HIGHER EDUCATION

Expert Views of U.S. 

Accreditation

Report to Congressional Requesters

December 2017

GAO-18-5

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-5, a report to 

congressional requesters

December 2017

HIGHER EDUCATION

Expert Views of U.S. Accreditation

What GAO Found

The U.S. accreditation system—which helps to ensure that schools provide 

students with a quality education—has some key strengths, according to many of 

the experts GAO convened in a roundtable on the issue, as well as what was 

reported in literature GAO reviewed and interviews it conducted. Specifically, 

experts said the structure of the accreditation system, which includes 

nongovernmental accrediting agencies recognized by the Department of 

Education (Education), allows for accreditor reviews that are tailored to various 

school types, from medical to cosmetology schools. Experts also said the use of 

peer review by academic faculty and administrators offers the relevant expertise 

to assess academic quality and provide schools with feedback for improvement. 

However, some experts, literature GAO reviewed, and interviews identified 

challenges with the accreditation system’s oversight of academic quality. For 

example, some experts and literature stated that accreditors may be hesitant to 

terminate schools’ accreditation when they identify issues because such action 

would adversely affect schools’ eligibility for federal student aid programs, 

potentially leading to school closure. Many experts also said the accreditation 

system may not provide useful information to students about academic quality. 

Further, most experts and literature identified challenges with how to effectively

define and measure academic quality. For example, experts said it can be 

difficult for accreditors to measure academic quality in fields without quantifiable 

outcomes, such as pass rates for professional licensing exams.

Potential approaches to improve the U.S. accreditation system’s oversight of 

academic quality range from modifying accreditors’ and Education’s current roles 

to restructuring the current system, based on experts and GAO’s literature 

review. While experts cautioned that there could be potential disadvantages to 

these approaches, the proposals for addressing oversight challenges included:

• Modifying oversight roles and responsibilities: Some experts suggested

clarifying or redefining responsibilities, including those of accreditors and 

Education; providing protections for accreditors from legal action by schools;

and allowing Education to set and enforce accreditation standards for student 

achievement. 

• Strengthening communication and transparency: Some experts 

proposed sharing more accreditor information to help students, policymakers, 

and the public make informed decisions on investments in higher education. 

• Using academic quality measures and expanding accreditation options: 

Some experts proposed increasing accreditors’ focus on student outcomes in 

assessments of academic quality. A few experts proposed adding an 

accreditation category that would allow a school to maintain its federal 

student aid eligibility at a reduced level while making improvements.

• Changing the structure of the accreditation system: GAO identified four 

approaches in the literature—three of which were developed by roundtable 

experts—to establish new entities to set standards for assessing schools’ 

academic quality. These approaches differ in how they assign oversight 

responsibilities, such as assessments and monitoring.

View GAO-18-5. For more information, 

contact Melissa Emrey-Arras at (617) 788-

0534 or emreyarrasm@gao.gov.

Why GAO Did This Study

Education provided more than $125

billion in federal student aid funds in 

fiscal year 2016 to help students pay 

for higher education. To participate in

federal student aid programs,

postsecondary schools must be 

accredited by an accrediting agency 

recognized by Education. Accreditors 

work with Education to oversee 

participating schools and play a critical 

role in assessing academic quality.

GAO was asked to review the U.S. 

accreditation system’s oversight of 

academic quality.

This report examines (1) the strengths 

and challenges of the current U.S. 

accreditation system in overseeing the 

academic quality of schools, and (2) 

potential approaches for improving the 

U.S. accreditation system’s oversight 

of academic quality. GAO convened a 

roundtable of 18 experts with the help 

of the National Academies of Sciences, 

Engineering, and Medicine, a nonprofit 

agency whose mission includes 

informing public policy decisions, and 

surveyed the experts before and after 

the roundtable meeting. GAO also 

conducted a literature review, reviewed 

relevant federal laws and regulations 

and Education documents, and 

interviewed Education officials and 

higher education stakeholders, 

including academic researchers.

In its comments, Education stated that 

it is reviewing the report carefully as it 

works to improve postsecondary 

education opportunities for students 

and its role in the accreditation 

process.
Page i GAO-18-5 Views on Higher Education Accreditation

Letter 1

Background 4

Experts Cited Strengths and Challenges with the Accreditation 

System’s Oversight of Academic Quality 11

Potential Approaches Identified by Experts and the Literature for 

Improving Oversight of Academic Quality at Schools Range 

from Modifying Roles to Restructuring the Accreditation System 30

Agency Comments 44

Appendix I Objectives, Scope, and Methodology 45

Appendix II Participants in GAO Expert Roundtable 

on Higher Education Accreditation 52

Appendix III List of Research and Policy Papers GAO Reviewed 54

Appendix IV Student Outcomes by Accreditor Type 60

Appendix V Other Potential Approaches Discussed 

at GAO’s Expert Roundtable 63

Appendix VI Summary of Approaches for Changing the 

Structure of the Accreditation System 66

Appendix VII Comments from the Department of Education 75

Appendix VIII GAO Contact and Staff Acknowledgments 76

Contents
Page ii GAO-18-5 Views on Higher Education Accreditation

Tables

Table 1: Summary of Expert Views on Clarifying or Redefining 

Oversight Roles and Responsibilities 32

Table 2: Summary of Expert Views on Providing Accreditors with 

Protections from Legal Action 33

Table 3: Summary of Expert Views on Repealing the Statutory 

Provisions That Prohibit Education from Setting and 

Enforcing Accreditation Standards for Student 

Achievement 34

Table 4: Summary of Expert Views on Improving Accreditation 

Communication and Collaboration 36

Table 5: Summary of Expert Views on Increasing Transparency of 

Accreditation Oversight Information 37

Table 6: Summary of Expert Views on Focusing on Student 

Achievement and School Performance 39

Table 7: Summary of Expert Views on Expanding Accreditation 

Options 40

Table 8: List of Expert Participants in GAO Higher Education 

Accreditation Roundtable Held September 29-30, 2016 52

Table 9: Summary of Expert Views on Re-examining 

Requirements for Different Types of Accreditors 64

Table 10: Summary of Expert Views on Developing a Common 

Accreditation Language 65

Table 11: Establishing an Independent Authorizer to Approve 

Innovative Educational Program Providers 67

Table 12: Establishing Third-Party Entities to Set Standards and 

Thresholds, Based on Student Outcomes 69

Table 13: Establishing a Higher Education Quality Assurance 

Commission to Coordinate with Accrediting Agencies 71

Table 14: Establishing a Congressionally Chartered Accreditation 

Governance Entity 73

Figures

Figure 1: Roles and Responsibilities of Members of the Higher 

Education Oversight Triad 5

Figure 2: Types of Accrediting Agencies Recognized by the 

Department of Education and Their Postsecondary 

School Membership, as of June 2017 8

Figure 3: Sample Accreditation Process for Postsecondary 

Schools 9
Page iii GAO-18-5 Views on Higher Education Accreditation

Figure 4: Key Challenges, Identified by Experts, of the Current 

Accreditation System that Can Affect Oversight of 

Postsecondary Schools’ Academic Quality 15

Figure 5: Categories of Potential Approaches, Identified by 

Experts and the Literature, for Improving Oversight of 

Academic Quality 31

Figure 6: School-Level Student Outcomes for Regional, National, 

and Programmatic Accreditors’ Member Postsecondary 

Schools 61

Abbreviations

Education Department of Education 

Higher Education Act Higher Education Act of 1965, as amended

National Academies National Academies of Sciences, 

Engineering, and Medicine

NACIQI National Advisory Committee on Institutional 

Quality and Integrity 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

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Page 1 GAO-18-5 Views on Higher Education Accreditation

441 G St. N.W.

Washington, DC 20548

December 22, 2017

The Honorable Rosa DeLauro

Ranking Member

Subcommittee on Labor, Health and Human Services, Education, and 

Related Agencies

Committee on Appropriations

House of Representatives

The Honorable Richard Durbin

United States Senate

The Honorable Brian Schatz

United States Senate

In fiscal year 2016, the Department of Education (Education) provided 

over $125 billion in assistance to help more than 13 million students 

pursue higher education. These funds were provided to students and 

families through federal student aid programs authorized under Title IV of 

the Higher Education Act of 1965, as amended (Higher Education Act).1

To help ensure that postsecondary schools with access to federal student 

aid provide a quality education to students, the Higher Education Act 

requires schools to be accredited by entities recognized by Education as 

reliable authorities on assessing academic quality. These recognized 

accreditors must regularly assess the schools they accredit using 

standards covering areas specified by the Higher Education Act, and take 

actions, such as issuing sanctions, when schools do not meet the 

standards that accreditors establish for them. Education provides 

oversight of federal funds by monitoring schools’ compliance with federal 

student aid requirements and collecting data on student outcomes and 

school finances.

 1

Title IV of the Higher Education Act is codified at 20 U.S.C. §§ 1070 – 1099d. In order to 

participate in federal student aid programs authorized under Title IV (referred to in this 

report as “federal student aid programs”), schools must meet the act’s definition of an 

institution of higher education, which provides, in part, that in addition to being accredited, 

such schools must be authorized to provide postsecondary education by the state in which 

they are located. Schools must also be determined to be eligible and certified by 

Education as meeting certain administrative capability and financial responsibility 

requirements. In this report, we use the term “school” or “postsecondary schools” to refer 

to an institution of higher education. 

Letter
Page 2 GAO-18-5 Views on Higher Education Accreditation

Recent school closures have displaced tens of thousands of students and 

resulted in hundreds of millions of dollars in financial losses for the federal 

government.2 Policymakers and other key stakeholders have raised 

questions about how effectively the U.S. accreditation system ensures 

academic quality at schools and protects students’ and taxpayers’

investment in higher education.3 In addition, in our December 2014 report 

we found that, on average, accreditors were no more likely to take action 

against schools with weaker student outcomes—measures that Education 

and researchers consider important indicators of educational quality, such 

as graduation and retention rates—than schools with stronger student 

outcomes.4

In light of these issues, you asked us to review the U.S. accreditation 

system’s oversight of academic quality.5 This report examines (1) the 

strengths and challenges of the current U.S. accreditation system in 

overseeing the academic quality of schools, and (2) potential approaches 

for improving the U.S. accreditation system’s oversight of academic 

quality.

 2

In April 2015, Corinthian Colleges Inc. permanently shut down all operations. The 

company had more than 100 schools nationwide at its peak, with total enrollments of 

approximately 72,000 students who annually received about $1.4 billion in federal student 

aid. According to a report by Education’s Office of Inspector General, the company ceased 

operations after Education placed it on an increased level of financial oversight because of 

its failure to address concerns about its practices, including falsifying job placement data 

presented to students. In September 2016, ITT Educational Services Inc. ceased all 

company operations, including online and classroom-based instruction, at 136 locations 

that enrolled approximately 35,000 students across the country. According to Education, 

ITT Educational Services Inc. reported about $850 million in total revenue in 2015, roughly 

$580 million of which was sourced from federal aid dollars. Education reported that this 

closure occurred after Education increased financial oversight measures due to significant 

concerns about the company’s non-compliance with its accreditor’s standards, financial 

viability, and ability to serve students, among other reasons.

3

In this report, we use the phrase “U.S. higher education accreditation system” broadly to 

describe the accreditation oversight bodies and processes used as part of determining 

schools’ eligibility to participate in federal student aid programs. This includes the activities 

of accreditors to accredit schools and the activities of Education to recognize accreditors. 

Accreditation is one component of oversight of higher education in the United States, for 

which Education, accreditors, and states all share some responsibility. 

4

GAO, Higher Education: Education Should Strengthen Oversight of Schools and 

Accreditors, GAO-15-59 (Washington, D.C.: Dec. 22, 2014). Education defines retention 

rates as the percent of first-time degree/certificate-seeking students who enrolled in one 

school year and either successfully completed their program or re-enrolled in the next fall.

