Middle States Commission on Higher Education


Other News

U.S. Department of Education

Accreditation and the
Federal Commission on
The Future of Higher Education


Jean Avnet Morse
Executive Director


You have probably heard comments and statements issued recently by the Secretary of Education's Commission on the Future of Higher Education about the American system of higher education accreditation.


What are the Issues?

The main points made in these statements are that regionally based institutional accreditors should be more accountable, more transparent, more public, and less regional.


While some of these issues may merit further discussion, the danger is that the Commission might recommend radical reforms that undermine a system that has a proven history of being able to change as needed, or that it might recommend reforms that are impractical and unrealistic. One consultant to the Commission has even proposed a new federal agency to replace accreditation as a gatekeeper for federal loans and grants to students. This is not likely to occur, but there will doubtless be pressure for other changes. 


How Might Presidents Respond?

Before the federal Commission issues its final report in August 2006, you may be called upon for reactions or suggestions. Here is some information that may help you respond to inquiries about the federal Commission’s activities and their implications for your institution.


In addition, please feel free to use an “opinion” article we prepared for a newspaper editorial page. It covers similar points, and it may be easier for public audiences to understand. (Click here for a copy of “Re-evaluating Higher Education Evaluation.”)


How is Middle States Responding?

Middle States' hope is to direct pressure into areas where change is helpful and feasible, so that the federal Commission does not create antagonisms by making harmful recommendations in its final report. Of course, change and improvement are always needed, but accreditors are already aware of current problems, are taking steps to correct them, and are willing and able to make more changes—without drastic reforms that would undermine the usefulness of an accreditation system that has supported evolving colleges and universities for over 80 years.


As with Reauthorization of the Higher Education Act, all of the regional accreditors have been working hard "behind the scenes" through our national organization, the Council of Regional Accrediting Commissions ("C-RAC"). These include attending hearings and meetings and working with the federal Commission's staff. C-RAC will submit a detailed, written response and recommendations to the federal Commission.


Areas in which the federal Commission and institutions of higher education might agree include the need for clearer definition and assessment of essential skills; increased attention to academic rigor and standards; more transparent disclosure of the results of accreditation visits; and perhaps more involvement in accreditation processes by public representatives.


However, as described below, support for change should be considered within the context of acknowledging that higher education has already recognized the need for many of these steps and is making progress towards them. 


1. STUDENT LEARNING: Accreditors and colleges can do better, but we are already on the right track.


·     The higher education community is well aware of the need to define and assess learning clearly so that the benefits of higher education can be readily understood by students and the public. Over the past few years, accreditors have introduced standards that emphasize this area very heavily, such as Middle States' Standard 14 (Assessment of Student Learning). These new standards may require major institutional transformations, so significant evidence of student learning, while underway, may not be apparent for a few years.


·      Accreditors have provided training, publications, and institutional review to assist institutions in making the cultural changes that are needed to bring about a transformed view of student learning and assessment. Accreditors work with each institution within the context of its own mission. The type of individually tailored and intensive attention supplied by accreditors would not be provided if taxpayers bore the expense.


·      Accreditors are already required by federal regulations to have standards that address success with respect to student achievement (including appropriate consideration of course completion, state licensing examinations, and job placement rates). They are also required to address curricula, faculty, student support services, length of program, and other areas that affect student success.


·      Middle States' accreditation standards already require "college-level proficiency in general education and essential skills,” including at least oral and written communication, scientific and quantitative reasoning, critical analysis and reasoning, technological competency, and information literacy. Institutional accreditors in other regions have similar standards.


·      Standardized and/or numerical testing of students may not be the most appropriate and useful way to assess the actual learning goals of some institutions. Existing tests rarely supply the type of information needed to inform improvements and are subject to many issues regarding accuracy and value.



2. TRANSPARENCY: Accreditors could do better, but we already do much to make our work accessible to the public.


  • Accreditation actions, including required follow-up, are available to the public upon request and, by July 1, 2006, they will be posted on our website (www.msche.org).
  • A “Statement of Accreditation Status” is also available to the public upon request and will also be available on our website by July 1.
    It provides information such as branch campuses and accreditation history for each institution. 
  • In the event of an adverse action, a public disclosure statement is made available to the public.


3. ACCOUNTABILITY: Accreditors are reviewed regularly by the federal government and others.


  • Federal regulations require that accreditation standards address success with respect to student learning achievement, as described above. 
  • Federal regulations also cover the structure of the agency, conflicts of interest, administrative and fiscal responsibilities, quality of evaluators, and due process for institutions being reviewed.
  • Middle States and several other specialized and regional accreditors also are recognized by the Council on Higher Education Accreditation (CHEA).


4. NATIONAL CONSISTENCY: Accreditors' standards may appear different, but they all reflect similar expectations. Structures are in place to increase already existing co-operative efforts. 


  • C-RAC, the Council of Regional Accreditors, meets frequently to create joint efforts and policies. Regional accreditors have created several joint publications through C-RAC, including “Interregional Guidelines for Electronically Offered Degree and Certificate Programs,” “Regional Accreditation and Student Learning: Principles for Good Practices,” “A Guide for Institutions and Evaluators,” and “Preparing Teams for Effective Deliberation.”
  • All regional accreditors address the most important aspects of institutions of higher education, including mission, planning, institutional performance (including student learning), resources, faculty, student services, admissions, curricula (including general education), governance and administration. Each regional accreditor may have additional requirements, and the format of their standards may differ, but expectations regarding fundamental aspects of programs and services are quite consistent.
  • All regional accreditors have similar processes that require self-assessment reports, team visits, due process, and decisions by peers.
  • Regional accreditors have agreements for accreditation of institutions operating in more than one region, and for requirements regarding the change of ownership of for-profit institutions.


5. DIFFERENT TYPES OF INSTITUTIONS: This is one of the great strengths of American higher education, and accreditation is structured to support it.


Accreditors review each institution within the context of its own mission, using peers from similar institutions. Standardized measures for all colleges would foster uniformity, which might prevent the American system of higher education from meeting the needs of a diverse student body and complex society.


  • Using flexible standards allows higher education to remain both unified and diverse. Regional accreditation includes public and private institutions, large and small, community colleges and research institutions, conservative and liberal.
  • An example of “one size does not fit all” is the uselessness of applying graduation rate requirements to community colleges, whose students often have goals that do not include earning an associate degree.
  • The artificiality of separating colleges into “sectors” is reflected in the new multiple factors recently substituted for the old “Carnegie” classifications.


6. ABILITY TO SELF-REFORM: Accreditation has made major changes in the past and has internal mechanisms and wherewithal to do so again. 


  • Examples of past reforms/changes include introduction of the self-study, the accreditation of distance learning, revision of accreditation standards to include requirements for efficiency as well as effectiveness, and revision of standards to emphasize the importance of assessing student learning.
  • Examples of current reforms include pilot projects to test the feasibility and value of accrediting foreign institutions, simplified processes for assessing institutional compliance with accreditation standards based on existing documentation; and a proposed policy to clarify accreditation expectations for externally controlled for-profit and other institutions.


7. TAXPAYER COST SAVINGS: Accreditation is funded by fees from institutions and by time contributed by thousands of volunteers.


  • Many states in our region rely on regional accreditation to assure the quality of the institutions that operate within their borders.
  • The level of expertise and the volume of attention needed for campus visits and reviews of documentation would entail enormous expense if funded publicly.

Please feel free to use this memo and the linked opinion article in any way that may be useful, and to contact me with suggestions and questions at
267-284-5025 or jmorse@msche.org.