“This Is Not Your Grandfather’s NACIQI”; Takeaways from the June Institutional Quality Review Meeting

“This Is Not Your Grandfather’s NACIQI”; Takeaways from the June
Institutional Quality Review Meeting
By Amber Saddler

Amber Saddler is a Policy Assistant with EducationCounsel where she works on a range of higher education and K-12 issues to help improve equity and education access for all students. She enjoys long walks on the beach and observing federal advisory boards at work.

Recently, I joined the National Advisory Committee on Institutional Quality and Integrity (NACIQI) and spent three very long and very exciting days in a hotel conference room in Northern Virginia while the committee made recommendations to the U.S. Department of Education (ED) to continue or deny federal recognition to programmatic and institutional accreditation agencies wishing to serve as gatekeepers to federal funding under Title IV of the Higher Education Act.

Among the audience, there was great interest in NACIQI’s recommendation to ED to revoke federal recognition of the Accrediting Council for Independent Colleges and Schools (ACICS). While ACICS was the only agency NACIQI is currently suggesting should have its recognition removed, many committee members made it clear that other accrediting agencies, especially the regional entities, should sit up and take notice of the “new sheriff in town.” Committee members from both sides of the aisle and from various higher education backgrounds agreed with the need for stronger enforcement of agency standards than had been in place in the past and that a new, more rigorous review process for all accreditors is the path forward for higher education.

Here are a few things I learned about the priorities of a new and improved NACIQI of the 21st century:

• New focus on student outcomes: NACIQI is intensifying its focus on student outcomes data and the accrediting agency standards that reflect them (or don’t, as the case may be). Committee members are paying close attention to sections of the Higher Education Act (HEA) which outline accreditation standards and where they fall under the committee’s purview. Accrediting agencies that fail to enforce their own standards for student outcomes will not be given endless opportunities to right their ships.  Some on the committee believe that the threat posed to students and taxpayers when NACIQI puts its faith in an accrediting agency with a bad track record is too great. As one member put it, the committee is unwilling to be painted as “at best morons, and at worst complicit in villainy” for a failure to act on an agency’s history.
• Rejection of the old “checklist” approach: Committee members criticized the special scrutiny in the Department of Education’s compliance report about the American Bar Association (ABA)  dedicated to “minutiae” such as missing staff resumes, while ignoring important law student outcomes such as crushing debt loads and dismal job placement rates. The committee’s critical response to the compliance report illustrates their desire for ED to move away from their current broadly focused, checklist approach and instead give targeted attention and deeper review to those areas of an accrediting agency’s work that is most relevant to students.  
• Fair treatment for all accreditors:  Some committee members are very concerned about the possibility of Department of Education staff applying a higher level of scrutiny to how rigorously national accrediting bodies enforce their standards than to their regional counterparts. While national accreditors are more likely to have student outcomes data such as job placement rates written into their review processes for institutions, regional accreditors should also prepare for the committee to home in on those areas during the recognition process. Moving forward, NACIQI will closely examine all existing agency standards, especially student achievement standards, for all types of accrediting bodies.
• More rigorous review: This NACIQI demands more of accreditors seeking renewal of recognition than simply meeting the bare minimum requirements of Title IV access. As demonstrated by the vote to limit ABA’s ability to accredit new institutions, the committee is moving beyond its traditional pass/fail review process and will sanction even accrediting agencies that don’t rise to an intolerable level of egregiousness with penalties less severe than the “absolute death sentence” that is revocation of access to Title IV programs and funding.
• New focus on the Triad:  The committee is increasingly focused on cooperation and transparency among members of the Triad (the federal government, states, and accreditors), especially between accrediting agencies and different State actors. As illustrated by an exchange between representatives of ACICS and the Maryland Attorney General’s Office, NACIQI expects both entities to be more proactive about communicating and sharing information about investigations into institutional wrongdoing with each other.

NACIQI will continue in August with a conference call to consider renewal of recognition petitions by the several agencies postponed from the June meeting, and again in December when the committee will continue testing its outcomes-focused pilot project with other accrediting agencies, including most notably, the Higher Learning Commission (HLC).

EducationCounsel supports the efforts of NACIQI to improve and strengthen the accreditation process and to hold accrediting agencies accountable.  To help states, agencies and others understand the various questions in this area, with the support of the Lumina Foundation we released a new Framework for Risk-Informed, Differentiated Accreditation. The framework proposes some policy and practice ideas that could address many of the issues raised at this most recent NACIQI meeting by creating an accreditation system that is more responsive to student outcomes and better at directing time, resources, and attention to those institutions that need it most.  Also, last year we released Getting Our House in Order: Transforming the Federal Regulation of Higher Education as America Prepares for the Challenges of Tomorrow, a paper which assesses the current state of the higher education regulatory regime and suggests new approaches that eliminate unnecessary and burdensome regulations.