American Accreditation:
Its Process and SpiritCharles M. Cook∗

Research Institute for Independent Higher Education
Tokyo, JapanMay 15, 2002

It is a pleasure to stand before you today and share some thoughts about theexperience in the United States with accreditation, our primary means of quality
assurance in higher education, but also a practical tool for institutional improvement. Ivery much appreciate the opportunity provided me to do this. I speak to you not as ascholar of accreditation and evaluation, but rather as a practitioner. For more than two
decades I have been responsible for directing the accreditation process for over 200
colleges and universities in six-state New England region of the United States, which
includes not only the most selective and prestigious institutions of higher learning in ourcountry, but also less well known institutions which together serve to provide
educational opportunity to well over a half million students

My task is to provide you some understanding of our system of accreditation. I hope todo that by relating to you not only the details of its operation, but also its spirit, which
gives it life and meaning, which makes it unique, and which is an essential element of
the environment in which our system of higher education functions and thrives. And I
wish to leave you with some thoughts as to the essential principles that can be takenfrom our now nearly 100 year’s experience with institutional evaluation which I believe
have universal applicability.

∗

Director of the Commission on Institutions of Higher Education, New England Association of Schools andColleges, 209 Burlington Road, Bedford, MA 01730-1433, USA. E-mail: ccook@neasc.org

(Before beginning, let me note that I have prepared a handout which provides theaddresses for numerous accreditation related web sites in the United States. Obviously,
I can’t say everything here, and those interested can use, the internet, to learn more.
Because the measurement of student learning outcomes is pertinent to accreditation, I
have also included a number of sites related to this topic.

I understand that thisdocument is being made available to conference participants.)

First some context may be useful. The American system of higher education is marked
by three fundamental characteristics: size, diversity, and competitiveness. We haveover 3000 degree granting institutions and their range by type is greater than others
would think should be included in higher education, particularly those who follow theEuropean university model.

We have two year community colleges, undergraduate

liberal art institutions, graduate professional schools of all sorts, research universities,
though that list does no more than to begin to suggest the compass of our educational
universe. I would also note in particular the existence of very small institutions both
graduate and undergraduate – often enrolling less than 500 students, sometimes evenless than 20, each adding an essential micro-nutrient to our society. Somewhat morethan half of our institutions are independent – that is receive no direct public funding.
Here the United States has much in common with Japan, the only two countries in theworld with large independent sectors, in both nations sources of great educational andmore broadly, societal strength. Most students, in the United States attend publicly
supported colleges and universities. Over half of the students finishing high school thisyear in the United States will attend a tertiary institution in the coming year, though theaverage age of a college student in the United States has steadily increased in recent
years and now approaches 30, and as an expression of this fact, the number of parttime students is growing. Also this statistic is powerfully reflective that we have indeed
become a national of life-long learners.

Higher education in the United States is throughout a remarkably competitive industry,
the result of its relative autonomy within a decentralized federal structure, the large
number of independent institutions, our strong cultural incentives for the enterprising,2and the American belief that a largely unfettered market place is more productive ofsocial good than interventionist state regulation. Our system of accreditation permits
and encourages this competition. Historically it was invented because of the absenceof state involvement in higher education and, provided it continues to do its job well, its
existence precludes significant state intervention.

The role of government in terms of quality assurance and oversight of American higher
education is quite limited. Washington, though there is a Department of Education, has
no direct powers of control.

The federal government fundamentally depends on

accreditation as its primary quality indicator, but there are no national standards. Whilehigher education is a direct responsibility of each of our fifty states, their intervention,compared to what has been the norm elsewhere, is also limited; the states too dependon accreditation for basic quality assurance. While all institutions must be licensed orchartered, which is a state responsibility, for most independent institutions this does notprovide a basis for ongoing oversight or quality assurance except in extraordinary
circumstances. Indeed, some of our leading universities benefit from colonial charters,
making them, in their mind, totally free as an educational enterprise from state
involvement. Even among public institutions, many of whom refer to themselves as only
“publicly assisted” reflective of the fact that less than half their support comes directlyfrom the state, there is also remarkable autonomy in law in terms of academic mattersand no less importantly by practice.

It is our system of accreditation which provides basic quality assurance within whatmust be seen from the outside as chaos. Simply put, accreditation is a status granted
to institutions and programs found to meet or exceed standards designed to measure
educational quality. It has dual purposes: quality assurance and quality improvement; itjudges but it also helps.
institutions.

Accreditation, in effect, confers a basic legitimacy on

However, accreditation processes are designed in such a way as toencourage the improvement of institutional quality, its other basic purpose. Indeed, I
would suggest that the most important product of accreditation is improvement. These3

two purposes, quality assurance and improvement, are interlocking, they function
symbiotically. I would argue that in any effective system of accreditation both must exist.

Accreditation is private and non-governmental. It is carried out by independent not-forprofit entities, the members of which are the accredited institutions or programs.