5

In this report, we generally focus on academic quality as it relates to student achievement 

(also known as student outcomes).
Page 3 GAO-18-5 Views on Higher Education Accreditation

To address our objectives, we used a variety of data collection methods 

to obtain diverse perspectives on the current U.S. accreditation system 

and approaches for improving it. We worked with the National Academies 

of Sciences, Engineering, and Medicine (National Academies) to convene 

a roundtable of 18 experts to discuss the strengths and challenges of the 

current accreditation system’s oversight of academic quality, and potential 

approaches for improvement.6 These experts represented a broad 

spectrum of views and backgrounds from Education, policy organizations, 

academia, and other key higher education stakeholder groups, including 

associations and those representing accreditors, public and private 2- and 

4-year schools, state higher education officials, and students.7 We 

selected experts based on their experience and knowledge of higher 

education accreditation issues, and recommendations from the National 

Academies. To inform our discussion, we surveyed experts prior to the 

roundtable and quantified their responses to questions related to key 

accreditation strengths, challenges, and potential approaches to improve 

the U.S. accreditation system’s oversight of academic quality. We also 

surveyed experts after the roundtable to collect additional information on 

the approaches identified during the roundtable and the survey conducted 

before the roundtable.8 Further, we interviewed Education officials and 

other higher education stakeholders to obtain additional perspectives on 

key accreditation issues. We also conducted a literature review of 

publications published from January 2015 to June 2016 to gather 

additional information on the strengths and challenges of the current 

 6

The National Academies is a private, nonprofit organization whose mission is to provide 

independent, objective analysis and advice to the nation and conduct other activities to 

solve complex problems and inform public policy decisions. Our meeting of experts was 

planned and convened with the assistance of the National Academies to better ensure 

that a breadth of expertise was brought to bear in its preparation. However, all final 

decisions regarding meeting substance and expert participation are the responsibility of

GAO.

7

See appendix II for the list of experts who participated in our roundtable. We invited an 

association representing career postsecondary schools primarily in the for-profit sector to 

participate in the expert roundtable. The association declined to participate in the expert 

roundtable and related pre- and post-roundtable surveys; however, two representatives 

participated in an interview. Similarly, we invited an organization conducting projects 

related to higher education accreditation to participate in the expert roundtable. The 

organization was unable to participate in the roundtable; however, a representative 

participated in an interview and completed the pre- and post- roundtable surveys.

8

In this report, we refer to the survey we provided to experts prior to the roundtable as the 

“pre-roundtable survey” and the survey we provided to experts after the roundtable as the 

“post-roundtable survey.”
Page 4 GAO-18-5 Views on Higher Education Accreditation

accreditation system, as well as approaches to improve it.9 In addition, we 

asked roundtable experts and other stakeholders we interviewed for 

recommendations on relevant research. We also reviewed relevant 

federal laws and regulations, and Education’s relevant policies, guidance, 

and reports. Neither GAO nor the roundtable participants as a whole 

recommend or endorse the adoption of any of the potential approaches 

discussed in this report. Our study methods are summarized in greater 

detail in appendix I.

We conducted this performance audit from March 2016 to December 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

The primary purpose of accreditation is to help ensure that schools 

provide a quality education to students. While accreditation first arose in 

the United States as a means of ensuring academic quality through a 

nongovernmental peer review process, over time the process evolved 

and it currently serves as one of the bases for determining a school’s 

eligibility to participate in federal student aid programs. Accrediting 

agencies (or accreditors)—generally nongovernmental, nonprofit 

entities—work with Education and states as part of the “triad” that 

oversees postsecondary schools participating in federal student aid 

programs authorized under Title IV of the Higher Education Act (see fig. 

1). The roles and responsibilities of the triad are intertwined under the 

Higher Education Act. Accreditors oversee academic quality at schools by 

applying and enforcing standards for the schools they accredit.10 State 

agencies are generally responsible for licensing or authorizing schools to 

 9

In this report, we use the term “paper” to refer to the wide range of accreditation research 

and policy papers we reviewed. These papers included published papers by academic 

researchers, policy institutes and other organizations, and associations. See appendix III 

for a list of the papers we reviewed.

1020 U.S.C. § 1099b.

Background

Accreditation Process and 

Oversight Entities
Page 5 GAO-18-5 Views on Higher Education Accreditation

operate within their state.11 Education certifies schools’ eligibility to 

participate in federal student aid programs, and recognizes accreditors it 

determines to be reliable authorities on assessing academic quality.12

Figure 1: Roles and Responsibilities of Members of the Higher Education Oversight 

Triad

The Higher Education Act and Education’s regulations require accreditors 

to meet certain criteria and have certain operating procedures in place to 

be “recognized” by Education as reliable authorities on assessing 

academic quality.13 Accreditors must have their recognition renewed by 

Education at least every 5 years.14 To recognize an accrediting agency, 

Education officials and the independent National Advisory Committee on 

Institutional Quality and Integrity (NACIQI), which advises the Secretary 

 1120 U.S.C. § 1099a. In some cases, state agencies may also be approved by Education 

to accredit schools. 

1220 U.S.C. §§ 1099b, 1099c. Education also monitors compliance with federal student 

aid program requirements.

1320 U.S.C. § 1099b(a), (c); 34 C.F.R. pt. 602. Education is required to publish a list of 

accrediting agencies that the Secretary recognizes as reliable authorities on the quality of 

education or training provided by the schools they accredit. 20 U.S.C. § 1001(c).

1420 U.S.C. § 1099b(d).
Page 6 GAO-18-5 Views on Higher Education Accreditation

of Education on accreditation issues, must, among other 

responsibilities:15

• review and assess accreditors’ compliance with Education’s 

recognition criteria, including standards, policies, and procedures in 

areas required by statute;

• evaluate whether accreditors apply their own standards, policies, and 

procedures when they accredit schools; and

• each make recommendations on whether and for how long an 

accreditor should be re-recognized to Education’s Senior Department 

Official who is designated to make the decision regarding 

recognition.16

The Higher Education Act identifies specific areas—such as student 

achievement and curricula—in which recognized accreditors must have 

standards (see sidebar).17 The standards must respect the stated mission 

of the school, and accreditors are required to assess schools’ compliance 

with these standards to ensure the courses or programs offered are of 

sufficient quality to achieve their stated objectives.18 The specific 

standards that accreditors develop in these areas can differ, and 

accreditors may also establish additional standards in areas not required 

by law.19 For example, accreditors may evaluate schools based on 

governance, which helps ensure that the board, the school administration, 

and the faculty each have responsibilities according to their expertise and 

 15NACIQI advises the Secretary of Education on matters related to postsecondary 

accreditation and the eligibility and certification process for postsecondary schools to 

participate in federal student aid programs. NACIQI is comprised of 18 members. The 

Secretary of Education appoints six members, and the majority and minority leaders of 

both the House of Representatives and the Senate each appoint three members. NACIQI 

members are appointed on the basis of their technical qualifications, professional 

standing, and demonstrated knowledge in the fields of accreditation and administration in 

higher education. 20 U.S.C. § 1011c. 

16In the event of an administrative appeal, the Secretary of Education makes the final 

recognition decision.

1720 U.S.C. § 1099b(a)(5). The Higher Education Act does not dictate the specific content 

of accreditors’ standards and prohibits Education from developing regulations with respect 

to these standards. It also prohibits Education from establishing criteria that specify, 

define, or prescribe standards for accreditors to use to assess any school’s success with 

respect to student achievement. 20 U.S.C. § 1099b(g),(o).

1820 U.S.C. § 1099b(a)(4)(A). 

1920 U.S.C. § 1099b(g). 

Areas in Which Accreditors Are Required 

to Have Standards 

1. Success with respect to student 

achievement (standards may be 

established by the school and differ 

according to its mission)

2. Curricula

3. Faculty

4. Facilities, equipment, and supplies

5. Fiscal and administrative capacity

6. Student support services

7. Recruiting and admissions practices

8. Measures of program length and 

objectives

9. Student complaints

10. Compliance with federal student aid 

program responsibilities

Source: 20 U.S.C. § 1099b(a)(5). | GAO-18-5
Page 7 GAO-18-5 Views on Higher Education Accreditation

function. If Education finds issues with an accreditor’s standards or its 

application of them during the recognition or re-recognition process, 

Education may choose to recognize the accreditor for a limited time, or 

reject the accreditor’s application for recognition or re-recognition.20

According to Education, terminating an accreditor’s recognition is 

unusual. In the last 5 years, Education officials reported that one 

accreditor has had its accreditation terminated.21

In general, Education recognizes three types of accreditors—regional, 

national, and programmatic—that are responsible for assessing the 

academic quality of schools and programs.22 Based on Education’s data, 

regional accreditors accredit mostly nonprofit and public schools, while 

national accreditors generally accredit for-profit schools (see fig. 2). 

Programmatic accreditors generally accredit specific programs within 

schools, such as a school’s law program.23 As of June 2017, over half of 

all 5,234 accredited schools were accredited by regional accreditors, 

while the remaining schools were accredited by national and 

programmatic accreditors.

 2020 U.S.C. § 1099b(l). Education’s regulations also establish an appeal process. 34 

C.F.R. §§ 602.37-602.38.

21In September 2016, Education withdrew its recognition of the Accrediting Council for 

Independent Colleges and Schools, which was responsible for accrediting primarily forprofit schools with approximately 900 campuses in 47 states and Puerto Rico. Education

found violations of multiple regulatory criteria, including some related to the application 

and enforcement of the accreditor’s standards. The accreditor appealed the decision to 

withdraw its recognition to the Secretary of Education; however, the appeal was denied in 

December 2016. The accreditor subsequently appealed the decision in federal court, and 

that litigation is currently pending. Schools accredited by this accreditor may continue 

participating in federal student aid programs for up to 18 months, to allow them to seek 

accreditation from another accreditor recognized by Education and remain eligible for 

federal student aid.

22Education also recognizes certain state agencies as accreditors. See, e.g., 34 C.F.R. pt. 

603. However, for the purposes of this report, we focus on regional, national, and 

programmatic accreditors and excluded from our analysis any state agencies that have 

been recognized as accreditors. Additionally, Education refers to some accreditors as 

“specialized” accreditors, such as those that accredit faith-based and religious schools. 

For the purposes of this report, we generally include specialized accreditors in our 

discussion of programmatic accreditors.

23Education also recognizes some programmatic accreditors to accredit schools for Title 

IV eligibility purposes, including free-standing professional or vocational schools (such as 

law schools or schools of massage therapy), and certain educational programs in noneducational settings, such as hospitals.
Page 8 GAO-18-5 Views on Higher Education Accreditation

Figure 2: Types of Accrediting Agencies Recognized by the Department of 

Education and Their Postsecondary School Membership, as of June 2017

Note: The figure includes the regional, national, and programmatic accreditors recognized by the 

Department of Education (Education) as reliable authorities on assessing the academic quality of 

schools, and the 5,234 schools that were accredited by these recognized accreditors as of June 

2017. The Accrediting Council for Independent Colleges and Schools is included in Education’s June 

2017 data as a national accreditor. In September 2016, Education withdrew its recognition of this 

accreditor, and an appeal of Education’s decision is currently pending in federal court. Education 

refers to some accreditors as “specialized” accreditors, such as those that accredit faith-based and 

religious schools. GAO included these specialized accreditors in the programmatic accreditor 

category in the figure. Also, Education recognizes certain state agencies as accreditors; however, 

these agencies are not included in the figure.

a

Accreditors assess different types of schools, including: (1) public schools—operated and funded by 

state or local governments; (2) nonprofit schools—owned and operated by nonprofit organizations 

whose net earnings do not benefit any shareholder or individual; and (3) for-profit schools—privately 

owned, and net earnings can benefit shareholders or individuals.

b

This figure shows the number of schools accredited by programmatic accreditors for Title IV eligibility 

purposes. These can include free-standing professional or vocational schools, certain educational 

programs in non-educational settings, such as hospitals, and faith-based schools. Programmatic 

accreditors that only accredit specific programs within schools are not included in this figure.
Page 9 GAO-18-5 Views on Higher Education Accreditation

One of the requirements for schools to participate in federal student aid 

programs is accreditation by an agency recognized by Education. 

Recognized accreditors are responsible for assessing schools to 

determine if they meet standards to become or remain one of the 

accreditor’s member schools.24 Accreditors generally re-evaluate their 

member schools at least every 10 years (depending on the accreditor and 

the school) using a process that involves volunteer peer evaluators, 

generally from other member schools, selected by the accreditor. Specific 

steps vary by accreditor; however, schools generally go through a similar 

accreditation process that starts with the school conducting a selfevaluation of its performance and concludes with the school’s accreditor 

making a decision about its accreditation status.25 (See fig. 3.)

Figure 3: Sample Accreditation Process for Postsecondary Schools

 24Accrediting agencies are primarily funded by annual dues and fees paid by their 

member schools. In some cases, accrediting agencies may receive funding through 

conferences and meetings, private foundations, or other sources.

25Among other things, accreditors are required to perform regular on-site inspections and 

reviews of schools with particular focus on educational quality and program effectiveness, 

and ensure that accreditation team members are well-trained and knowledgeable with 

respect to their responsibilities. 20 U.S.C. § 1099b(c)(1). 

