Many of you are aware that the U.S. Department of Education has proposed sweeping new regulations for the policies and procedures that accrediting agencies must follow to be recognized as “gatekeepers” for the purposes of federal student aid.
Below are AACC’s core positions on the accreditation Notice of Proposed Rulemaking (NPRM). We encourage you to reinforce these and other views at regulations.gov.
Support the NPRM’s transfer of credit provisions
Community colleges embrace the NPRM’s provisions concerning transfer of credit. They will ensure that community college students who enroll in another institution are treated fairly and transparently when their academic path continues. The NPRM does not require the acceptance of credit from incoming students, but it does require that they receive an explanation if any credits have not been accepted. This policy is an overdue and welcome change in higher education.
Limit the analysis of institutional expenditures to realistic metrics
The NPRM requires accreditation agencies to ensure that a “cost-benefit” analysis is performed by institutions in evaluating expenditures, as well as their own analysis. The policy’s goal is constructive, but the provisions need refinement. As a practical matter, a cost-benefit analysis cannot be applied to many types of student-focused activities—learning and other aspects of student experience cannot always be translated into the economic calculations on which a cost-benefit analysis rests. Accreditors should continue to play an important role in ensuring that, overall, institutions remain fiscally sound, but a cost-benefit analysis is not necessary to ascertain this. This provision should be rewritten accordingly. It also should be stated that for reasons of ongoing fiscal exigency and public accountability, community colleges strictly monitor all expenditures.
Oppose the requirement that accreditors enforce intellectual diversity
Community colleges do not have a substantial problem with a lack of viewpoint or intellectual diversity and involving accreditors in trying to evaluate it will complicate campus procedures without commensurate advantages. Community college campuses, from cafeterias to classrooms, reflect their local communities, and this incudes faculty and their interactions. In addition, numerous community college programs, particularly career-related ones, have no meaningful relationship to the concept of intellectual diversity, however it might be attempted to be defined in practice. Finally, the federal government should not insert itself into this core academic facet of institutions—this policy represents an undesirable, top-down approach to education that the Administration has indicated it would like to shun.
Oppose the requirement that accreditors enforce the First Amendment
As public institutions, community colleges are required by law and longstanding tradition to ensure that First Amendment is observed in all facets of campus life. Involving accreditors in securing First Amendment rights needlessly complicates these critical campus practices. The Education Department should reject this new requirement to help ensure that accreditation remains focused on quality assurance and not divert resources to a function where it lacks deep expertise.
The wider context
Even given accreditation’s current reach, the proposed regulations leverage accreditation to increase federal involvement in institutional practices and operations in substantially new ways. The regulations will apply to community colleges as much as selective research institutions.
The accreditation NPRM comes at a time of substantial criticism and questioning of the value of higher education, if not always community colleges. Key aspects of the regulation require accreditors to perform functions that they do not currently undertake, and some of these, new roles duplicate those of other entities or are best left to campuses.
Accreditation’s central, ongoing focus should continue to be one of providing quality assurance. Some aspects of the proposed regulations would move accreditors more explicitly into this space and are appropriate. But in other areas, accreditors would be mandated to take on responsibilities where they lack expertise, other entities are better suited, or intervention cannot be solved through regulation.
The accreditation rule has many facets and AACC staff are eager to provide additional context for you, should you desire it. If you have questions, please contact David Baime, senior vice president of public purpose and national advocacy, at dbaime@aacc.nche.edu.