Accreditation is non-regulatory but rather self-regulatory. It is the accredited entities
themselves who establish and enforce the standards of quality which accredited
institutions and programs are committed to abide by.

It is often said that accreditation is voluntary, and in a way it is. There is no explicit
requirement that institutions need it to exist. However, accreditation is so written into
law and regulation in the United States as the chief indicator of quality and a part ofacademic practice that it is in practice mandatory (e.g., only individuals graduating fromaccredited institutions may be licensed to teach, it provides basis for the transfer ofacademic credit from one institution to another and admission into graduate school,
employers typically hire only graduates from accredited institutions, and no parents
would allow their child to attend a non-accredited institution). As a result, there arealmost no unaccredited institutions in the United States.

Accreditation in the United States is a mature construct. Generally speaking, in its
present form, American accreditation has existed for about a half century, though it is by
no means resistant to change; its history has been one of growth and adaptation in
response to a dynamic system of higher education. Our form of accreditation as ourprimary system of quality assurance, being non-governmental, non-regulatory, is acondition, though not a cause, which has permitted and encouraged this institutional
dynamism which others would like to emulate.

We have two forms of accreditation: institutional accreditation and specialized or
professional accreditation.

While they share values and approaches, their unit ofanalysis is different. Institutional accreditation covers the entire college or university; it

4encompasses the whole entity, but not any one of its parts specifically. It is carried out
by several agencies, each quite autonomous, which cover separate geographicalregions; the term regional accreditation is synonymous with institutional accreditation.
The agency or commission that I direct, as indicated, has jurisdiction over the 200
colleges and universities in the six state New England region. For some institutions,this is their only form of accreditation which is their sole form of external quality
assurance.

Specialized or professional accreditation is program specific. That is, these agencies,
and there are about 50 of them, accredit specific academic programs primarily in
professional or applied areas such as law, medicine, teaching, social work, clinicalpsychology, even business administration.

The traditional arts and sciences (e.g.,history, philosophy, languages, biology, other forms of psychology) do not haveseparate accreditation agencies; their quality is assured through institutional
accreditation.

Organizationally, accreditation agencies are quite similar whether they deal with
programs or institutions. They are not-for-profit entities, administered by small paid
staffs. A board elected by the accredited institutions or programs provide oversight,
determine evaluation criteria and policy, review evaluations, and make decisions aboutaccreditation. The actual work of evaluation is undertaken by volunteers who are mostoften peer academics.

The accreditation process, generally speaking, is similar among all accreditors. Let me
provide a quick overview with the intention of addressing each step in some detail in a
moment, placed within context of regional accreditation. Institutions or programs are
asked first to engage in self-examination against the criteria or standards foraccreditation. The completion of the self-study is followed by an evaluation by a team ofpeers whose task is to assess fulfillment of accreditation standards by validating thecontent of the self study report. The team, which undertakes a visit to the campus,
prepares a written report of its findings which is then reviewed by the accrediting5commission, again made up of volunteer peers, who make a decision about program or
institutional accreditation.

Accreditation is cyclical; comprehensive reviews occur regularly every several years.
For institutional accreditation, the period between such visits is a decade and among
the specialized accreditors, it is typically somewhat shorter. In granting or reaffirming
accreditation, and it is through such actions that the accountability function is expressed,
these commissions will specify the timing of the next evaluation and often identify
matters of concern to be addressed in the interim. In cases where concerns are serious,
reports may be called for and evaluations on progress in addressing identified concerns
may also be required.

The decision about granting or reaffirming the status ofaccreditation and its cyclical nature give meaning to the process of self-study andevaluation.

However, once accredited with the date of the next visit established,institutions are not left unmonitored. While colleges and universities are essentiallystable creatures, they do change, and accreditation processes recognize this. Typically,
institutions are asked to submit annual reports which provide basic information, andthere are policies on substantive change which require that when accredited entities
undergo certain types of change (e.g., begin offering degrees at a higher level thanwhen most recently accredited, begin using new instructional modalities such as
distance education) a review of their accreditation is mandated.

It is an essential

expectation of accreditation that between reviews, while institutions are essentially “lefton their own,” they will self-regulate, that is function in a manner compatible withaccreditation standards.

Let me now talk in some detail about institutional or regional accreditation. The objectof analysis, the accredited entity, is the institution as a whole. What are our standards?
Or put another way, how have we developed criteria which at once serves as a basis forthe evaluation of our diverse set of colleges and universities and encourages thatdiversity? The criteria applied, given the wide focus of evaluation and the variety of ourmember institutions, are broad; they are mission-driven and open-ended.

While

expressed in detail, essentially accreditation standards ask: What is the institution’s

6mission? Does it have the resources to fulfill its mission? Is it fulfilling it, and can it be
expected to do so into the future? Thus, for example, the standard on faculty asks,
does the institution have a faculty sufficient in number and by training to offer the
institution’s educational program? What evidence is there that they are successful asteachers? Does the institution have in place mechanisms and a culture by which thereis assurance that it will continue to have in place a suitable instructional staff?

