Proposed Rule Would Change Accreditation’s Purpose (opinion)

If the lights go out in your house, you call an electrician. If a pipe bursts, you call a plumber. Both matter. Both protect the house. But asking the plumber to inspect the wiring does not make the house safer. It simply gives the plumber the wrong job.

Something similar is happening in American higher education.

The U.S. Department of Education’s proposed Accreditation, Innovation and Modernization regulations begin with goals that many of us share: stronger accountability, better student outcomes, less unnecessary regulatory burden, greater innovation and better protection for students and taxpayers. The Council for Higher Education Accreditation and the colleges and universities we represent support those goals. Our members are deeply committed to student success, educational quality, accountability and continuous improvement.

But good goals do not guarantee good policy.

The question is not whether higher education should be accountable. It should be. The question is who should be accountable for what and how.

I have spent most of my professional life in higher education. I have been a faculty member, an academic administrator and a university chancellor. I have also served inside the U.S. Department of Education, and today I lead CHEA. Seeing higher education from all three perspectives has reinforced something I have come to believe deeply: Strong accountability does not require everyone to do the same job. It requires each participant to do their own job well.

That principle has long been embedded in American higher education. Institutions are responsible for educating students and fulfilling their missions. The federal government determines whether institutions meet requirements for participation in federal student aid programs. States authorize colleges and universities to operate. Independent accrediting organizations evaluate academic quality through peer review. These responsibilities sometimes overlap, but they are deliberately distinct. Congress chose this structure rather than creating a federal system for determining academic quality. 

Those distinctions are not bureaucratic trivia. They are safeguards. Yet several provisions in the proposed regulations risk blurring them.

Should an accreditor be responsible for determining whether a university complies with every applicable federal and state law? Institutions must, of course, obey the law. So must accreditors. But determining whether the law has been violated is the responsibility of the government agencies charged with enforcing it and, ultimately, the courts. Turning accreditors into legal compliance officers does not strengthen accreditation. It changes its purpose. 

Should an accreditor determine whether a university has spent too much on faculty, facilities, student services or scholarly activity? Accreditation should certainly examine whether an institution has the resources necessary to fulfill its educational mission. But requiring accreditors to conduct cost-benefit analyses of institutional spending places them in the very different role of judging how universities allocate their resources. Those decisions appropriately belong to institutions and their governing structures. 

These new responsibilities also carry real costs. Requirements imposed through accreditation ultimately translate into additional data collection, documentation, analysis, reporting and review. Before adding new requirements, policymakers should ask whether they are justified by a meaningful improvement in quality and student protection.

And should Washington prescribe exactly how accreditors evaluate student achievement, academic freedom, intellectual diversity, faculty policies and other dimensions of academic life?

These are important issues. CHEA strongly supports academic freedom and meaningful attention to student outcomes. But supporting an objective is different from believing that the federal government should prescribe what an independent accreditor must measure and how it must conduct that evaluation. The proposed rule too often crosses that line. 

There is an important distinction here: Federal oversight of accreditation is necessary. Politicization of accreditation is not. That distinction matters, especially now.

Higher education is being asked difficult questions about cost, value, student success, public trust, academic freedom and workforce preparation. Accreditation cannot respond to those questions simply by defending the way things have always been done. It must continue to improve. It should use better information, focus more clearly on student outcomes, reduce unnecessary burden and encourage innovation.

But reform should strengthen accreditation’s ability to judge educational quality, not gradually transform it into an enforcement mechanism for every public policy objective affecting higher education.

Indeed, the more responsibilities we pile onto accreditation, the greater the danger that it becomes less effective at fulfilling the responsibility for which it was created.

In its formal comment to the Department of Education, CHEA identifies provisions it supports and recommends revisions where the proposal would expand accreditation beyond its appropriate role. Higher education does not need less accountability. It needs smarter accountability. A safe house needs working plumbing, reliable electricity and a sound structure. Every part matters. But that does not mean the plumber, electrician and contractor should all be asked to do the same job.

Let institutions remain responsible for fulfilling their missions and serving their students. Let government enforce the law. Let states exercise their authority. Let institutions govern themselves within those boundaries. And let independent accreditors carry out their role within the framework Congress established: evaluating educational quality while helping to protect students and support institutional improvement. 

The electrician and the plumber both matter. We should resist the temptation to hand them the same toolbox.