Accreditation Process for 

Schools
Page 10 GAO-18-5 Views on Higher Education Accreditation

To be accredited, schools are required to meet the standards of their 

accrediting agency. If an accreditor has concerns about a member 

school’s performance and ability to meet its standards, the accreditor may 

impose sanctions, such as issuing probations or warnings.26 Accreditors 

can also take a variety of other actions, such as requiring the school to 

furnish interim reports on how it is meeting certain standards, for 

example, those pertaining to student achievement, or reaccrediting the 

school for a shorter amount of time.27 If the school is unable to meet 

accreditor standards, the accreditor can terminate the school’s 

accreditation.

 26Accreditors must notify Education and the appropriate state licensing or authorizing 

agency within 30 days of any final decision to deny, withdraw, suspend, or terminate a 

school’s accreditation, place a school on probation, or take other adverse action. Also, 

accreditors must provide written notice to the public of such sanctions within 24 hours of 

notice to the school. 20 U.S.C. § 1099b(a)(7), (c)(7); 34 C.F.R. § 602.26(b), (c).

27In our December 2014 report, we discussed accreditors’ sanctions of schools for noncompliance with accreditor standards, and how likely accreditors are to sanction schools. 

See GAO-15-59. 
Page 11 GAO-18-5 Views on Higher Education Accreditation

The U.S. accreditation system’s nongovernmental structure and use of 

peer reviewers to oversee academic quality are key strengths that provide 

flexibility and subject matter expertise to assess a range of schools and 

programs, according to many roundtable experts we surveyed and our 

literature review.28 Roundtable experts specifically identified the on

governmental structure of the current system as a strength because it 

allows for accreditor reviews that are tailored to the various school types 

and missions.29

 28See Vickie Schray, Assuring Quality in Higher Education: Key Issues and Questions for 

Changing Accreditation in the United States, Issue Paper 4, Secretary of Education’s 

Commission on the Future of Higher Education; Paul L. Gaston, Higher Education 

Accreditation: How it’s Changing, Why it Must (Sterling, VA.: Stylus Publishing, 2014); 

Peter T. Ewell, Eleven Reform Proposals for Accreditation (Boulder, CO.: National Center 

for Higher Education Management Systems, 2015); and American Council on Education, 

National Task Force on Institutional Accreditation, Assuring Academic Quality in the 21st 

Century: Self-Regulation in a New Era (Washington, D.C.: American Council on 

Education, 2012). Stakeholders we interviewed also noted that this structure is 

distinguished from other international higher education systems that have centralized 

government entities that oversee and assess the quality of postsecondary schools. 

29A school’s mission identifies its unique goals and priorities, the students it seeks to 

serve, and reflects its vision for the future. For example, one community college describes 

its mission, in part, as to educate students who wish to transfer to other schools to pursue 

a degree. In contrast, one research university describes its mission, in part, as to provide 

undergraduate, graduate, and professional education, research, and other kinds of public 

service. According to our pre-roundtable survey, 13 of 18 roundtable experts (accreditors 

and non-accreditors) agreed or strongly agreed that a strength of the current accreditation 

system is that accreditor reviews are tailored to the various school types and missions. 

Additionally, 10 of 18 roundtable experts (accreditors and non-accreditors) agreed that 

allowing accreditors to set their own standards is a strength of the current accreditation 

system. Also, 9 of 18 roundtable experts (accreditors and non-accreditors) agreed that 

allowing schools to set their own goals for learning is a strength of the current system. 

Goals for learning generally identify the knowledge, skills, competencies, or careerpreparation practices that students are expected to acquire from a program.

Experts Cited 

Strengths and

Challenges with the 

Accreditation 

System’s Oversight of

Academic Quality

Many Experts Identified 

the Nongovernmental 

Structure of the 

Accreditation System and 

Use of Peer Review for 

Overseeing Academic 

Quality as Strengths
Page 12 GAO-18-5 Views on Higher Education Accreditation

Under the existing system, schools can apply for the type of accreditation 

that aligns with the education they seek to provide.30 For example, a 

medical program or a cosmetology school may apply for accreditation 

from an accreditor that specializes in its respective field.31 This alignment 

between schools and their accreditors can help schools focus on their 

mission by working with accreditors who understand and support their 

priorities, according to one paper we reviewed.32

The accreditation system’s use of peer reviewers that have relevant 

expertise to oversee schools’ academic quality was also identified as a 

key strength by many roundtable experts we surveyed.33 Peer reviewers, 

comprising a range of knowledgeable academic faculty and 

administrators, assess the academic quality of schools and provide 

schools with critical feedback on their weaknesses and areas for 

improvement, based on our literature review, expert roundtable 

discussion, and stakeholder interviews (see sidebar).34 One expert we 

surveyed commented that programmatic accreditation in particular relies 

on peer reviewers who are content matter experts (i.e., field practitioners 

and industry professionals), in addition to academic faculty and 

administrators, to ensure that students are competent to practice in their 

 30See Schray, Assuring Quality in Higher Education: Key Issues and Questions.

31For instance, a nursing program may choose to apply for accreditation from a 

programmatic accreditor such as the Accreditation Commission for Education in Nursing. 

According to this accreditor, its goal is to strengthen nursing education through a common 

core of standards, and it includes nursing education representatives on its board. 

Similarly, a cosmetology school may choose to apply for accreditation from the National 

Accrediting Commission of Career Arts and Sciences. According to this programmatic 

accreditor, it aims to foster and improve education and training in cosmetology arts and 

sciences. 

32See Gaston, Higher Education Accreditation.

33In our pre-roundtable survey, 12 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that the peer review process’s reliance on faculty 

with relevant expertise is a strength of the accreditation system.

34Peer reviewers voluntarily serve as evaluators on teams. The composition of peer 

review teams varies by accreditor and is generally driven by the expertise needed to 

review a specific school or program, according to a few roundtable experts. Accreditors 

typically seek out individuals with specific skills or knowledge to meet the needs of the 

review and may assemble a different set of peer reviewers for each accreditation review. 

See Congressional Research Service, An Overview of Higher Education Accreditation in 

the United States (Washington, D.C.: February 2016); Ewell, Eleven Reform Proposals; 

American Council on Education, Assuring Academic Quality; and Lamar Alexander, 

Higher Education Accreditation Concepts and Proposals (U.S. Senate Committee on 

Health, Education, Labor, and Pensions, Washington, D.C.: 2015).

Perspective on Peer Review and Subject 

Matter Expertise

“Peer review relies on members of a 

professional community to examine one 

another’s practices rigorously based on 

professional norms. As in medicine and 

scientific research, peer review is the 

foundation of professional integrity and largely 

defines what it means to be a profession. 

Unlike legislation or regulation, peer-based 

judgments can be applied flexibly and 

adjusted to local circumstances on the basis 

of shared expertise.”

Source: American Council on Education, National Task Force 

on Institutional Accreditation, Assuring Academic Quality in 

the 21st Century: Self-Regulation in a New Era (Washington, 

D.C.: American Council on Education, 2012). | GAO-18-5
Page 13 GAO-18-5 Views on Higher Education Accreditation

field of study. Similarly, some regional accreditors may involve employers 

in the peer review process, according to one stakeholder we interviewed. 

Most roundtable experts agreed that peer review feedback from 

knowledgeable professionals can help schools improve their ability to 

meet the educational needs of students.35

While many roundtable experts agreed on positive aspects of the 

accreditation system’s nongovernmental structure and use of peer review, 

some roundtable experts thought that these features may limit the 

effectiveness of oversight of academic quality at schools.36 For example, 

a few roundtable experts said the current structure could encourage too 

much variation in accreditors’ reviews and schools’ goals for learning. 

One paper stated that with too much variation in reviews, accreditors may 

not be able to assure consistent levels of quality across accredited 

schools (see sidebar).37 Regarding the use of peer review, one paper and 

a few roundtable experts noted concerns related to the rigor of peer 

reviewers’ evaluations.38 For example, according to the paper, some peer 

review teams may not receive adequate training on evaluation 

techniques, such as surveys and focus groups, to conduct their reviews 

and make effective judgments of academic quality. Peer reviewers may 

attend training for a day or less before participating in reviews, according 

to the paper, and may rely on less effective evaluation techniques, such 

as group interviews, to collect information during their site visits with 

 35In our pre-roundtable survey, 15 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that school improvement via feedback from the 

peer review process is a key strength of the current accreditation system. 

36In our pre-roundtable survey, 5 of 18 roundtable experts (accreditors and nonaccreditors) disagreed that schools setting their own goals for learning is a strength of the 

current system. Three of 18 roundtable experts we surveyed (all non-accreditors) 

disagreed that accreditor reviews that are tailored to the various school types and 

missions are a strength. Additionally, two of 18 roundtable experts we surveyed (nonaccreditors) disagreed that accreditors developing specific standards to assess academic 

quality at the schools they accredit is a strength. 

37See Schray, Assuring Quality in Higher Education: Key Issues and Questions.

38See Ewell, Eleven Reform Proposals. In our pre-roundtable survey, 4 of 18 roundtable 

experts (non-accreditors) disagreed that the peer review process relies on faculty with 

relevant expertise to make determinations about academic quality.

Perspective on Flexibility of the 

Accreditation Process

“When confronted by the public’s puzzlement 

at how some of the finest and some of the 

worst institutions in the land enjoy the same 

accreditation status—a feature that the latter 

often trumpet in their advertising—

accreditation insiders refer to the uniqueness 

of institutional missions as central to all 

judgments about quality.” 

Source: Barmak Nassirian, Statement Before the National 

Advisory Committee on Institutional Quality and Integrity

(Washington, D.C.: American Association of Collegiate 

Registrars and Admissions Officers, February 2011). | 

GAO-18-5
Page 14 GAO-18-5 Views on Higher Education Accreditation

schools.39 Most roundtable experts we surveyed also agreed that current 

review processes may not be suitable for assessing new types of 

programs, such as competency-based education models and online 

programs.40 Additionally, a few roundtable experts raised concerns about 

whether accreditors have sufficient capacity and resources (such as staff 

and knowledgeable peer reviewers) to manage their reviews of schools 

they accredit.

Peer review may not effectively capture information from students or 

identify students’ needs, according to a few experts at our roundtable 

discussion and one paper we reviewed.41 One roundtable expert said that 

there is limited interaction with students in the peer review process. 

According to one paper, peer reviewers typically have an open meeting 

with students during their school site visit, however, these students may 

 39According to the paper we reviewed, group interviews may be unstructured and may not 

be as reliable as other data collection methods, such as surveys and focus groups. See 

Ewell, Eleven Reform Proposals. Recognized accreditors are required to have competent 

and knowledgeable individuals, qualified by education and experience in their own right 

and trained by the accreditor on their responsibilities, as appropriate for their roles, 

regarding the accrediting agency’s standards, policies, and procedures, to conduct its onsite evaluations, apply or establish its policies, and make its accrediting and preaccrediting decisions. 34 C.F.R. § 602.15(a)(2). One stakeholder we interviewed noted 

that accreditors’ practices for training peer reviewers may vary.

40In our pre-roundtable survey, 14 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that adapting current accrediting processes to 

determine the quality of new types of programs may be difficult. Competency-based 

education models allow students to demonstrate proficiency in academic content without 

regard to time, place, or pace of learning. Assessing new types of programs may be 

challenging because accreditation evaluations are designed to review the quality of more 

traditional aspects of programs, such as face-to-face classroom instruction and faculty 

roles, according to papers we reviewed. See Lindsey M. Burke and Stuart M. Butler, 

Ph.D., Accreditation: Removing the Barrier to Higher Education Reform (Washington, 

D.C.: The Heritage Foundation, 2012), and American Council on Education, Assuring 

Academic Quality. One roundtable expert said that current review processes are lengthy 

and may be a barrier to innovative educational programs. However, another roundtable 

expert said that it may be beneficial that accreditors take a more traditional, conservative 

approach to reviewing new types of schools and programs, in order to protect students’

and taxpayers’ higher education investment.

41One of the 18 roundtable experts (a non-accreditor) in our pre-roundtable survey

commented that peer review may not consider students’ needs. According to one paper, 

students may not consistently play a role in accreditation reviews. See Ewell, Eleven 

Reform Proposals. Another roundtable expert noted that in contrast to the United States, 

some European countries include students on peer review teams.
Page 15 GAO-18-5 Views on Higher Education Accreditation

be “preselected” or volunteers.42 These issues raise questions about how 

effectively accreditors review schools to help schools better serve 

students, according to a few roundtable experts.

Roundtable experts, stakeholders we interviewed, and our literature 

review identified a number of challenges within the current accreditation 

system that can affect oversight of academic quality at schools. These 

challenges were related to three key areas: (1) oversight roles and 

responsibilities, particularly for accreditors and Education, (2) 

communication and transparency, and (3) measuring academic quality 

(see fig. 4).