Essentially, what this means is that each institution is evaluated against its own statedpurposes. Given this construct, the same standards can be applied to very different
colleges and universities.

This broad and open-ended approach to institutional quality recognizes that educational
opportunity can be provided in different forms to meet the diverse demand for education
found in modern society.

It is this definition of quality which has allowed if notencouraged educational diversity, flexibility, and creativity in our country.

Furthermore, this approach in defining quality reflects several things.

First, ourprofound commitment to institutional autonomy. It also reflects our own perspective on
quality, that it cannot be meaningfully defined in detail; the content of education is toocomplex and diverse for that. But also, detailed or highly focused definitions stultify thecreativity and experimentation so vital to institutional growth and improvement.

Included in the application of these criteria are all aspects of the institution. Thus there
are 11 standards in number: Mission and Purposes, Planning and Evaluation,
Organization and Governance, Programs and Instruction, Faculty, Library and Learning
Resources, Student Services, Physical Resources, Financial Resources, Public
Disclosure, and Integrity.

There are no normative standards; as noted, colleges and universities are evaluatedagainst their own stated purposes. Obviously, these open-ended criteria call for theapplication of considerable professional judgment, something we are quite comfortable

7

with. As suggested, by design and application, they permit incredible variety, evenamong institutions of the same type, and encourage experimentation. It should also be
noted that these are minimum standards, though there are implicit and explicit
expectations that institutions will seek to improve themselves. Yes, these criteria resultin significant and substantive variation among accredited institutions in terms of
traditional aspects of quality.

While the institution is accredited as a whole, it isunderstood that some programs will be stronger than others.

How do we develop our standards; by what processes are they formulated? As noted,
accreditation is a form of self-regulation.

Therefore, the members themselves

periodically assess the effectiveness of their criteria and, as necessary formulate new
ones. We have regularly gone through such processes in New England and will soon
set about this task anew.

Recently, we undertook an evaluation of our standards,

seeking the views of member colleges and universities through such individuals as chief
executive officers, chief academic officers, and self-study leaders, that is persons
knowledgeable about our accreditation and its processes. We also polled evaluators
and, as it were, the consumers of our accreditation, employers of college graduates.
Our revision process, once begun, will continue to seek this input through a series ofmeetings with member institutions. Where thought needed, new criteria will be draftedby committees of institutional representatives. We will go through a lengthy comment
period allowing institutions to react to any changes, before new standards are finallyadopted. This process also results in a sense of ownership of and commitment too thestandards. The point of this detail is to suggest that accreditation is and should behighly participatory. That the very nature of self-regulation mandates the thoughtful
involvement of institutions if it is to be effective.

Turning our attention to how these standards are applied, let us begin with self-study. It
is important to think of self-study in two ways, first as a process and then as a product.
The process.

Essentially, this is typically a two-year effort largely about broadly

participatory candid self-analysis and reflection which seeks to measure the institution
against the standards for accreditation.

Its purpose is primarily improvement.

8

Institutions essentially assess their own effectiveness with an eye to identifying
strengths and ways to maintain and improve them as well as concerns which need to beaddressed if the institution’s success in fulfilling its purposes is to be enhanced. It isalso a product in the form of a report, a document of about 100 pages which relates thefindings of the process of self-assessment. This report serves as a basis for further
review for accountability purposes.

The process itself is most often characterized by a committee structure topped by asteering committee, which gives leadership to and directs the process as a whole, andsub-committees, each of these responsible for one of the standards. Who is on thesecommittees? A broad range of faculty and administrators. Most often, the process is
led not by the president; generally CEOs are at arm’s length from day-to-day self-study
activities. Nor is the chief academic officer usually in charge. Self-studies are mostoften directed by a senior academic knowledgeable of and experienced with theinstitution.

Similar individuals make up the various committees.

While responsible

administrators may be involved with a particular subcommittee but not in leadershiproles, e.g., librarians would certainly serve on the library sub-committee, they do notchair it. In this way, we believe, the process, while it has some risks, can be more
searching and productive.

The various subcommittees and the steering committee spend their time thoughtfully
considering, often debating, how well the institution meets the relevant standard,offering a view of what improvements are necessary and how they might be achieved.
This, obviously facilitates one of the purposes of accreditation, institutional improvement.

I might also note that the commission I work for provides a two-day self-study workshop
in the fall to assist institution in understanding expectations as well as planning for theorganization of the effort. We include a special session for presidents, who while notexpected to be directly involved in the self-study effort, must understand its purpose andpossibilities for the institution and the necessity of giving to it importance by relating to
the institutional community their commitment to an effective and useful effort.

