when a federal judge in Virginia took it upon himself to substitute his own judgment for that of the accrediting body in an appeal of denial of accreditation. Not only did he overturn the denial, he also slapped the accrediting agency with damages of more than $400,000.

The case could have been the first episode in a new reality series “Accreditors Behaving Badly” as there did seem to be some serious issues with how the staff and volunteers of the accrediting agency had dealt with the institution and its appeal. Nonetheless, the judge went further than any court had ever gone before, even second guessing “vague” Standards and making his own judgments about an institution in what is supposed to be a “peer review” process.

But last week a Federal Appeals Court reversed that lower court decision when it ruled that the judge at the lower court level had wildly overreached. The Appeals Court noted that the lower court had essentially conducted its own trial rather than focusing upon the procedural fairness which should have been the limit of an appeal. Judge J. Harvie Wilkinson III wrote the decision for the U.S. Court of Appeals for the 4^th Circuit and said, in part, “…the district court was remedially aggressive not only in its awarding of a large amount of damages, but also in ordering that the institution in question be reaccredited, thereby overturning the judgment and expertise of an agency that in this case rested on a sound and supportable basis.”

This is an important legal victory because it upholds previous case law that has established a “hands off” approach by courts when it comes to second guessing the professional judgment of accrediting agencies. But even as we celebrate, we should not forget some important lessons to “take away.” Namely, accreditors have a responsibility to remain objective and impartial (no matter how frustrated they may become with a particular program or institution). And we must ALWAYS, ALWAYS follow our published policies and procedures in a consistent manner. Hopefully there won’t be any more episodes of “Accreditors Behaving Badly.”