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What A Report on Accreditation Means to Higher Ed IT

Outside of e-learning circles, accreditation is not an area that normally draws much attention from the higher education IT community. So, it would not be surprising if last week's meeting of the commission charged with advising the U.S. Department of Education (ED) on accreditation—and especially which accrediting bodies ED will recognize in establishing institutional/programmatic eligibility for federal student aid programs—went largely unnoticed among CIOs and their staffs. However, the draft report approved at that meeting by the National Advisory Committee on Institutional Quality and Integrity (NACIQI), which presents recommendations for ED to consider as it approaches next year's reauthorization of the Higher Education Act, touches on two areas of increasing importance for EDUCAUSE members—the level of communication, coordination, and collaboration between federal and state higher education regulators and accreditors, and the role of data in addressing accountability and effectiveness demands.

I noted several months back that ED's extension of state authorization regulations to online distance learning indicated a breakdown in the department's understanding of the degree to which institutions had relied on its previously long-standing policy (namely that an institution only needed authorization by the state in which it was physically located to meet state authorization requirements for federal student aid eligibility) in developing their e-learning programs, and how the dynamics of e-learning required a thoughtful, collaborative approach to revising that policy engaging both state regulators and institutional representatives. As we now know, the precipitous change the department pursued saw its state authorization regulation overturned by a federal district court.

That ruling is now in the hands of a federal appeals court, which will decide whether to uphold it or reinstate the relevant regulation. And has been said by many tracking this issue, the ultimate status of the regulation does not impact one way or the other whether a state might consider an institution in violation of its laws on state authorization in providing e-learning to its citizens. However, the ongoing storm that erupted around the regulation highlights how the easy reach of e-learning across state lines and regional accrediting territories requires a much stronger partnership between the federal, state, and accreditation components of the higher education regulatory framework (known as "the Triad"), at least if those involved don't wish to see the capacity of e-learning to help meet the nation's postsecondary education goals severely impacted.

In its report, the draft of which the committee approved largely as currently written, NACIQI explicitly recognized this need by calling on ED to take a strong, proactive role in convening dialogue and collaboration with state regulators and accreditors to address how best to harmonize the Triad's various requirements:

The federal member of the triad could be expected not only to set expectations for the elements for which it is responsible, but also to convene and promote communication and collaboration across the triad.

Among states, there is considerable variability in the responsibilities that different states assume, yielding uneven coverage of those areas of responsibility specifically allocated to states. The inconsistency of state approaches also renders some institutions triply-monitored, while others are actively monitored only by the federal and accrediting members of the triad. Our recommendations concerning the state role include:

  1. Determine what mechanisms will best insure that critical quality assurance/eligibility expectations are met across institutions and agencies nationwide.
  2. Draw on the convening capacity and function of the federal level to develop models for triad articulation and to promote greater engagement and consistency across states.

..., the presumption that state boundaries define the delivery and oversight of education may in some respects be inconsistent with the newer methods of education that are not tied to land boundaries, and the multiplicity and inconsistency of state regulation may hamper both effective application of quality standards and educational diversity and innovation. Our recommendations in this regard include:

  1. Evaluate whether the diversity of state regulation across the country might be shaped to incorporate recognition of the growth of cross-state (and, indeed, cross-nation) educational activity.

Even though NACIQI only advises the department on accreditation issues, and its recommendations on harmonizing the regulatory/accreditation framework in relation to e-learning may be seen as taking it a bit far afield from its core charge, the higher education community has to consider the committee's recommendations in this regard as a major plus. Having one of ED’s primary advisory bodies press it to engage other relevant actors in developing collaborative solutions to e-learning regulation cannot go unnoticed within the department. We can only hope that ED will take NACIQI's recommendations to heart, especially given the department's experience in federal court as well as proposed Congressional legislation to eliminate the state authorization regulation regardless of court action. (See also the letter to the U.S. House of Representatives that EDUCAUSE joined supporting the repeal bill.)

Consistent with the committee’s call for greater coordination and cooperation among higher education regulators and accreditors, the NACIQI report includes a number of recommendations about data collection, sharing, and standards. While these only constitute proposals at this time, they bear watching by the higher education IT community given our members’ likely role in their planning, implementation, and management, both institutionally and inter-institutionally, should they be adopted. This is especially true given similar developments, such as the Common Education Data Standards (CEDS) and continuing interest in integrating college and university data into statewide longitudinal data systems (SLDSs).

  1. Reconsider data that are collected by all accreditation, state, and federal agencies. In this reconsideration, evaluate the costs of data collection relative to its utility and appropriate use.
  2. Wherever possible and of value, share data provided to and analysis conducted by the federal government (e.g., regarding institutional financial responsibility) to assist accreditors in reviews
  3. From the above reconsideration of data, costs and benefits, define a specific set of data that is needed as a minimum to address (a) federal interest and/or (b) institutional improvement. This would entail:  
  • Developing a set of consistent definitions and appropriate metrics for use in the accreditation process. Achieving convergence of agreement about definitions may—without altering the state regulatory authority or interest—assist states in becoming more aligned in their regulations and thereby provide institutions whose activity crosses borders with fewer divergent data demands.
  • Insuring that this data is accurate and meaningful, and consistent across institutions, without specifying minimum thresholds to be applied across all institutions. All data requirements should account for distance education modalities.
  • The specific set of minimum data would not preclude accreditors from requiring data appropriate for their philosophy and specialty. Accrediting agencies can and should consider what additional data is needed for the function of continuous institutional improvement. However, additional requirements for data collection should be developed with an assessment of its burdens and sufficient lead time for the data to be compiled.
  1. A data set with common definitions might beneficially include data on such outcomes as completion/graduation, licensure or job placement (where appropriate), and/or other indices of career progress. Note that this consideration does not include specification of student learning outcome measures, nor of uniform thresholds on any measure to be applied across all institutions.
  2. The accuracy of data is so central to eligibility and to consumer decisions that it may be appropriate for critical data elements to be independently audited under specified circumstances. It may also be appropriate to review the penalties for submission of fraudulent, inaccurate, or misleading data.
  3. Some types of data may require that systems be developed in order to compile the information in a manner that protects privacy of individuals appropriately. Recognizing the controversy concerning national unit record systems, further consideration could be directed to how completion (graduation) data might be gathered in a privacy-protected manner.
  4. Explore and implement how the Integrated Postsecondary Education Data System (IPEDS) data could be made more accurate, timely, and useful.