9

As a product, in the form of a 100 page report, the self-study is an exercise ingeneralization. This requires the winnowing of subcommittee reports to assure only
grain and not the chaff is found in the final document. Admittedly, this is not an easytask. However, this distillation results in a focus on broad, often systemic, institutional
issues, issues that cut across organizational and program boundaries. It also assuresthe usefulness of the process for improvement by precluding an emphasis on minutiae
and the trivial.

We ask that the document’s format be comprised of three components: description,
appraisal, and projection. The first, description, seeks to describe the institution in its
current state of development against the standards for accreditation. This is meant tobe a largely factual exercise. Appraisal is meant to assess how well the standards aremet.

This is in many ways the most critical component which demands not only

considerable professional judgment but also great candor. Finally, there is projection.
Here the institution is asked to outline the steps it will take in response to its own
findings to preserve and enhance strengths while also addressing those areas in needof improvement. Thus, the self-study is a blue print for institutional development. In thissense, self-studies have a life outside of the accreditation process by serving
institutional purposes aimed at improvement.

A moment ago, I mentioned the importance of candor. Clearly, honesty and frankness
are essential elements of effective self-appraisal. Without them, the self-study is likely
to be no more than public relations document.

Implicit in this observation is anunderstanding that improvement only comes with candor and the identification of issues
to be addresses, with acceptance of the idea that no college or university is perfect andthat all should strive to improve. Admitting weaknesses, finding deficiencies is not afault, rather it is a strength.

Do our institutions take self-study seriously? Particularly those of great prestige eventhough their accreditation is unquestioned? The best evidence is found in their self-10

studies, many of which are posted on the World Wide Web. I would encourage each of
you to spend some time, for example, reviewing the self-study report of Yale University.

The self-study report is the primary document used by our committees which undertakethe actual evaluation of colleges and universities. Essentially, the task of these groupsof peers is to validate the self-study. If they find a document is which not candid andforthcoming, which endeavors to hide difficulties, the conclusion that they draw is thatthe is unaware of the challenges it faces, or worse, that it seeks to deceive, something
unlikely to succeed.

What of the evaluation process? It is important to understand that the accreditation
process in the States is heavily dependent on volunteers. We have a small staff; thecommission I work for has four professional and three clerical staff, with an annual
budget of approximately $1,000,000 – this to oversee about 200 institutions. In addition
to offering leadership in matters of policy, its formulation and application, and otherwise
relating and assuring that commission expectations are fulfilled, the staff’s task is to
manage and coordinate the evaluation process.

The actual work of evaluation is carried out by unpaid volunteers, faculty andadministrators from accredited colleges and universities.

This kind of voluntarycommitment is seen in all aspects of the commission's work; hundreds give of their timeand expertise every year.

Obviously, this kind of committed participation is a key

element in fulfilling the self-regulatory character of accreditation.

Why do people

volunteer, spending considerable time in preparation and the actual work. First, it isinteresting and professionally rewarding. If you are an academic interested in higher
education and concerned with your own professional development, you benefit fromexamining and learning from seeing another institution. Beyond that, there is an implicit
recognition that without voluntary efforts, accreditation won’t function properly, and thealternative, governmental intervention, something seen as deleterious to higher
education, is the likely result. So, there is a kind of carrot and stick at work here.

11The commission in putting together its evaluation committees draws from a list of
approximately 800 individuals. We endeavor to include senior and respected persons
with considerable experience, important characteristics given that the task is essentiallyabout applying professional judgment. This group covers the full range of institutions bytype and size as well as includes the expertise necessary to apply the various
accreditation standards. Thus, for example, the President of Yale University is one of
our evaluators, as is a student service officer from a small two-year junior college. We
seek to maintain a cadre of individuals who have experience in our process, but as amembership organization, we also constantly add new persons to our list of possible
evaluators, seeking to broaden and deepen institutional participation.

Our teams, which again actually visit the institution with the task of determine if
accreditation standards are met, vary in number depending on the size and complexityof the college or university under scrutiny. A team can be as small as three, but israrely larger than 10. Each team must include individuals knowledgeable about theseveral standards to assure that they are applied appropriately. Typically led by a chief
executive or chief academic officer, but occasionally a faculty member or dean, a teamwould include several faculty, a librarian, a student service officer, and an individual withknowledge of administration and finance.

The concept of peer is important in team selection. Remember, we have mission driven
standards, so it is critical that the individuals applying them have an appreciation of thenature and content of the institution they will be assessing. Thus, for example, it would
do no good to have a team of individuals from research universities with a highly
selective admissions policy evaluating a small junior college. Also, it is important, if theprocess is to have validity, for the team to be respectable and creditable in the eyes of
all involved.

Most of our teams are comprised of individuals who have served before, but we also try
to include new persons on each visiting committee. Prior to going out, we provide

12training not only to assure an understanding of the process but also an appreciation of
the expectations the commission has of them.

