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.”

More Hot Topics in Higher Ed

Submitted by Thomas Skalko, PhD, LRT/CTRS, CAAHEP President

Other hot topics shared during the  Association for Specialized and Professional Accreditors (ASPA) meeting were proposals that are being discussed including a proposal by the Administration for rating colleges and universities on quality and value of an education; the use of gainful employment as a variable in the programmatic accreditation process; the implementation of competency-based innovations in education; and proposals to create state level alternative institutional accreditation options.  There seem to be a host of items on the radar with regard to higher education accreditation that impact both institutional and programmatic accreditors.  For programmatic accreditors, ASPA is actively engaged in representing the interests of the programmatic accrediting agencies.

With regard to innovations in education, competency-based education is one of the topics gaining traction.  Some universities are working through the logistics and implementing competency-based education for a host of degree programs. 

  

Hot Issues Facing Higher Ed

Submitted by Thomas Skalko, PhD, LRT/CTRS, CAAHEP President

In order to keep folks abreast, it seemed logical to pitch a short blog on things that are happening in the accreditation world.  I had the privilege of attending the Association for Specialized and Professional Accreditors (ASPA). There seem to be some key issues that are confronting all accreditors. It is time to keep our eyes and ears open and ASPA is playing an important role in representing programmatic accreditors.

On the top of the agenda is the re-authorization of the Higher Education Act. There are competing options and priorities including the comprehensive bill by Senator Harkin, separate partial proposals from the House and the priorities of the Obama Administration.  Currently, there is a push by the U.S. Department of Education and the Council for Higher Education Accreditation (CHEA) that place greater demands on accreditators. Among the topics of interest include a new push for more transparency and open disclosure of accreditation actions. This transparency includes access to self-studies, accreditation team reports, and accreditation communications. While conceptually some level of transparency may not be overly alarming, the issue, however, on how far the call for transparency goes may indeed be problematic. Will the push include all materials? Will documents and decisions be misinterpreted by the public? Will there be a requirement to release documents prior to an institutions opportunity for due process and opportunity to clarify and offer additional information that may alter decisions? What are the legal implications of full disclosure? So many questions and so few answers!

When is a Doctor not a Doctor?

When I graduated from law school with my J.D. (Juris Doctor) degree, I remember getting a call from one of my smart-aleck brothers. We had another brother with a doctorate in theology, so Mr. Smart Aleck said, “Now we have two doctors in the family and neither one of you is worth a damn.” That might be a debatable point when he needs a lawyer, but he was reflecting a commonly held belief, maybe a bit old-fashioned now, that the only REAL doctors are M.D.s. But these days a whole array of health care providers attain doctorate degrees – most of which (like my J.D.) are non-research professional doctorates. So, physical therapists, pharmacists, and dentists are all “doctors.” But, especially in the field of nursing, the question of who can call themselves doctors has become an even hotter topic.

In my home state of Florida – where you can always count on the most extreme ideas to come from our state legislature – bills have been introduced that would force health care providers with doctorate degrees to explain to patients and the public that they are "not medical doctors" or face felony charges. Yes, that’s right – felony charges!!

The AMA has had a “Truth in Advertising” campaign for several years now. They have data that indicates there is a lot of confusion among consumers of health care as to who the various practitioners are. We in allied health know that this is a problem – everyone who has direct contact with patients is perceived by most patients as either a doctor or a nurse.

So, the AMA’s “model legislation” calls for all health care practitioners who come in contact with patients to wear a name tag “that clearly identifies the type of license held…” This is certainly not a bad thing and it would help promote the visibility of professions like medical assisting. The AMA’s material notes that the model bill “does not provide for criminal penalties.” But it goes on to say, “although a state may wish to pursue that course.” Really? Do we really want to further clog up our criminal courts with felony charges against a nurse practitioner who fails to clearly identify him or herself as NOT a doctor?? Will prosecutors, who are ever sensitive to political concerns, be lobbied to throw these “not real doctors” in the slammer?

For more information on the AMA’s campaign, here is the document I have cited:

http://www.ama-assn.org/resources/doc/arc/tia-campaign-resources.pdf. The AMA says this is not a “turf battle” but others disagree. Here’s an interesting article from Bloomberg that offers another perspective: http://www.bloomberg.com/news/2013-03-04/nurses-spar-with-doctors-as-30-million-insured-seek-care.html

State of the Education Union

Education and accreditation leaders were not shocked when, in his State of the Union address, President Obama said this about higher education: “Taxpayers cannot continue to subsidize higher and higher and higher costs of higher education. Colleges must do their part to keep their costs down, and it’s our job to make sure they do.” This is a theme we have been hearing repeatedly from the Administration.

But the “supplemental document,” released after the speech, did contain a very big surprise for the accreditation community. In that document the White House said: “The President will call on Congress to consider value, affordability, and student outcomes in making determinations about which colleges and universities receive access to federal student aid, either by incorporating measures of value and affordability into the existing accreditation system; or by establishing a new, alternative system of accreditation that would provide pathways for higher education models and colleges to receive federal student aid based on performance and results.”

Right now, in order for their students to receive federal financial aid, a college must have institutional accreditation from an agency recognized by the US Department of Education.  (This is different from program accreditation which is what CAAHEP does). The main purpose of the recognition by the Department is to assure that the accreditors are serving as “gatekeepers” for that federal aid. But with rising default rates on student loans and ever-escalating costs for a college degree, the Administration clearly believes that those institutional accreditors are somehow failing in their duty as gatekeepers.

There has been a lot of debate in recent years in the accreditation community about how we should balance our roles as the cop who assures certain outcomes versus promoter of quality and quality improvement. That debate will no doubt continue.

But what is of particular interest to me is that the underlying philosophy in the Administration’s position seems to be that federal money should be used only to train students for jobs. If you want to spend $40,000 on a liberal arts degree that won’t prepare you for a profession, you have that right. But not at taxpayers’ expense.

Many of us in the “Boomer” generation started out with English or philosophy degrees before we ultimately settled into a profession. But given high unemployment rates and the fear of the looming crises over student loan defaults, this would appear in the minds of many to be a “luxury” we can no longer afford.