Figure 4: Key Challenges, Identified by Experts, of the Current Accreditation 

System that Can Affect Oversight of Postsecondary Schools’ Academic Quality

 42For example, schools may select students based on their involvement in campus life 

(e.g., student government, leaders of clubs or student organizations, etc.). The author 

stated that to provide students with a larger role in accreditation, peer reviewers could 

randomly select a group of 15 or 20 students, include students as peer review team 

members, or allow students to help design the accreditation review process. See Ewell, 

Eleven Reform Proposals.

Some Experts Said 

Challenges Related to 

Oversight Roles, 

Communication, and 

Measuring Academic 

Quality Could Impede 

Oversight
Page 16 GAO-18-5 Views on Higher Education Accreditation

Accreditors’ dual role—helping schools improve their performance and 

also making accreditation decisions that can affect schools’ access to 

federal student aid programs—may be difficult to balance and could 

create tension and potential conflicts of interest, according to roundtable 

experts we surveyed, stakeholder interviews, and our literature review 

(see sidebar).43 Over time, accreditors’ role in ensuring academic quality 

and helping schools improve expanded to include serving as 

“gatekeepers” for federal funds as accreditation became one of the bases 

for determining schools’ eligibility to participate in federal student aid 

programs.44 One paper stated that serving a dual role may be difficult for 

accreditors to balance because serving as “gatekeepers” for federal 

student aid involves making judgments that may create tension in the 

relationship between schools and accreditors.45 For example, schools

may sue accreditors when accreditors identify issues and take adverse 

actions that can affect schools’ accreditation status and, therefore, their

access to federal student aid programs, according to the paper and a few 

roundtable experts.

Further, schools pay dues and fees to fund the accreditor responsible for 

helping determine their eligibility to access federal student aid, creating a 

potential conflict of interest that may be a challenge for oversight of 

 43The Higher Education Act generally requires recognized accreditors of schools to be 

“separate and independent,” both administratively and financially, of any related, 

associated, or affiliated trade association or membership organization. 20 U.S.C. § 

1099b(a)(3),(b); 34 C.F.R. § 602.14. Accreditors are also required to have clear and 

effective controls against conflicts of interest, or the appearance of conflicts of interest, by 

the agency’s board members, commissioners, evaluation team members, consultants, 

administrative staff, and other agency representatives. 34 C.F.R. § 602.15(a)(6). In 

addition, accreditors’ review procedures are required to include an appeal process that is 

subject to a conflict of interest policy. 34 C.F.R. § 602.25(f). 

44In our pre-roundtable survey, 14 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that lack of clarity regarding defined roles and 

responsibilities for accreditors presents a challenge.

45See Gaston, Higher Education Accreditation.

Accreditors’ role in oversight of 

schools

Perspectives on Tension in Accreditors’ 

Role

• “Today’s accreditation agencies 

perform two contradictory functions. 

From the federal perspective, they 

must serve as gatekeepers that decide 

if an institution can access federal 

financial aid. But many of these 

agencies see their main job as helping 

colleges improve, thereby creating 

suboptimal incentives...if your goal is 

to help someone get better, removing 

them from federal aid programs is 

partly a failure by the accreditor.” 

Source: Ben Miller, David Bergeron, and Carmel Martin, 

A Quality Alternative: A New Vision for Higher Education

Accreditation (Washington, D.C.: Center for American 

Progress, October 2016).

• “Accreditation is also a binary variable 

(colleges and universities either have it 

or they do not), and because federal 

aid is the lifeblood of many institutions, 

losing eligibility would put most in 

severe financial distress. This creates 

a barrier to exit, as accreditors--already 

sympathetic to the institutions they 

evaluate--are reticent to revoke a 

school's accreditation because doing 

so would represent a death sentence.”

Source: Andrew P. Kelly and Kevin James, Untapped 

Potential: Making the Higher Education Market Work for 

Students and Taxpayers (Washington, D.C.: American 

Enterprise Institute, 2014). | GAO-18-5
Page 17 GAO-18-5 Views on Higher Education Accreditation

academic quality, according to many roundtable experts we surveyed.46

Some roundtable experts and papers stated that since access to federal 

student aid is critical for schools to maintain operations and recruit and 

retain students, and accreditors are dependent on member schools for 

their revenue, some accreditors may be hesitant to take adverse actions 

against schools. These may include imposing sanctions when they find 

issues, including terminating schools’ accreditation, because such actions 

could affect a school’s eligibility for federal student aid programs and may 

lead to school closure.47 In our December 2014 report we identified 

issues with accreditors’ oversight practices, finding that accreditors may 

not consistently take action to sanction schools with academic quality 

 46In our pre-roundtable survey, 10 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that the potential conflict of interest in the 

relationship between schools and their accreditors presents a challenge. However, 4 of 18 

roundtable experts (accreditors and non-accreditors) we surveyed disagreed or strongly 

disagreed that the membership relationship between schools and accreditors is a 

challenge. One roundtable expert (an accreditor) commented that there is little evidence of 

conflicts of interest between accreditors and member schools. Additionally, according to a 

paper authored by one expert we surveyed, accreditors may take several steps to address 

conflicts of interest, including training volunteers on using evidence to make objective 

judgements and monitoring peer review teams to ensure that reviews remain rigorous. 

See Gaston, Higher Education Accreditation. Another expert we surveyed co-authored a 

paper on an alternative accreditation oversight structure which may potentially reduce 

conflict of interest concerns. See Ben Miller, David Bergeron, and Carmel Martin, A 

Quality Alternative: A New Vision for Higher Education Accreditation (Washington, D.C.: 

Center for American Progress, October 2016). We discuss this alternative approach to the 

current accreditation system and others later in this report.

47See Gaston, Higher Education Accreditation; Andrew P. Kelly and Kevin James, 

Untapped Potential: Making the Higher Education Market Work for Students and 

Taxpayers (Washington, D.C.: American Enterprise Institute, 2014); Barmak Nassirian, 

Statement Before the National Advisory Committee on Institutional Quality and Integrity 

(Washington, D.C.: American Association of Collegiate Registrars and Admissions

Officers, February 2011); and American Council on Education, Assuring Academic 

Quality. One roundtable expert commented that in some instances when accreditors took 

strong actions against some schools, Education allowed these schools to continue to 

operate. In our prior report we noted that according to a representative of an accrediting 

agency, if an accreditor terminates a particular school’s accreditation, there may be 

significant negative reaction from the public in the affected region, and a view that the 

accreditor is being too punitive. See GAO-15-59.
Page 18 GAO-18-5 Views on Higher Education Accreditation

issues.

48 Additionally, many roundtable experts we surveyed questioned 

the rigor of accreditors’ standards and oversight practices (see sidebar).49

Given student and federal investments in higher education, a few 

roundtable experts said accreditors have an important role in holding 

schools accountable for providing students with a quality education.

In addition, a few experts at our roundtable and in our interviews raised 

questions about whether accreditors’ financial review responsibilities and 

their potential overlap with other triad members’ responsibilities may 

reduce accreditors’ capacity to oversee academic quality.50 Our prior 

report found that accreditors most frequently issued sanctions for failure 

to meet standards on financial capability, not academic quality.51 Under 

the Higher Education Act, accreditors are required to have standards to 

assess schools’ fiscal and administrative capacity, and schools’ record of 

compliance with federal student aid program requirements, which can 

include reviewing schools’ financial audits.52 Education also oversees 

schools’ compliance with federal student aid requirements in several 

 48For example, we found that schools with weaker student outcomes were, on average, 

no more likely to be sanctioned by accreditors than schools with stronger student 

outcomes, and that the proportion of schools that accreditors sanctioned varied. 

Specifically, our analysis of Education’s sanction data from October 2009 through March 

2014 found that two accreditors sanctioned less than 2 percent of their member schools 

during this time frame, compared to 41 percent for another accreditor. See GAO-15-59. 

Additionally, in a January 2012 report on credit rating agencies, we discussed similar 

potential conflicts of interest created when issuers of debt securities pay a fee to credit 

rating agencies to produce their ratings. Critics of rating agencies have raised questions 

about the integrity of ratings processes and the accuracy of their ratings. See GAO, Credit 

Ratings Agencies: Alternative Compensation Models for Nationally Recognized Statistical 

Rating Organizations, GAO-12-240 (Washington, D.C.: Jan. 18, 2012).

49In our pre-roundtable survey, 11 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that inadequate accreditors’ standards are a 

challenge for overseeing academic quality and that accreditors lack effective oversight 

practices for academic quality. One roundtable expert commented that accreditors too 

often focus on process (i.e., whether schools assess their performance and how they 

conduct such assessments), rather than examining what their assessments identify about 

academic quality.

50Also, in our pre-roundtable survey, 12 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that overlapping roles and responsibilities for triad 

members presents a challenge. Roundtable experts also generally discussed the 

advantages and disadvantages of clarifying or redefining triad members’ accreditation 

roles and responsibilities to better oversee academic quality. We summarize experts’

views on this issue later in this report.

51See GAO-15-59.

5220 U.S.C. § 1099b(a)(5); 34 C.F.R. § 602.16(a)(1).

Expert Perspective on Accreditor 

Standards

“Accreditors have standards, but sometimes 

they are so open for interpretation that they 

miss the core message of teaching and 

learning – and, most importantly, producing 

strong student outcomes.” 

Source: Expert response to GAO survey. | GAO-18-5
Page 19 GAO-18-5 Views on Higher Education Accreditation

ways, including monitoring their financial activities.53 A few experts from 

our roundtable and interviews noted that accreditors’ regular contact with 

schools through site visits and other assessments makes them wellpositioned to identify financial issues in schools and can help ensure that 

schools are financially stable to offer a quality education to students. 

However, other experts expressed concerns that financial oversight may 

detract from accreditors’ capacity to oversee schools’ academic quality.

Education has taken some actions to modify its oversight of accreditors; 

however, a few experts who participated in our roundtable and 

stakeholders we interviewed (accreditors and non-accreditors) expressed 

concerns that these actions may diminish key strengths of the current 

accreditation system, such as its nongovernmental structure and use of 

peer review to assess schools’ academic quality. For example, in 

November 2015, Education issued a notice announcing a set of planned 

actions that it said were intended to improve accreditors’ and Education’s 

oversight activities and focus on student outcomes and transparency. 

Education announced that it would publish key student outcome 

measures, such as graduation rates and student loan repayment rates, 

for each school alongside its accreditor.54 According to Education, this 

effort was intended to help Education better understand how accreditors 

oversee low-performing schools and to improve accreditors’ oversight 

 53One of the requirements for participation in federal student aid programs is that schools 

must demonstrate that they are financially responsible, based on criteria and processes 

established in the Higher Education Act and Education’s regulations. 20 U.S.C. § 

1099c(c); 34 C.F.R. §§ 668.15, 668.171 – 668.175, and apps. A-B. Education assesses 

schools against these financial responsibility standards and requires schools that do not 

meet the standards to receive additional oversight. See GAO, Higher Education: 

Education Should Address Oversight and Communication Gaps in Its Monitoring of the 

Financial Conditions of Schools, GAO-17-555 (Washington, D.C.: Aug. 21, 2017).

54As part of this effort, Education’s announced actions also included publishing 

accreditors’ student achievement standards on its website. According to Education’s 

notice, these actions were partially in response to suggestions from NACIQI—the 

committee that advises Education on accreditation issues—and GAO’s recommendation 

for Education to strengthen its oversight of schools and accreditors. See GAO-15-59. 

Additionally, in June 2016, NACIQI began piloting more systematic, outcomes-focused 

reviews of accreditors, based on Education’s student outcomes data, and increased its 

focus on accreditor’s standards for student achievement. Since these plans were 

announced and the NACIQI pilot began, there has been a change in administration. 

Education officials were unable to comment on whether such efforts will continue under 

the new administration.

Education’s role in oversight of 

accreditors
Page 20 GAO-18-5 Views on Higher Education Accreditation

activities.55 During our expert roundtable and interviews, a few experts 

and stakeholders representing accreditors raised concerns about 

Education’s actions, and said they suggest decreasing trust in 

accreditors’ oversight of schools.56 They also said that these actions 

could make accreditors and Education focus too much attention on 

certain student outcome measures that may not provide a complete 

picture of some schools.57 However, many roundtable experts we 

surveyed, including both accreditors and non-accreditors, agreed that 

accreditors’ current standards and practices may not provide adequate 

oversight of academic quality.58 Further, some papers we reviewed 

identified an increased demand for accountability in the accreditation 

system, and attributed this demand, in part, to increased federal and 

student investment in higher education (see sidebar).59

 55At the same time, Education also put forth some legislative proposals, including one 

recommending that Congress repeal the statutory prohibition on Education’s ability to set 

and enforce expectations regarding student achievement standards in its accreditor 

recognition process. Education’s proposal recommended that Congress provide for the 

differentiated recognition of accreditors based on student outcomes and other risk-based 

criteria. According to Education’s notice, such a change could create an incentive for 

accreditors to focus their attention on low-performing schools.