Our evaluation visits usually begin on a Sunday afternoon and conclude by the noon
hour on Wednesday. This is period of highly intense and concentrated activity; the days
are long and the nights short. How do teams spend their time? They do so collectively
and individually. The first activity is a joint team meeting and they also get together atthe end of every day to discuss their findings and seek consensus on the conclusions
they need to reach. In such meetings they work as colleagues, in principle each equal
to the other in terms of their relevance and potential contribution to the success of theprocess.

To be sure, the team chair is important, but if he or she does their job

effectively, they will not dominate the process, rather the will facilitate it, working toward
a common effort in which all participate and advance the success of the effort. In thisregard, the goal is to create a sense of ownership as well as a sense of commitment to
the work of the team as a whole. We want no prima donnas, rather a strong collective
enterprise where the contribution of each is important and distinctive.

Apart from their evening meetings, the team mostly works in small groups or as
individuals. Their work is primarily interviewing institutional personnel; though someeffort is also devoted to reviewing institutional documents. This activity reflects at once
their individual expertise as well as their assignment. Evaluators are given specificstandards to apply.

For example, as one might guess, the librarian on a team is

responsible for the standard on the library. But this means more than visiting the libraryand discussing its effectiveness with its staff. In addition, such a member of the teamwould want to have interviews with individuals who use the library – faculty and students– as well as the academic leadership of the institution.

Important committees are interviewed, e.g., curriculum and promotion and tenure.
Trustees meet with the team and we always ask that teams hold open meetings whereanyone from the college and university can come to say whatever the believe the teamshould hear.

13

As noted, the essential task of evaluation in the process I am describing is to validate
the self-study. And like the self-study process, candor, openness, and an unfetteredwillingness and ability to identify both strengths and weaknesses are essential on thepart of both the institution and team in the evaluation process. We recognize that some
aspects of accredited institutions are stronger than others, that weaknesses do exist,
and to be sure it is the task of the team to uncover them, or better to substantiate theinstitution’s self-study findings in this regard. The end here is not to tote up deficiencies,
to point the finger of criticisms for its sake alone, to be inspectors wearing white gloves
seeking to identify every deficiency that they can find. Rather evaluators function as
critical colleagues whose task is to assist the institution in its strive for excellence,something that cannot be done except though forthright analysis. To be sure, the teammust come to a conclusion about whether or not the institution fulfills the standards forpurposes of accreditation, but most of the team’s time is spent on how to assist theinstitution in its improvement. For us, the identification of weaknesses is not something
to be feared, but rather it is a way toward betterment.

Evaluation teams conclude their work by presenting an exit interview to the institution’s
leadership. Essentially, what is provided here is a summary of team findings which at
the end is expressed in a list of major institutional strengths and concerns, oropportunities for improvement.

As with self-study, these evaluations, is necessarily broad brushed. The resulting teamreport, again like the self-study, is an exercise in generalization.

Our visiting

committees can at most do a kind of sampling with the evaluative emphasis frankly
varying somewhat among accreditation reviews at different institutions; they lack a kindof bureaucratic consistency, the result of non-professional peer participation and aprocess that recognizes the fact that different things are important at a given moment at
different universities. Thus accreditation reports of evaluation committees, while they allreflect certain essentials, are not exhaustive and comprehensive renditions assessing
the institution in detail. Furthermore, they do not engage in comparisons of one

14

institution against others; remember each is evaluated on its own merits against
mission-based standards for accreditation.

Reports seek to address broad issues

facing the college or university. The task is to be diagnostic, not prescriptive; teamreports identify problems but don’t provide solutions. In the spirit of accreditation, ourcommitment to institutional autonomy preclude us from doing so.

Reports, which are drafted by the teams themselves, are rarely longer than 30 pages.
(Examples are available on the Web; those interested can use the handout provided foraccess to these documents.)

They provide a summary of team findings and areconcluded, again by a summary list of strengths and concerns as related at the exit
interview.

As with everything else I have related, candor and frankness must

characterize these documents if the are to be useful. To be sure, its important that they
be cast in a helpful, rather than hurtful manner.

While the parts of the report are initially drafted by individual members of the team, thefinal document is prepared by the team chair.

And once the penultimate report iscompleted, it is sent to the institution for correction of errors of fact.

And, upon

submission of the final report to the institution, the president is asked to prepare andsubmit a written response to the report, giving emphasis to those activities undertaken
subsequent to the visit designed to address its findings.

Of course, the work of accreditation is not done with the completion of the team report.
It must be considered as a part of the final step of the process, action by theCommission on Institutions of Higher Education on the institution’s accreditation. Here,like every other step of the process, accountability and improvement, the dual purposesof accreditation, are mixed. But before discussing this last aspect of our process let me
relate a description of the commission itself.

Comprised of 18 individuals, it is elected by the member colleges and universities. Itstasks are two fold. First, it is the policy making body; it determines the standards foraccreditation, following the consultation process discussed earlier, as well as sets15

polices for their application. Second, it reviews and takes action on the accreditation ofindividual institutions. In other words, they both fashion and apply accreditation policy.

