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 Accreditation Policy and Community Colleges -- November 2016 


The landscape for accreditation continues to shift in ways that could challenge community colleges. The accreditation process has been under scrutiny for several years and remains a key issue in the Higher Education Act (HEA) reauthorization discussion. Legislation that would dramatically change it has been introduced by influential members of Congress.  Meantime, the U.S. Department of Education (ED) has used its considerable leverage to influence accreditation practices. The broader policy environment has seen numerous high profile organizations, policy analysts, and the media criticize the current process. All the while, accreditors themselves struggle to reconcile these external pressures with their longstanding role that is fundamentally faced inward towards institutions and students.

Community college leaders would do well to keep abreast of these developments. It is particularly critical for college leaders to engage with their accreditors to ensure that the process retains its relevance and rigor in the public eye, as well as on their campuses.

Congressional Perspectives on Accreditation
Congressional interest in accreditation is not new, though it has intensified in recent years, in part because of the ongoing HEA reauthorization. The reauthorization will likely continue through the next Congress and perhaps beyond.

Negative Congressional critiques of accreditation come from a variety of perspectives. Some members focus on the perceived failure of accreditors to ensure that colleges provide minimum academic quality, and thereby responsibly discharge their “gatekeeping” role for the student financial aid programs. These concerns gained urgency in light of the recent collapse of the Corinthian Colleges and ITT and broader trends in the for-profit college sector.

 Furthermore, ED announced in September its decision to terminate recognition of the Accrediting Council for Independent Colleges and Schools (ACICS). The potential loss of accreditation for the City College of San Francisco also drew national attention.

However, it should be kept clearly in mind that tough questions are being raised by legislators about the educational outcomes of public and private non-profit institutions, including community colleges. The concerns about community colleges often focus on low graduation rates and high student loan defaults—numbers that community college leaders can account for, but generally from a defensive position. 

Other Congressional critics of accreditation say the process is overly expensive and bureaucratic and stifles innovation. Research universities have helped foster this view with loud complaints about accreditation’s cost and irrelevance. Accreditation also is said to be overly focused on institutional inputs rather than student success. This perspective often carries with it the policy prescription that the "cartel" of accreditation should be opened up to allow other entities to serve as gatekeepers of Title IV aid.

AACC and ACCT submitted formal views on accreditation to the Senate Health, Education, Labor and Pensions Committee in April 2015. The associations largely supported the current system of regional accreditation, and, while acknowledging that change was likely, emphasized some of the unique characteristics of community colleges.

Federal Legislation

A few of the more prominent bills that have been introduced on accreditation include:

Accreditation Reform and Enhanced Accountability Act of 2016 (S.3380)
Introduced by Democratic Senators Warren (MA), Durbin (IL), and Schatz (HI) on September 21, 2016, S. 3380 would dramatically restructure the relationship between accreditors and the federal government, essentially making accrediting agencies implementers of a new “bright line” federal outcomes policy.  Some of the main features of S. 3380 include:

  • Accreditors would be required to establish and enforce minimum baseline threshold standards for institutions for completion rates, 3-year cohort default rates, and 5-year loan repayments.  The Secretary could add other measures through regulation. The standards could be tied to an institution’s mission. Colleges that failed to meet the standards two out of three years would lose their accreditation.
  • The Secretary also would be required to set institutional “standards” in a variety of areas of student achievement, keyed to a college’s mission. Previously these standards were determined by accreditors. The assumption is that the new standards would be quantitative.
  • Accrediting agencies would be explicitly authorized to accredit institutions with “distinction” or “risk,” adding additional evaluative gradations to today’s binary approach.
  • Would require that, four years after enactment, agencies ensure that each institution in their jurisdiction “provides for the transfer of credit earned for all general education courses and for courses required as part of substantially similar programs.” However desirable this arrangement might be, it does not seem practical.

The Access, Success, and Persistence, in Reshaping Education (ASPIRE) Act (S.3368)
The ASPIRE Act, introduced by Senators Chris Coons (D-DE) and Johnny Isakson (R-GA) on Sept. 21 of this year, gives more selective colleges with lower numbers of low-income students four years to boost low-income student enrollment or pay a fee to participate in the federal college loan program. High-access, low-performing colleges would have the option to get up to $8 million over five years to improve student outcomes. These resources — to be generated through the fees collected from schools that do not improve low-income student enrollment – would be accompanied with new bare minimum completion standards, applicable to all four-year institutions. 