56Two roundtable experts (an accreditor and non-accreditor) also commented that 

accreditors have general concerns about increased requirements by Education in the 

accreditation system. For example, one of the experts said that over time, Education has 

expanded federal student aid compliance requirements for schools and required more 

information from accreditors about compliance issues.

57For example, one roundtable expert said that some community colleges may have lower 

graduation rates because some of their students leave school to work full-time instead of 

finishing their program of study. Our prior report also found that limitations in currently 

available information on outcome characteristics at schools make certain measures less 

useful for evaluating some types of schools. For instance, community colleges typically 

serve a high proportion of part-time and returning students, but these students are not 

included in official graduation rate statistics collected by Education. See GAO-15-59.

58As previously discussed, in our pre-roundtable survey, 11 of 18 roundtable experts 

(accreditors and non-accreditors) agreed or strongly agreed that inadequate accreditor

standards are a challenge for overseeing academic quality and that accreditors lack 

effective oversight practices for academic quality.

59See Gaston, Higher Education Accreditation; U.S. Department of Education, A Test of 

Leadership: Charting the Future of U.S. Higher Education (Washington, D.C.: September 

2006); Schray, Assuring Quality in Higher Education: Key Issues and Questions; Ewell, 

Transforming Institutional Accreditation in U.S. Higher Education (Boulder, CO.: March 

2015); and Robert C. Dickeson, The Need for Accreditation Reform, Fifth Issue Paper for 

the Secretary of Education’s Commission on the Future of Higher Education.

Perspectives on Public Demand for 

Increased Accountability

• “There has been a dramatic shift toward 

public accountability and for accreditation 

to remain relevant...Accreditation is 

responsible to demonstrate that high 

standards are met in areas key to the 

public debate about quality and 

effectiveness of higher education.”

Source: Expert statement at GAO roundtable. | GAO-18-5

• “Both the frequency and volume of calls 

for greater accountability have increased, 

with the result that accreditation now 

operates under scrutiny more critical and 

vigilant than at any time in the past.”

Source: Paul L. Gaston, Higher Education Accreditation: How 

it’s Changing, Why it Must (Sterling, VA.: Stylus Publishing, 

2014). | GAO-18-5
Page 21 GAO-18-5 Views on Higher Education Accreditation

While there are requirements in place for triad members (accreditors, 

Education, and states) to communicate with each other, most roundtable 

experts we surveyed agreed that triad members lack effective 

communication and collaboration mechanisms, which may adversely 

affect oversight of schools.60 Communication and collaboration can be 

critical to protecting consumers when schools are in danger of closing so 

that triad members can develop plans for affected students (see sidebar). 

According to a few roundtable experts and stakeholder interviews, there 

is no formal system in place to help triad members regularly communicate 

or alert other members about important developments regarding 

schools.61 For example, one roundtable expert said that triad members 

may not consistently share information with each other about schools 

being sanctioned when accreditor standards are not met. Additionally, 

triad members may not sufficiently collaborate to respond to impending 

school closures, according to the roundtable expert, which may affect 

efforts to ensure that students receive sufficient assistance to complete 

their education. Another roundtable expert commented that some states 

 60In our pre-roundtable survey, 16 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that triad members lack effective communication. 

Fourteen of 18 roundtable experts (accreditors and non-accreditors) agreed or strongly 

agreed that triad members lack effective collaboration. 

61There are some requirements in place for triad members to alert each other about 

important developments with schools. For example, recognized accreditors are required to 

notify Education and the appropriate state licensing or authorizing agency within 30 days 

of certain accreditation actions, including final decisions to place a school on probation; 

deny, withdraw, suspend, revoke, or terminate a school’s accreditation; or take other 

adverse action. 20 U.S.C. § 1099b(a)(7); 34 C.F.R. § 602.26. For certain adverse actions, 

accreditors are also to provide a summary of the accreditor’s reasons, along with 

comments from the school or program. 20 U.S.C. § 1099b(a)(8); 34 C.F.R. § 602.26(d). In 

addition, accreditors must submit other specified information to Education, such as the 

name of any school or program that the accreditor has reason to believe is failing to meet 

its federal student aid program responsibilities or is engaged in fraud or abuse. 34 C.F.R. 

§ 602.27. Further, Education’s regulations provide that the department will notify a school 

or program’s accreditor no later than 10 days after taking an action against the school or 

program. 34 C.F.R. § 602.50. According to Education officials, the department routinely 

shares key information with accreditors about their member schools, such as Education’s 

decisions about denying or terminating a school’s eligibility for federal student aid.

Communication among 

members of the triad

Perspective on Communication 

Challenges

“...when there is a clear problem and action is 

being taken by one member of the triad 

[which consists of Education, accreditors and 

states] – that member should have a 

responsibility to alert others charged with 

overseeing that institution to inform their own 

reactions to the situation. In too many recent 

cases, the lack of communication delayed an 

effective response, and too many students 

were left with bad options.” 

Source: Expert response to GAO survey. | GAO-18-5
Page 22 GAO-18-5 Views on Higher Education Accreditation

learned about impending school closures in 2016 through the media, 

rather than through early notification from Education or accreditors.62

Some roundtable experts and papers also noted that states vary widely in 

their efforts to oversee schools with respect to consumer protection, 

which may affect collaboration with accreditors and Education.63 For 

example, one roundtable expert noted that some states require schools to 

have teach-out agreements—written agreements between schools that 

give students the opportunity to complete their program elsewhere if their 

school ceases to operate—while others may not.64 Another roundtable 

expert said that some states may not reach out to accreditors to jointly 

address complaints received about schools.65 Education officials 

 62Education has taken some recent steps it says are intended to improve communication 

among triad members. For example, in January 2016, the offices within Education 

responsible for higher education issued a memorandum with several recommendations to 

the Secretary, including identifying steps for Education to increase sharing of key 

information with accreditors, and working with state authorizing agencies to identify 

opportunities to improve information sharing. According to the memorandum, these efforts 

were intended to build on the executive actions and legislative proposals announced by 

Education in November 2015 to improve accreditors’ and Education’s oversight activities. 

In November 2016, Education issued guidance clarifying terminology and requirements for 

accreditors’ reports to Education under the Higher Education Act and Education’s 

regulations. Since these plans were announced, there has been a change in 

administration and Education officials were unclear on whether such efforts will continue 

under the new administration.

63States generally require schools to have consumer protection policies and are 

responsible for responding to student complaints, according to our literature review and 

our prior report. See Andrew P. Kelly, Kevin J. James, and Rooney Columbus, Inputs, 

Outcomes, Quality Assurance: A Closer Look at State Oversight of Higher Education 

(Washington, D.C.: American Enterprise Institute, 2015); and Thomas Harnisch, Barmak 

Nassirian, Amber Saddler and Art Coleman, Enhancing State Authorization: The Need for 

Action By States As Stewards of Higher Education Performance (Denver, CO.: Education 

Commission of the States, December 2016); and GAO-15-59.

64Recognized accreditors must require schools they accredit to submit a teach-out plan for 

approval in certain circumstances, such as when the school notifies the accreditor that it 

intends to close. 20 U.S.C. § 1099b(c)(3); 34 C.F.R. § 602.24(c). This plan may include, if 

required by the accreditor, an agreement with other schools to allow students from the 

closed school to complete their program of study. If a school closes without a teach-out 

plan or agreement, the accreditor must work with Education and the appropriate state 

authorizing agency, to the extent feasible, to assist students in finding reasonable 

opportunities to complete their education without additional charges. 34 C.F.R. § 

602.24(d). 

65Similarly, one stakeholder we spoke with said that accreditors may not provide 

information to some states related to complaints they receive about schools. Information 

from accreditors about complaints could increase states’ awareness of schools with 

potential performance problems, according to the stakeholder. 
Page 23 GAO-18-5 Views on Higher Education Accreditation

commented that they are generally unclear what information states collect 

and can share about the academic quality of schools they authorize, and 

that states do not typically share information about active state 

investigations of schools with the department or accreditors.66 Variation in 

states’ efforts and limited communication and collaboration among 

members of the triad may make it difficult for triad members to coordinate 

effectively, particularly in circumstances related to protecting students.

Many roundtable experts we surveyed disagreed with the view that the 

current accreditation system provides students with useful information on 

the academic quality of schools, and a few roundtable experts expressed 

concerns that the public may misinterpret accreditation information.67

General information about which schools are and are not accredited is 

publicly available on Education’s website.

68 Students may assume that 

general information about accreditation status implies that accredited 

 66States are required to notify Education promptly (a) whenever the state revokes a 

school’s license or other authority to operate, and (b) whenever the state has credible 

evidence that a school within the state has committed fraud in the administration of federal 

student aid programs or has substantially violated a provision of Title IV of the Higher 

Education Act. 20 U.S.C. § 1099a. For example, some states have investigated schools 

that allegedly engaged in deceptive practices that could cause harm to students, such as 

misrepresenting the job opportunities available to their graduates or the transferability of 

credits earned to other schools.

67In our pre-roundtable survey, 10 of 18 roundtable experts (accreditors and nonaccreditors) disagreed or strongly disagreed that the current accreditation system provides 

prospective students with information on schools that meet a minimum standard for 

quality. However, 4 roundtable experts (accreditors and non-accreditors) agreed that the 

current system provides students with information on schools that meet a minimum 

standard for quality. One roundtable expert commented that programmatic accreditation 

provides students with information on the quality of academic programs.

68Recognized accreditors are required to make certain information available to the public, 

including: (1) decisions to award accreditation or reaccreditation; (2) final denial, 

withdrawal, suspension, revocation, or termination of accreditation; and (3) decisions to 

place schools on probation or take other adverse action. For any decision to deny, 

withdraw, suspend, revoke, or terminate accreditation, the accreditor must also make 

publicly available a summary of the reasons for the decision and any comments from the 

affected school. 20 U.S.C. § 1099b(a)(8), (c)(7); 34 C.F.R. § 602.26. In April 2017, 

Education also began posting on its website letters from accreditors to schools explaining 

the accreditors’ reasons for taking adverse actions against the schools. Additionally, 

NACIQI, the committee that advises Education on accreditation issues, holds public 

meetings at least twice a year to review applications for recognition submitted by 

accreditors and make recommendations to Education’s Senior Department Official 

designated to make the decision regarding recognition. Transcripts of NACIQI’s meetings 

are publicly available on Education’s website. In our pre-roundtable survey, 11 of 18 

roundtable experts agreed that a strength of the current accreditation system is that 

recognition meetings held by NACIQI are open to the public.

Sharing information with 

students and the public
Page 24 GAO-18-5 Views on Higher Education Accreditation

schools meet the same standards of quality, according to a few 

roundtable experts.69 However, our analysis of Education’s data found 

that some schools with very different performance on certain outcome 

measures have the same accredited status, which may not be clear to the 

public. For example, we found that one private, nonprofit accredited 

school had a 95 percent student retention rate.70 In comparison, another 

private, nonprofit school accredited by the same accreditor had a 32 

percent student retention rate. While no single outcome measure can be 

used to fully examine the quality of a school, our prior report found that a 

low retention rate may indicate a lack of academic quality, among other 

measures.71 Appendix IV presents a collection of indicators that can 

provide more information on the academic quality of accredited schools.72

While many roundtable experts we surveyed acknowledged that the 

current accreditation system may not provide students with useful 

information about the academic quality of schools, there is disagreement 

 69One roundtable expert said that students may assume that accreditation is a measure of 

academic quality; however, accreditors tend to assess a school’s capacity to ensure 

quality. As previously discussed, accreditors are required to have standards in specific 

areas, such as student achievement and curricula; however, the specific standards that 

accreditors develop in these areas can differ among accreditors, and they may also 

establish additional standards in areas not required by law. 20 U.S.C. § 1099b(a)(5),(g); 

34 C.F.R. § 602.16.

70In Education’s Integrated Postsecondary Education Data System, retention rates are the 

percent of first-time degree/certificate-seeking students who enrolled in one fall and either 

successfully completed their program or re-enrolled in the next fall.

71Researchers have reported that assessing multiple indicators (e.g., graduation rates and 

retention rates) could shed light on the quality of education provided by schools, according 

to our December 2014 report. See GAO-15-59. 