15 of the commissioners come from accredited institutions. Like members of evaluation
teams, they are faculty and administrators. Too, like our teams, they represent thevarious areas of institutional activities reflected in the standards.

Thus the current

commission includes chief executive and chief academic officers, faculty, librarians, anacademic dean, and individuals with expertise in student services and well as
administration and finance. The commission also reflects the range of member colleges
and universities by type.

We have both public and independent institutional

representation on the commission, persons for research universities as well as two-yearcolleges, and many in between.

Three commissioners are what we call “public members,” that is persons who have noaffiliation with an institution. They are there to represent the public’s interest. We
believe that higher education exists to serve the common good, to advance the wellbeing of society. Given the importance of accreditation in fulfilling broad societal goals,
we are convinced that the public has an interest in the work of the commission, that it isultimately accountable to the public, and this is best done though these public members
who are considered in every way equal in terms of their voice and vote on matters
before the commission.

The commission meets four times a year, two days at each meeting. While some time
is given over to policy discussion, most of their efforts are devoted to considering
institutional reports and taking action on accreditation. At least some members of thecommission receive full sets of institutional documents: self studies and relatedmaterials, the team report and institutional response. All members of the commission
receive and read each team reports, of which there maybe as many as 20 to consider ata meeting. The agenda book may be several inches thick, not counting self-studies.

16

By way of process, the Commission first has discussions by itself, but also meets withthe team chair and the president of each institution evaluated. Essentially, the task is todetermine if the visiting committee came to appropriate conclusions. The team makes arecommendation to the commission regarding accreditation as well as any follow up
activities believed necessary. The commission considers this and may modify it as they
believe necessary.

Commissioners take their role very seriously; they work hard;commission meeting are intense; and the focus of attention is on the dual purposes ofaccreditation – accountability and improvement.

They too function more as criticalcolleagues than officious inspectors, their goal is to facilitate improvement, but when
they find serious deficiencies which threaten accreditation, the do take negative actions,something necessary if they are to fulfill their public responsibility.

A word or two about the actions taken by the commission which I think will give further
and maybe some concluding insights into the accreditation process. As noted, action istaken on accreditation. That is a determination is made whether to grant or continue
institutional accreditation.

But it doesn’t stop there.

Accreditation is an ongoing

relationship between the institution and the commission.

Thus, in its action, thecommission will also identify what it expects from the institution in the future. Amongother things, the timing of the next evaluation will be identified. If there are concernsthat have been identified, an interim report may be requested on those concerns. It
may be followed by an evaluation visit focused solely on its content. Most institutions
are placed on a ten-year evaluation cycle, that is comprehensive visits, the sort of visit
preceded self study as I have describe, occur decennially. All institutions on this cycle
must submit a report at the fifth year. Here too, the Commission will identify matters to
be particularly addressed in the interim and reported on. Thus improvement thoughaccreditation is ever before the institution. Of course, it is desirable that there be a clear
connection related to improvement at each stage of the process that I have described.
That is, this process works best when the findings of the self-study are validated by thevisiting committee in its report, which in turn find their way into the commission’s action.
Throughout,efforts are directed toward the identification of those important issues which
the institution should address if it is to improve. Candor, the capacity to self-criticize

17and to accept constructive criticism are critical elements in the success of the effort at
the institution.

Let me turn in conclusion to some suggestions as to what might be learned from ourexperience with accreditation. It is not my intent to offer up the American model for
adoption in its detail. There are some principles, however, which we have learned fromour experience which are, I believe, applicable in any system of higher learning
contemplating the implementation of an evaluative processes.

The first principle is that institutions of higher teaming should regulate themselves. The
self that I am referring to here, is the community of higher education, all the institutions
taken together, or at least appropriate sets. I believe that given the singular character ofhigher education and its special role, societies are best served if our colleges anduniversities, individually or collectively manage their own affairs.
Several ideas stand behind the principle:1

1) Self-regulation is preferable to and in the long run more effective than any
form of external regulation.

2) Any system of external regulation can be effective only to the extent that itrecognizes and builds upon a group’s willingness to engage in selfregulation.

3) A substantial number of people and institutions will regulate themselves alongagreed upon lines if they know what behavior is expected by the groupand why.

1

Adapted from Understanding Accreditation, Kenneth Young, ed.

184) An overwhelming majority of people and institutions will regulate themselves
along agreed upon lines if they believe that they might be identified bypeers as not doing so.

5) Only a small number of people and institutions will deliberately engage inbehavior that they know will be disapproved by the larger group.

Nomatter how many laws are passed or rules written or inspectors hired,antisocial behavior by these types cannot be inhibited or prevented.

Are there flaws in the self-regulatory framework? Of course. As Winston Churchill once
said of democracy, it is the worst form of government, except all those other forms thathave been tried from time to time. This applies to self-regulation, a form of democracy.
It is not a perfect approach, there is none. Its chief defect is that it can be self-serving.
Institutions and programs, in charge of their own destiny, can be accused of having atendency to undertake their self-regulatory activities in a way least burdensome andmost beneficial and which does not always result in desired ends. This happens as
individuals forget that autonomy carries with it obligations. Indeed, there are probably
greater obligations for self-regulating institutions than for those subject to only external
control.