Higher Education Reform and Opportunity Act (S.649)
Introduced by Senator Mike Lee (R-UT), on March 4, 2015,S. 649 would allow state agencies to replace the role that accreditors have traditionally played as serving as one of the legs of the traditional “triad” leading to federal student aid approval: accreditation, state licensure, and eligibility and certification approval by ED. Under S. 649, state agencies would have to establish an “alternative accreditation agreement” that would permit accreditation to be bypassed.

U.S. Department of Education Actions on Accreditation
The U.S. Department of Education (ED) continues to play an active role in the work of accrediting agencies. The regulations that set the formal conditions for the “recognition” of accrediting agencies by ED (recognition allows the agencies to serve as Title IV gatekeepers) are just the legal launch pad for further administrative actions and policies that are visibly affecting accreditation practice. Within the last year, the Department has demanded that accrediting agencies turn over vast amounts of material on the institutions they approve, a request that has had agencies reeling under its weight. Later that month, ED sent a communication to all agencies that proposed dramatic shifts in the criteria that ED would use to evaluate agencies. Among other things, ED stated that agencies must place greater emphasis on numerical outcomes in approving institutions, and that it reserved the right to require agencies to adopt similar evaluation methods of institutions, in effect challenging their autonomy. The overwhelming emphasis on this new expectation was the greater use of bright line outcomes standards. The Department has also created new reporting terminology and requirements for accreditors that have translated into substantial new reporting burdens.

ED’s National Advisory Committee on Institutional Quality Improvement (NACIQI) publicly reviews and recommends to ED whether it should recognize accrediting agencies for Title IV, and on what terms. Over time the panel, with members appointed by both Congress and the Administration, has moved increasingly into the policy realm. Critics of NACIQI assert that in both formal and informal actions it has exceeded its appropriate role. Examples include advancing recommendations for the HEA reauthorization, and inquiring about specific institutional accreditation decisions. The panel has also appeared to reflect the wishes of ED to focus more heavily on graduation rates and default rates.

Also, after being formally importuned by the American Council on Education and two of the major associations representing research institutions, ED has explicitly authorized accreditors to conduct “differential reviews” of institutions. The logic for doing so is to permit the most selective and best- resourced colleges to bypass aspects of accreditation that are time-consuming, costly, and not necessary relevant to their campuses. AACC has grave reservations about the federal government formally sanctioning differential treatment of institutions. Accreditors have long accommodated the different nature of the colleges they review. But ceding the principle of uniform treatment of all institutions, in what is invariably a process-oriented undertaking, is highly problematic.

Accrediting Agency Actions of Note
In late September, the Council of Regional Accrediting Agencies (C-RAC) announced a major initiative to adopt enhanced examinations of institutions that have relatively low graduation rates and high default rates. Community colleges with graduation rates of less than 15% (as measured by IPEDS, under the 200% of “normal time” measurement rather than the 150% metric more commonly used) would be subject to the reviews. The 15% standard is keyed to half the average community college graduation rate. This effort clearly signals that accreditors are sensitive to policymakers’ expressed concern about their ability to ensure institutional rigor. Also, although accreditors have agreed on a common screen to use for enhanced review, their procedures will not necessarily be uniform.

The C-RAC effort holds both promise and some peril for AACC members. Enhanced scrutiny of colleges with particular difficulty in graduating students may lead to better results. The reviews could spark a helpful campus “call to arms” about the need to focus above all else on student success. This approach is also more flexible than more rigid “bright line” proposals such as S. 3380. On the other hand, being singled out for special review is no badge of honor and could create problems with public perceptions.

Overall, AACC believes that the C-RAC effort can help institutions and help maintain the reputation of the accreditation process in the eyes of skeptics. In its public statements on the initiative the association accentuated the positive, while noting that some institutions will invariably not welcome increased scrutiny.

What You Can Do To Advance and Protect Your Institution
The accreditation environment demands the attention of institutional leaders. It is important that every leader becomes knowledgeable about the issues, as the debate promises to continue for many months. Federal legislation will not be enacted before next winter at the earliest. However, the Department of Education’s policy initiatives continue, and a new set of executive branch policymakers will be formulating positions in 2017.

Perhaps most important for CEOs is that they actively engage their own regional accreditors and their institutional peers in helping agencies respond constructively to the current environment. Leaders are urged to work with their accreditors to shape the C-RAC initiative described above in a way that simultaneously ensures the continued benefits of accreditation and helps institutions improve. Successful movement in this direction is likely to help protect colleges from unhelpful federal interventions. Accreditation is a process that was established by and for institutions, and institutional engagement is necessary to keep it that way.

For more information, please contact Dr. Walter Bumphus, President and CEO, or David Baime, Senior VP for Government Relations and Policy Analysis

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