72In June 2016, Education began publishing “accreditor dashboards” on its website which 

provide information on several indicators of school performance related to academic 

quality, such as graduation rates. At the same time, NACIQI began reviewing graduation 

rates and the amount of debt incurred by students graduating from accredited schools 

during its accreditor recognition hearings, among other indicators and supplementary 

information, to examine the performance of schools accredited by each accrediting 

agency applying for recognition renewal.
Page 25 GAO-18-5 Views on Higher Education Accreditation

on what information accreditors should share.73 Some roundtable experts 

and papers noted that some accreditors and schools publicly release 

detailed information, such as peer review reports, while others do not, 

and that typical peer review reports may not contain information that the 

public wants.74 (See sidebar.) A few roundtable experts also questioned 

whether there is public interest in accreditation materials that are currently 

available. One roundtable expert said that peer review reports may not be 

helpful to the public because they are written to provide schools with 

feedback and are not developed with consumers in mind.75

Additionally, some accreditors have concerns that more public disclosure 

of accreditation review findings could damage the trusted relationship 

between accreditors and schools, according to a few roundtable experts. 

For example, one roundtable expert noted the need to keep some quality 

improvement conversations between accreditors and schools private 

because publicly sharing such information could lead to inaccurate 

perceptions of the school. However, one roundtable expert noted that 

there is little evidence that recent efforts by a regional accreditor to share 

more information with the public have damaged its relationship with 

 73In our pre-roundtable survey, 16 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that there is a lack of consensus on what 

information accreditors should share with the public. In addition to providing certain 

information about accreditation decisions to the public, as previously mentioned, 

accreditors are currently required to make other information available to the public, 

including whether a school is being considered for accreditation or reaccreditation and 

written materials describing its standards and procedures, among other things. See 20 

U.S.C. § 1099b(a)(8), (c)(7), and (c)(8); 34 C.F.R. §§ 602.23, 602.26.

74See Gaston, Higher Education Accreditation; Ewell, Transforming Institutional 

Accreditation in U.S. Higher Education; Dickeson, The Need for Accreditation Reform; and

Kelly and James, Untapped Potential. Peer review reports generally include an 

assessment of the school’s compliance with the accreditor’s standards; however, the type 

of information in these reports may vary by accreditor. Schools participating in federal 

student aid programs are required to provide certain information annually to all enrolled 

students and upon request to any enrolled or prospective student, including the names of 

the school’s accreditor(s) and the procedures by which students may review documents 

describing the school’s accreditation. 20 U.S.C. § 1092(a)(1)(J); 34 C.F.R. § 668.43(a)(6). 

In addition, accreditors must provide for the public correction of any incorrect or 

misleading information an accredited school or program releases about its accreditation 

status, the contents of reports of on-site reviews, or the accrediting agency’s actions with 

respect to the school or program. 34 C.F.R. § 602.23(e).

75In an October 2014 report, we found that transparency tools are most effective if they 

convey relevant information to consumers in a way that consumers can readily understand 

and use to make meaningful distinctions. See GAO, Health Care Transparency: Actions 

Needed to Improve Cost and Quality Information for Consumers, GAO-15-11 

(Washington, D.C.: Oct. 20, 2014).

Perspectives on Sharing Information with 

the Public

• “[T]he system of accreditation really 

wasn't set up to be conveying information 

to students directly. I actually have read 

every single self-study report, every single 

team visit report I've ever been able to get 

my hands on with great interest, because 

it lets me know things, for example, like 

accreditation isn't going to tell me 

anything about misrepresentations that 

recruiters might be making to bring 

students into the school.”

Source: Expert statement at GAO roundtable. | GAO-18-5

• “Students definitely use accreditation as a 

baseline measure of quality (and should 

continue to do so). The problem is that for 

some schools, that accreditation status 

may mask real problems that are not 

being fully addressed through the 

accreditation process.”

Source: Expert response to GAO survey. | GAO-18-5
Page 26 GAO-18-5 Views on Higher Education Accreditation

schools.76 Further, without sufficient information about the academic 

quality of schools, consumers may not be well-positioned to make 

decisions about their time and financial investments in higher education, 

according to our literature review and a few roundtable experts.

Accreditation is intended, in part, to ensure that the education offered by 

schools is of sufficient quality to achieve the schools’ objectives. 

However, lack of agreement on existing measures to define academic 

quality is a challenge affecting oversight of schools, according to most 

roundtable experts we surveyed.77 Because academic quality is difficult to 

measure and define, some roundtable experts and stakeholders we 

interviewed said that it can be interpreted in various ways and affected by 

many factors, such as the student body characteristics of a school or 

program or its educational objectives. There is also a lack of agreement 

on how to measure it effectively (see sidebar). For example, student 

outcomes—measures that can range from graduation rates to 

assessments of what students learn from their education—may reflect 

academic quality, according to our literature review, some roundtable 

experts, and our prior work.

78

A few roundtable experts said that aggregate outcome data collected by 

Education (such as graduation rates and student loan default rates) is an 

 76Specifically, the Accrediting Commission for Senior Colleges and Universities of the 

Western Association of Schools and Colleges, a regional accreditor that oversees schools 

in California, Hawaii, and the Pacific Islands, announced in July 2012 that it would post all 

of its current accreditation evaluation reports and action letters publicly on its website to 

make accreditation information more transparent and available to the public. 

77According to our pre-roundtable survey, 14 of 18 roundtable experts (accreditors and 

non-accreditors) agreed or strongly agreed that determining a common definition of 

academic quality is a challenge. Difficulties establishing a common definition of academic 

quality are not unique to the United States, as other countries also encounter challenges, 

according to one paper we reviewed and a few roundtable experts. See Ellen Hazelkorn, 

What We Know and Don’t Know About Quality (Washington, D.C.: April 2013).

78See Kelly, James, and Columbus, Inputs, Outcomes, Quality Assurance; Ewell, 

Accreditation and Student Learning Outcomes: A Proposed Point of Departure (Council 

for Higher Education Accreditation, September 2001); Schray, Assuring Quality in Higher 

Education: Key Issues and Questions; American Council on Education, Assuring 

Academic Quality in the 21st Century; GAO-15-59 and GAO, Postsecondary Education: 

Student Outcomes Vary at For-Profit, Nonprofit and Public Schools, GAO-12-143 

(Washington, DC: Dec. 7, 2011). Our December 2014 report also found that the ways 

accreditors measure quality vary widely, with some accreditors focusing on quantitative 

measures, such as licensure exam pass rates, while others rely on more qualitative 

measures, such as whether a school is evaluating success with respect to its mission. See 

GAO-15-59.

A common definition of 

academic quality

Perspectives on Lack of a Common 

Definition of Academic Quality

“I think it would be fair to say that each of us 

thinks we know what it [academic quality] is 

and all of us have a different definition.”

Source: Expert statement at GAO roundtable. |GAO 18 5

“The problem is that 'student achievement' is 

sometimes narrowly cast as graduation rates 

and loan default rates and earning rates for 

students who had federal financial aid. These 

can be useful indicators but they are 

inadequate as a definition of student 

achievement.”

Source: Expert response to GAO survey. | GAO 18 5
Page 27 GAO-18-5 Views on Higher Education Accreditation

incomplete measure of academic quality. Experts noted that some data 

are not reported for all students, and that the data may not provide 

information about what students learn. For example, Education’s data on 

graduation rates applies to first-time, full-time students, which may 

account for a small percentage of students at some schools, according to 

a few roundtable experts.79 Student learning outcomes, which can include 

measures of students’ skills related to oral and written communications 

and critical thinking, may more directly reflect academic quality, according 

to a few roundtable experts and our literature review.80 (See sidebar.) 

However, measures of student learning may also have some limitations. 

For example, certain student learning indicators, such as standardized 

tests, may not provide a full picture of academic quality and may be 

affected by student body characteristics, according to our literature 

review.81 While most roundtable experts acknowledged challenges 

agreeing on how to effectively measure academic quality, our prior report 

found that assessing a combination of student outcome measures can 

shed light on the quality of education provided by schools.82

 79For instance, one roundtable expert said that patterns in student enrollment are 

changing and students are increasingly likely to attend more than one school, making it 

more difficult to track results by school. Research has also shown that certain types of 

student body demographics may affect outcomes like graduation rates, such as 

percentages of low-income students. See GAO-15-59. In October 2017, Education 

announced the release of preliminary data from a new survey that is designed to collect 

outcome data for non-traditional students, including those who are part-time and transfer

students. According to the announcement, the final data for 2015-16 will be released in 

early 2018. 

80Information on student-learning outcome metrics varies and may be collected by some 

schools and accreditors. See Hazelkorn, What We Know and Don’t Know About Quality;

Schray, Assuring Quality in Higher Education: Key Issues and Questions; and Ewell, 

Accreditation and Student Learning Outcomes.

81Hazelkorn, What We Know and Don’t Know About Quality, and Robert Shireman, The 

Real Value of What Students Do in College (The Century Foundation, February 2016). A 

few roundtable experts also commented that information about the conditions needed to 

promote academic quality may be helpful to consider. For example, one roundtable expert 

said whether a school has sufficient financial or faculty resources may provide important 

information about academic quality. 

82See GAO-15-59. One roundtable expert authored a paper on an alternative 

accreditation oversight structure, in which the oversight entity would be responsible for 

identifying outcome measures to assess academic quality. We included this paper in our 

literature review and summarize this and other alternative structures later in this report.

Examples of Outcome Measures that May 

Be Related to Academic Quality

Aggregate student outcomes (as collected by 

Education)

• Graduation rate – the percent of first-time 

full-time degree/certificate-seeking 

students who complete a program within 

150 percent of the program length

• Retention rate – the percent of first-time 

degree/certificate-seeking students who 

enrolled in one fall and either successfully 

completed their program or re-enrolled in 

the next fall

• Three-year cohort default rate – the 

percent of borrowers in default 3 years 

after entering repayment status

• Three-year repayment rate – the percent 

of undergraduate borrowers at a school 

who are not in default on their federal 

student loans and who have paid down at 

least $1 of the initial balance on their 

loans 3 years after entering repayment

Student-learning outcomes (based on our 

literature review and accreditor 

documentation)

• Students demonstrate their understanding 

of major theories, approaches, concepts, 

and research findings in their area of 

concentration

• Students demonstrate ability to utilize the 

techniques, skills and modern tools 

necessary for practice

• Students have an understanding of 

professional and ethical responsibility

Source: GAO, Higher Education: Education Should 

Strengthen Oversight of Schools and Accreditors, GAO-15-59 

(Washington, D.C.: Dec. 22, 2014) and GAO analysis of 

research and policy papers and accreditor documentation. | 

GAO-18-5
Page 28 GAO-18-5 Views on Higher Education Accreditation

Many roundtable experts we surveyed also reported that the current 

accreditation system lacks sufficient ways to measure academic quality 

that reflect the wide range of fields of study across schools (see 

sidebar).83 For example, our December 2011 report found that certain 

types of professional fields, such as nursing and law, have licensure 

exams or certifications which can be more easily linked to the academic 

quality of the schools.84 One roundtable expert said that reviewing the 

quality of entire schools may be more complex than reviewing the quality 

of programs within schools, since professional programs are generally 

more comfortable setting expectations for specific indicators of quality, 

like licensure exam pass rates. A few roundtable experts and 

stakeholders we interviewed also noted that in fields that do not have 

licensure exams or certifications, such as liberal arts, reliable and valid 

ways to measure quality can be difficult to identify. One roundtable expert 

said that in some cases, students may be employed in a different but 

related field from their original field of study, making it difficult to identify 

adequate measures of success. While roundtable experts acknowledged 

a lack of agreement on existing measures of academic quality, and a lack 

of measures that reflect the range of fields of study across schools, two 

roundtable experts noted that some accreditors have started placing an 

increased focus on existing student outcome measures as a regular part 

of their review process. For example, in September 2016, the Council of 

Regional Accrediting Commissions—a council representing seven 

regional recognized accrediting agencies in the United States—began a 

new effort to more systematically examine their member schools that 

have low graduation rates.85

 83In our pre-roundtable survey, 11 of 18 roundtable experts (accreditors and nonaccreditors) agreed or strongly agreed that a lack of measures for academic quality for the 

range of schools in the United States is a challenge affecting the current accreditation 

system. Additionally, 13 of 18 roundtable experts (accreditors and non-accreditors) agreed 

that there is a lack of accreditor mechanisms to identify schools that do not meet a 

minimum quality standard. 

84See GAO-12-143. 