Essentially, self-regulation calls for self-restraint, for a willingness tosubordinate personal or institutional desires to greater demands. We can never forgetthat institutions of higher learning exist to serve the public good.

While life in theacademy can be pleasant and rewarding, the purpose of the university is not to serve
those who work there, bit rather to create a framework for the public good to be served.
There is a need to balance rights and responsibilities, though a perfect balance cannever be achieved; tensions will always exist between external needs and internal
control. There are no easy and universally applicable solutions to matters such asthese. They require continuing attention.

Certainly, the self-regulatory approach is more likely to achieve one of the primary goalsof evaluation: improvement. This then is the second principle I would like to enunciate
as validated by our experience in the States: a primary purpose of evaluation should be

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improvement. There is a corollary here, bringing these two principles together. In the
self-regulatory framework, evaluation if it is to be about improvement, should be initiatedas an internal process.

While self-regulatory evaluative mechanisms can be designed in a variety of ways -- I
would offer no set formulas here -- regardless of how organized, evaluative efforts
should also assist in, and otherwise lead to, the encouragement of improvement,
effectiveness, and excellence of affected institutions or programs. These things must
initially come from within the institution, they cannot be imposed from the outside. As I
will state later, external evaluation is a necessary component of any quality control
process, but without this internally generated improvement component, external
evaluation is capable of much mischief.

Let me build on these ideas here a bit. In referring to internal evaluation I am talking
about self-study.

As we have seen, in our evaluative scheme of accreditation,

institutions as the first step of the evaluative process engage in an introspective analysisof the institution against certain criteria.

In many ways, we believe that the self-study as process -- the very act of engaging in asearching self-criticism -- is more important than the resulting written report. As I havenoted, what we ask in self-study is that the various elements of the community be
engaged to reflect on the purposes and effectiveness of the institution, to examine its
strengths as well as its weaknesses, and where problems or opportunities are identified,
to begin to work toward their solution or fulfillment. Our experience has been that thegoals of self-study as a device for institutional improvement are most likely to beachieved when there is a sense of ownership and commitment. This can only occur
within the self-regulatory framework. Indeed, if this sort of meaningful self-review does
not occur, of course, the validity of self-regulation is placed in question.

However, I believe it is difficult to establish confidence in institutional performancethrough only self-study or internal evaluation. To be sure, many benefits can accrue to20

the institution. There are numerous evaluative models which are purely internal which
demonstrate this. But their primary goal is improvement not quality assurance.

This brings me to my next principle -- meaningful assurance about institutional quality isbest developed through a scheme of external evaluation. There are some corollaries
here drawn from other principles: The best external evaluation is based upon a selfregulatory model.

External evaluation should build upon or otherwise be keyed toexisting efforts at self-study or internal evaluation and in so doing foster excellence
while also providing assurance about program or institutional quality.

Let me expand. Internal evaluation activities do little, in and of themselves, to convince
those outside the academy -- governmental officials, legislatures, the citizenry ingeneral -- that quality exists or that the institution is living up to its potential in serving
the public interest or, put more simply, that the institutions receiving public support are
doing what they should be doing. At best, self-study efforts are not understood, and, atworst, they are seen as self-serving exercises which are either designed to cover up
institutional deficiencies or to squeeze the public purse for more support. Except in rarecases, few decision makers outside the academy will place credence in an institution'sor programs self-proclaimed quality. This was not always the case, but it is increasingly
so, and they can't be blamed for it.

Therefore, external validation must exist if there is a need to demonstrate the existenceof quality, and there increasingly is such a need. But like internal evaluation, schemesfor external evaluation should be based upon a self-regulatory model. A few moments
ago, I gave the rational for self-regulation. It applies to internal and external evaluation
equally well. But aren’t external evaluation and self-regulation incompatible? I think not,and our experience demonstrates the possibility, indeed, the preferability, of combining
the two.

Any number of formats can be devised, but they should have in common certain
elements. The first is peer review. The best judges of programs or institutions are21

practitioners from other institutions which have similar goals.

But they must be

demonstrably free of bias and apply standards for evaluation which have been agreed
upon by the group. We find it useful to engage another body of peers to review the
work of this primary group or groups to assure the reliability and validity of their findings.

Possibly one of the best reasons for undertaking external evaluation through a systemof peer review is that there is a greater likelihood that institutional improvement will
result while at the same time providing effective quality control. Peers tend to be lessthreatening, except where threats are needed, than outsiders. Thus, there is a greater
possibility of openness and frank assessment in the self-study phase as well as during
any form of external evaluation. Peers are more likely to understand and appreciate theunusual character of higher education, and as peers, knowledgeable of how the system
operates, they are less likely to be victims of deception.