85Under this new initiative, participating regional accreditors, who accredit mostly nonprofit 

and public schools, examine four-year schools that have graduation rates at or below 25

percent and two-year schools that have graduation rates at or below 15 percent as part of 

their accreditation reviews. They also follow up with schools to request information about 

conditions that may have led to low graduation rates and how they plan to improve. Since 

graduation rates based on federal data may reflect a small fraction of students at a school, 

these regional accreditors also review data related to transfer rates, loan default rates, 

and loan repayment rates, in addition to other supplemental data.

Identifying sufficient measures 

for academic quality

Perspectives on Identifying Sufficient 

Measures for Academic Quality

“No single accountability metric is perfect. So 

this system needs to have several 

complementary measures that help make up 

for shortfalls that others have. For example, if 

you only look at the levels of debt compared 

to earnings of graduates then you also need 

some measure to account for high rates of 

dropouts. A system based only on one 

measure is likely to fail and not be very 

effective.”

Source: Expert response to GAO survey. | GAO-18-5

“This is an international issue because there 

are no agreed international indicators for 

measuring and comparing quality. Rankings 

have emerged to fill the gap, but they are 

simplistic and comparisons across diverse 

social, economic and political context and 

institutions are extremely difficult to make.”

Source: Expert response to GAO survey. | GAO-18-5
Page 29 GAO-18-5 Views on Higher Education Accreditation

One of accreditation’s main purposes is ensuring that schools—which 

receive over $125 billion in federal student aid annually—provide a quality 

education to students; yet roundtable experts and research have noted 

challenges related to oversight roles and responsibilities, communication 

and transparency, and measuring academic quality. According to papers 

we reviewed, a quality higher education helps position students for longterm success, and strengthens America’s economic competitiveness. We 

will discuss in the next section approaches identified by roundtable 

experts and our literature review for addressing these challenges and 

improving the current accreditation system’s oversight of academic 

quality.
Page 30 GAO-18-5 Views on Higher Education Accreditation

Potential approaches to improve oversight of academic quality at 

postsecondary schools range from modifying triad members’ accreditation 

roles and responsibilities to restructuring the accreditation system, 

according to roundtable experts and our literature review.86 The level of 

specificity available for each approach varied, with some roundtable 

experts and literature providing detailed information about how the 

approach would work and others providing more general descriptions. We 

have categorized these approaches into four areas: 1) modifying 

oversight roles and responsibilities, 2) strengthening communication and 

transparency, 3) using academic quality measures and expanding 

accreditation options, and 4) changing the structure of the accreditation 

system. (See fig. 5.) Experts’ views on the approaches in these areas, 

including the advantages and disadvantages when such information was 

provided, are described in the sections that follow.87

 86Overall, 13 potential approaches were identified for improving oversight of academic 

quality. These approaches were identified by our roundtable experts and through our 

literature review. In this section, we describe 11 of the 13 approaches that more broadly 

address the key challenges with the current accreditation system’s oversight of academic 

quality as identified by our experts. The two remaining approaches are described in 

appendix V. For the approaches identified by roundtable experts, we provide a synthesis 

of information from expert roundtable and post-roundtable survey responses. The 

information presented is not intended to represent the views of GAO or the entire expert 

roundtable, or suggest consensus. Neither GAO nor the roundtable participants as a 

whole recommend or endorse the adoption of any of the specific approaches selected for 

discussion.

87The advantages and disadvantages of the approaches presented in this report

summarize experts’ views and opinions discussed at the roundtable and in their postroundtable survey responses, as well as in our literature review. For the purposes of this 

report, we did not assess the advantages and disadvantages reported by experts. For 

example, some of these approaches may require statutory or regulatory changes to 

implement; this report discusses such issues only to the extent they were identified by the 

experts as an advantage or disadvantage.

Potential Approaches 

Identified by Experts 

and the Literature for 

Improving Oversight 

of Academic Quality 

at Schools Range 

from Modifying Roles 

to Restructuring the 

Accreditation System
Page 31 GAO-18-5 Views on Higher Education Accreditation

Figure 5: Categories of Potential Approaches, Identified by Experts and the 

Literature, for Improving Oversight of Academic Quality

Roundtable experts identified potential approaches for modifying triad 

members’ roles and responsibilities to help them better oversee academic 

quality and address challenges facing the accreditation system. 

Specifically, experts discussed three approaches within this area: (1) 

clarifying or redefining triad members’ oversight roles and responsibilities, 

(2) providing accreditors with protections from legal action when they take 

action against schools not meeting their standards, and (3) repealing the 

statutory provisions that prohibit Education from setting and enforcing 

accreditation standards for student achievement.88 The experts discussed 

these approaches as possible solutions to some of the challenges facing 

the accreditation system, including those discussed previously in this 

report concerning oversight roles and responsibilities for accreditors and 

Education. Providing accreditors with protections from legal action, for 

example, could encourage them to take needed actions against poor 

 88The Higher Education Act prohibits Education from establishing criteria that specify, 

define, or prescribe standards for accreditors to use to assess any school’s success with 

respect to student achievement. It also prohibits Education from developing regulations 

with respect to accreditor standards. 20 U.S.C. §1099b(g),(o).

Modifying Oversight Roles 

and Responsibilities
Page 32 GAO-18-5 Views on Higher Education Accreditation

performing schools, according to some roundtable experts. A few experts 

said that such protections may help to reduce accreditors’ hesitation to 

take adverse actions that could affect schools’ eligibility for federal 

student aid. Tables 1, 2, and 3 provide details on the potential 

approaches to address challenges in the area of oversight roles and 

responsibilities.

Table 1: Summary of Expert Views on Clarifying or Redefining Oversight Roles and Responsibilities

Description of potential 

approach

Potential advantages 

experts identified 

Potential disadvantages 

experts identified

To identify areas of potential overlap 

and duplication, and better assign 

roles and responsibilities to protect 

students and oversee the academic 

quality of schools and programs, 

some experts proposed reexamining the roles and 

responsibilities of triad members—

accreditors, the Department of 

Education (Education) and states—

in overseeing schools and programs.

• A reexamination could better 

focus accreditors’ roles and 

responsibilities on overseeing 

academic quality.a

• Clarifying triad members’ roles 

and streamlining oversight could 

lead to less overlap or 

duplication between Education 

and accreditors in areas such 

as oversight of schools’ financial 

health, potentially providing 

accreditors more capacity to 

focus on academic quality.b

• Triad members may not fulfill their roles and 

responsibilities after they are clarified. For 

example, Education may have difficulty fulfilling 

its responsibilities, such as for financial 

oversight. Thus, some duplication may be 

appropriate and triad members may need to step 

in if another member does not fulfill its 

responsibilities.c

• Schools may not agree with how roles are 

clarified.

• Stakeholders may not agree on whether and to 

what extent the federal government should be 

responsible for clarifying roles. Education may 

overstep its role in the accreditation process.d

Source: GAO analysis of information from GAO expert roundtable and survey responses, and interviews. | GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from the 

expert roundtable and survey responses, and interviews. It is not intended to represent the views of 

GAO or the entire expert roundtable, or suggest consensus. Neither GAO nor the roundtable 

participants as a whole recommend or endorse the adoption of any of the specific approaches 

selected for discussion.

a

One roundtable expert suggested that accreditors should assume a greater role in verifying schools’

claims about the effectiveness of their programs. Accreditors have information about schools’

performance that could be useful to consumers such as students and employers, according to a few 

experts. For example, one expert said accreditors’ responsibilities for monitoring schools’ compliance 

with accreditor standards, and supporting schools’ continuous improvement efforts, could be 

reviewed and redefined.

b

Adopting this approach could help set explicit boundaries on Education’s responsibilities and states’

responsibilities, according to one roundtable expert. In addition, some states may not have the 

capacity to carry out expanded oversight responsibilities, according to another expert. This approach 

could also relieve accreditors from activities other than quality assurance, according to one expert.

c

In another example, a few roundtable experts said that if accreditors are solely responsible for 

reviewing academic quality and they do not effectively fulfill their role, there may be gaps in oversight. 

Also, some roundtable experts said that states’ capacity and approaches to higher education will 

continue to vary, making it difficult to define roles and responsibilities as part of the triad. States 

devote different levels of resources to higher education and that affects their level of involvement in 

the triad, according to some roundtable experts.

d

Currently, Education conducts various financial oversight activities, such as assessing schools 

against financial responsibility standards. 20 U.S.C. § 1099c(c); 34 C.F.R. §§ 668.15, 668.171 –

668.175, and apps. A-B. Because schools and states would not have the authority to define roles for 

each entity involved, Education should establish the roles and responsibilities for those involved in the 

oversight process, according to one expert.
Page 33 GAO-18-5 Views on Higher Education Accreditation

Table 2: Summary of Expert Views on Providing Accreditors with Protections from Legal Action 

Description of potential 

approach

Potential advantages 

experts identified

Potential disadvantages 

experts identified

Develop mechanisms to protect accreditors 

from lawsuits brought by schools when 

accreditors take action against schools for not 

meeting accreditation standards for ensuring 

academic quality. This could include providing 

financial support for accreditors when they 

are sued (indemnification), forming a body of 

accreditors to review an accreditor’s 

recommendation for adverse action to help 

prevent lawsuits before the case is taken to 

court, or instituting arbitration as an option 

when the accreditor takes an adverse action.a

Protection also could include defining the 

types of cases that can be brought to court 

and which courts would have jurisdiction to 

hear them.b

• Developing such a mechanism 

could reduce potential lawsuits 

faced by accreditors when they 

take adverse actions against 

schools.

• Could prevent costly litigation that 

may drain accreditors’ resources.

• If they were protected from 

lawsuits, accreditors may be more 

comfortable taking needed adverse 

actions, such as sanctioning poor 

performing schools.c

• If accreditors are given protection 

from legal action by schools, it may 

increase the risk of accreditors 

focusing less carefully on their 

reviews and making poor decisions 

when assessing schools.d

• Protection from legal action may 

result in students being limited in 

their ability to take actions against 

accreditors that accredit “predatory” 

schools (schools that may 

aggressively recruit students but 

provide a poor academic program).

• In some circumstances, legal action 

may be appropriate.e

Source: GAO analysis of information from GAO expert roundtable and survey responses. | GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from expert 

roundtable and survey responses. It is not intended to represent the views of GAO or the entire 

expert roundtable, or suggest consensus. Neither GAO nor the roundtable participants as a whole 

recommend or endorse the adoption of any of the specific approaches selected for discussion.

a

An accreditor may take adverse actions, including placing a school on probation, issuing a warning, 

or terminating a school’s accreditation, when there is serious concern about a school not meeting its 

standards. Accreditors can also require a school to furnish annual reports on finances or enrollment, 

among other actions.

b

According to one roundtable expert, the Southern Association of Colleges and Schools Commission 

on Colleges has a new policy that has dramatically reduced lawsuits, which also may reduce the 

need for accreditor protection.

c

GAO’s prior work found that over a 4.5-year period, accreditors sanctioned about 8 percent of 

schools for not meeting accreditor standards. Further, GAO’s analysis found that from October 2009 

through March 2014, schools with weaker student outcomes were, on average, no more likely to have 

been sanctioned than schools with stronger student outcomes. In addition, GAO found that 

accreditors terminated accreditation for about 1 percent of accredited schools. See GAO-15-59.

d

One roundtable expert noted that students’ and graduates’ careers may be affected if an accreditor 

makes a poor judgement against a school. According to a few experts, if accreditors mistakenly make 

a poor judgement against a school, they should be held accountable, particularly if students are 

harmed. A few experts emphasized that if given full protection from legal action, accreditors would not 

be accountable for any mistakes they may make in their accreditation decisions.

e

For example, legal action may be appropriate if an accrediting agency violates the law.
Page 34 GAO-18-5 Views on Higher Education Accreditation

Table 3: Summary of Expert Views on Repealing the Statutory Provisions That Prohibit Education from Setting and Enforcing 

Accreditation Standards for Student Achievement 

Description of potential 

approach

Potential advantages 

experts identified

Potential disadvantages 

experts identified

Remove the prohibition in 

the Higher Education Act 

on the Department of 

Education’s (Education) 

ability to set accreditation 

standards for student 

achievement, and have 

Education set and enforce 

student outcome standards 

during its accreditor 

recognition process.a

• If the statutory prohibition were repealed, Education could 

identify common measures to assess schools’ academic 

quality and establish a baseline for acceptable school 

performance, for purposes of federal student aid 

participation.b

• Authorizing Education to set and enforce standards for 

accreditors to meet in its recognition process, based on 

agreed upon data and terms, could help hold accreditors 

with weak student achievement standards accountable.c

• Enforcing such standards could help ensure that federal 

funds are invested in quality schools and programs that 

produce intended benefits for students and taxpayers.