External assessment is compatible with the encouragement of improvement. There
should be a natural link between the two which, while not without tensions, in effectresults in the mutual strengthening of both processes. To that end, it seems to me thatwhat any group of outside evaluators ought to be about is complimenting the internal
evaluation undertaken by the institution or program.

They should provide quality

assurance while also facilitating improvement, assessing while encouraging, judging
while helping.

Are there problems in undertaking external evaluation through self-regulation?

Ofcourse. Chief among them is an issue of credibility. Can higher education really be
expected to police itself?

The only way that interested individuals -- ministers,

legislators, businessmen, students, the public -- will be convinced that this is possible isfor higher education to do the best job it can: to be stronger self-critics than anyone
external to the academy would think of being, to establish and insist on compliance withthe highest of standards, and to be uncompromising when confronted with rot. As aresult, no one will be able to develop a case for anything but self-regulation, and theinstitutions and the public they serve will be the true beneficiaries.

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If a basic purpose of evaluation, internal or external, is improvement of quality, it is fair
to ask what is quality? Without some sort of definition, will an institution in self-study ora group of external evaluators know quality when they see it? Clearly, both forms ofevaluation, given what I have said here, should be working with the same definition.
Both must have a sense of direction, they must have a concept of the goal they are
striving to achieve.

This brings me to my next principle -- institutions or programs

should be evaluated, internally or externally, against their own stated purposes.

This principle, as we have seen, is reflected in our mission-driven standards, thesummary of which is best expressed in a series of questions:

1) Does the institution have appropriate purposes or goals?

The concerns here are several.

First, the goals or mission must be relevant andsuitable. It must be derived through a thoughtful process and it must give direction to allof the institutions activities.

The very process of developing a commonly accepted

understanding mission has great value.

2) Does the institution have sufficient resources to achieve its purposes?

Resources here are conceived broadly.

Some are obvious -- laboratories, faculty,

library -- but resources can also include curriculum, governance, and intangibles like
commitment, understanding, and leadership. Also involved is the proper organization ofthese resources.

3) Is the institution in fact, achieving its objectives?

This is, of course more difficult and represents a central dilemma in our system ofhigher education. Just how do you measure whether or not an institution is effective ornot? Difficult question. Clearly some things are not measurable, but others must be.

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We have not, nor do we intend to, develop a universal set of measures. Within theframework of self-regulation suggested here, institutions themselves should derive theirown mechanisms for assessing the achievement of its own goals.

But thesemechanisms and the findings which result from their implementation should beexternally validated.

4) Lastly, does the institution give evidence that it has the capacity to continue tofulfill its purposes?

Obviously, here we are concerned with the future.

Institutions should organize

themselves so as to continue to have the ability to achieve institutional goals. Planning
is important here, but so are clearly subjective considerations, such as vision.

Quality then, is the effective organization of sufficient resources to achieve institutional
goals now and into the future. Of course, it is necessary to take this paradigm andexpand on it with particulars so as to make it apply to specific situations, again as wehave done with our accreditation standards.

All of this can be said to be subjective and open ended. But, I believe that it is greatly
preferable to any more explicit or numerical standards. Experience with such standards,
apart from those which relate health and safety, have not generally been satisfactory.
Education and educational systems are too complex and appropriately varied for quality
to be reduced to a formula. Such formulas do not serve us well.

So far, I have given you a number of interrelated principles which I believe are importantfor effective evaluation. Through their application, internal and external evaluation canbe brought together effectively not only to provide appropriate quality assurance but
also to foster improvements in quality all to the end of serving the public good. However,I would leave you with one last principle -- systems of external evaluation designed toprovide public quality assurance should be accountable to the public they serve.

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In the United States we refer to accrediting agencies such as the one I work for, as
quasi-public. That is, they are private organizations -- in this case and association ofmember or accredited colleges and universities -- but they fulfill a public role or purpose.
Government depends on our activities in lieu of maintaining its own system of quality
assurance. We have a public responsibility and it is reasonable to be held accountable
for the demonstration that we are effectively fulfilling that responsibility through oursystem of internal and external evaluation and peer judgment and in doing so ultimately
serving the public interest.

This demand for accountability, however, cannot be heavy handed. It is best achieved
through a general oversight which applies reasonable criteria in a process of periodic
review. Such criteria should never be prescriptive nor provide the specifics of quality
assessment. To do so would work to destroy the very idea of self-regulation. The
frequency and nature of reviews of compliance with these criteria is best left to local
circumstance.

Indeed, here more than anywhere else, local customs, culture, andpolitics should dictate the precise nature of this aspect of the evaluative process.
However, it should not result in interference with quality assessments nor should it
review of actual decisions about quality.

Let me conclude by saying that I hope you found my words useful and meaningful andthat you find some application of them for your circumstances. It has been my pleasure
to work with Japanese educators over the years, and I look forward to continuing ourcollaboration.

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