• This approach would give more 

authority to Education than might 

be warranted, according to many 

roundtable experts.

• Education may not have the 

expertise to prescribe a common 

set of standards for school 

performance that is appropriate for 

assessing the wide range of U.S. 

schools with different student 

demographics.d

Source: GAO analysis of information from GAO expert roundtable and survey responses. |GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from the 

expert roundtable and survey responses. It is not intended to represent the views of GAO or the 

entire expert roundtable, or suggest consensus. Neither GAO nor the roundtable participants as a 

whole recommend or endorse the adoption of any of the specific approaches selected for discussion.

a

Under the Higher Education Act of 1965, as amended (Higher Education Act), to be recognized by 

Education, accreditors are required to apply and enforce standards in specified areas to assess 

whether the programs or courses offered by schools are of sufficient quality to achieve their 

objectives. The standards can differ among accreditors, and accreditors also may establish standards 

in additional areas not required by law. 20 U.S.C. § 1099b(a)(4),(a)(5), (g). The Higher Education Act 

prohibits Education from establishing criteria that specify, define, or prescribe standards for 

accreditors to use to assess any school’s success with respect to student achievement. It also 

prohibits Education from developing regulations with respect to accreditor standards. 20 U.S.C. § 

1099b(g).

b

A few roundtable experts said that common measures based in research should be developed by the 

appropriate stakeholder group. Measures may vary depending on the type of school or program being 

reviewed but could include student outcomes such as graduation, retention, student loan repayment 

and default, and job placement rates. Education has taken some steps to make public the measures 

and data that accreditors use to assess schools’ academic quality.

c

Under the Higher Education Act, Education recognizes accreditors it determines to be reliable 

authorities as to the quality of education offered by schools. To be recognized by Education, 

accreditors must meet certain statutory and regulatory criteria and have certain operating procedures 

in place. Accreditors also must have their recognition renewed by Education at least every 5 years. 

20 U.S.C. § 1099b(a),(c),(d).

d

A few roundtable experts suggested that accreditors, with input from schools, industry professionals, 

and other stakeholders, have the expertise needed to set standards, and therefore are more 

appropriate for that role than Education. For example, one expert expressed concern that Education 

may set standards in a “one-size-fits-all” measurement system, or become overly prescriptive about 

what those outcomes should be. Further, if Education should determine that a specific graduation rate 

or other outcome measure would be used as a metric for all schools, it may have an impact on certain 

types of schools. For example, having to meet a graduation rate set for all types of schools may 

pressure schools that participate in federal student aid to lower their graduation standards to allow 

more students to graduate, and penalize accreditors that oversee schools serving disadvantaged 

populations, according to a few roundtable experts.
Page 35 GAO-18-5 Views on Higher Education Accreditation

Some roundtable experts identified potential approaches to help 

strengthen communication and transparency in the current accreditation 

system to enhance oversight of academic quality. These were (1) 

improving communication and collaboration among triad members, and 

(2) increasing the transparency of accreditation information that is shared 

with the public.89 The experts discussed these approaches as possible 

solutions to some of the challenges facing the accreditation system, 

including those previously discussed concerning communication among 

members of the triad and sharing information with the public. For 

instance, increasing the transparency of accreditation information may 

address concerns that the system does not provide students with useful 

information to help them assess the quality of schools. As previously 

noted, general information about which schools are and are not 

accredited is publicly available on Education’s website. However, some 

experts raised questions about whether students understand that schools 

with very different records of performance may have the same accredited 

status. Tables 4 and 5 provide details on the potential approaches for 

improvements in the areas of communication and transparency.

 89We have developed a body of work that identifies key practices for improving 

collaboration, which includes any joint activity that is intended to produce more public 

value than could be produced when agencies act alone. As part of this work, we describe 

how agencies can enhance and sustain their collaborative efforts by engaging in eight 

practices, including agreeing on roles and responsibilities and establishing mutually 

reinforcing or joint strategies. For a detailed discussion of these practices, see GAO, 

Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

Strengthening 

Communication and 

Transparency
Page 36 GAO-18-5 Views on Higher Education Accreditation

Table 4: Summary of Expert Views on Improving Accreditation Communication and Collaboration

Description of potential 

approach

Potential advantages 

experts identified

Potential disadvantages 

experts identified

Improve how triad members—accreditors, 

the Department of Education (Education), 

and states—work together to address 

accreditation issues, such as schools at 

risk of closing. Improvements could involve 

(1) establishing a body of triad members 

that meets regularly; (2) identifying specific

triggers that require communication and 

collaboration among the triad; and (3) 

routinely sharing case studies, best 

practices, and other relevant information 

among triad members.a

• Improving how triad members work 

together could also improve the 

triad’s effectiveness when it comes 

to sharing information, identifying 

schools’ potential performance 

problems, and determining 

appropriate action needed.b

• Improving effectiveness of the triad 

could benefit schools and students 

by providing more timely 

information about performance 

problems.c

• Improving communication and 

collaboration may be difficult to 

implement and enforce, and may 

require statutory changes, including 

specifying how triad members will 

work together.d

• This approach would require 

clarification of triad members’ roles 

and responsibilities for overseeing 

academic quality, such as who is 

responsible for convening triad 

meetings.

Source: GAO analysis of information from GAO expert roundtable and survey responses, Education documentation, and interviews. | GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from the 

expert roundtable and survey responses, Education documentation, and interviews. It is not intended 

to represent the views of GAO or the entire expert roundtable, or suggest consensus. Neither GAO 

nor the roundtable participants as a whole recommend or endorse the adoption of any of the specific 

approaches selected for discussion.

a

One roundtable expert suggested identifying triggers, or specific circumstances, that would require 

triad members to work together when schools or programs have performance problems. A few 

experts also noted that re-establishing a former effort of Education’s in which it acted as a liaison to 

states could help improve communication and collaboration.

b

For example, some states may collect data on postsecondary schools and could alert accreditors 

and Education about schools with potential performance problems, according to one roundtable 

expert. Education has taken some recent steps to improve the department’s existing requests for 

information sharing. In January 2016, the Education office responsible for postsecondary education 

issued a memorandum to the Secretary with several recommendations, including requesting more 

information from accreditors on schools with performance problems, such as warnings or admonitions 

for potential violations of standards related to certain areas, including student achievement. The 

memo also identified opportunities to improve information sharing with states.

c

For example, according to one roundtable expert, if Education convened triad members to develop 

performance improvement plans for poor performing schools it could help prevent closures. 

Performance improvement plans may be used to identify a set of interventions to address deficiencies 

at a school.

d

This approach could interfere with the independent exercise of individual triad member activities, if 

roles and responsibilities are not carefully specified, according to one roundtable expert.
Page 37 GAO-18-5 Views on Higher Education Accreditation

Table 5: Summary of Expert Views on Increasing Transparency of Accreditation Oversight Information

Description of 

potential approach

Potential advantages 

experts identified

Potential disadvantages 

experts identified

Make accreditation 

information more

available and 

accessible for 

policymakers, 

students, and the 

public.a

• Increasing transparency may also increase 

public trust and help students, policymakers, 

and the public make better decisions.b For 

example, it could help students make 

decisions about schools they are planning to 

attend, and help policymakers develop more 

informed accreditation policy proposals.

• This approach could also strengthen 

accountability and help policymakers and 

the public assess the performance of 

accreditors and schools.c

• Even with increased transparency, accreditation 

information, terminology, and processes can be 

complicated and could be difficult for the public and 

policymakers to understand.d

• There is not a common understanding of what 

increasing transparency means in practice—that is, 

which documents and information should be made 

public.

• If detailed accreditation information is made available 

to the public, confidentiality of the peer review process 

may be undermined.e

Source: GAO analysis of information from GAO expert roundtable and survey responses, documentation from the Department of Education (Education), and other documentation.| GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from the 

expert roundtable and survey responses, Education documentation, and other documentation. It is 

not intended to represent the views of GAO or the entire expert roundtable, or suggest consensus. 

Neither GAO nor the roundtable participants as a whole recommend or endorse the adoption of any 

of the specific approaches selected for discussion.

a

This may include reaching agreement on the appropriate accreditation documents and data to 

publicly release, according to one roundtable expert. Accreditors, Education, and schools are 

currently required to provide various types of accreditation information to the public. For example, 

among other things, accreditors are required to make certain information available to the public 

related to: (1) decisions to award accreditation or reaccreditation, (2) final denial, withdrawal, 

suspension, or termination of accreditation, any findings, and the schools’ official comments, and (3) 

decisions to place schools on probation or take other adverse actions. 20 U.S.C. § 1099b(c)(7). 

Education is required to publish a list of recognized accreditors and to make publicly available the 

reason for denying recognition to an accreditor, including the specific statutory criteria that were not 

fulfilled. 20 U.S.C. §§ 1001(c), 1099b(n)(4). Schools participating in federal student aid programs are 

required to provide certain information annually to all enrolled students and upon request to any 

enrolled or prospective student, including the name of their accreditor(s) and the procedures by which 

students may review documents describing the school’s accreditation. 20 U.S.C. § 1092(a)(1)(J).

b

Accreditors and Education have taken some steps to share more accreditation oversight information 

with the public. For example, in July 2012, the Accrediting Commission for Senior Colleges and 

Universities of the Western Association of Schools and Colleges began posting all its accreditation 

evaluation reports on its website. Education provides general information on its website about the 

accreditation process and which schools are accredited or not accredited. In April 2017, Education 

began posting accreditor decision letters on its website, which explain the accreditors’ reasons for 

taking adverse actions against certain schools. Additionally, the National Advisory Committee on 

Institutional Quality and Integrity (NACIQI), which advises Education on accreditation issues, holds 

public meetings at least twice a year to review applications for recognition submitted by accreditors 

and make recommendations to Education’s Senior Department Official designated to make the 

decision regarding recognition. Transcripts of NACIQI’s meetings are publicly available on 

Education’s website.

c

In our pre-roundtable survey, 10 of 18 roundtable experts disagreed or strongly disagreed that 

students receive useful accreditation information. A few experts also said that publicly releasing 

student outcome data could help the public better understand school performance. Through 

“accreditor dashboards,” Education has taken one step toward making such information available. In 

June 2016, Education began publishing “accreditor dashboards” on its website to help policymakers 

and the public understand the student outcomes of accredited schools, such as their graduation 

rates.
Page 38 GAO-18-5 Views on Higher Education Accreditation

d

A few roundtable experts noted that students may misinterpret accreditation information that is 

currently available and assume that all accredited schools meet the same standards of academic 

quality.

e

Accreditors generally re-evaluate their member schools at least every 10 years (depending on the 

accreditor and the school) using a process that involves volunteer peer reviewers.

Some roundtable experts identified potential approaches for using 

academic quality measures in school evaluations and for expanding 

accreditation options. The two approaches discussed were (1) focusing 

on student achievement and the performance of schools and programs, 

and (2) providing more categories of accreditation to help differentiate 

schools’ accreditation status and eligibility for federal student aid.90 The 

experts discussed these approaches as possible solutions to some of the 

challenges facing the accreditation system, including those previously 

discussed concerning defining and identifying reliable and valid ways to 

measure academic quality. For example, focusing on student 

achievement and school performance could lead to addressing 

challenges related to measuring academic quality. As previously 

discussed, since academic quality can be measured and interpreted in 

various ways and affected by many factors, there is a lack of agreement 

on how to measure it effectively.91 This approach could encourage the 

identification of some common measures for academic quality. In 

addition, expanding accreditation categories could help reduce the 

tension accreditors may experience in helping schools to improve, while 

making decisions about schools’ accreditation status that can impact 

schools’ eligibility for federal student aid. For example, this approach may 

allow schools to remain accredited but receive varying levels of federal 

student aid while they correct deficiencies identified by their accreditor. 

Tables 6 and 7 provide details on these potential approaches in the area 

of using academic quality measures and expanding accreditation options.

 90Student achievement may refer to student outcomes—measures that can range from 

graduation rates to assessments of what students learn from their education—according 

to our literature review, some roundtable experts, and our prior work. 

91Our prior work also found that the ways accreditors measure quality vary widely, with 

some accreditors focusing on quantitative measures, such as licensure exam pass rates, 

and others relying on more qualitative measures, such as whether a school is evaluating 

success with respect to its mission. See GAO-15-59.

Using Academic Quality 

Measures and Expanding 

Accreditation Options
Page 39 GAO-18-5 Views on Higher Education Accreditation

Table 6: Summary of Expert Views on Focusing on Student Achievement and School Performance 

Description of potential 

approach

Potential advantages 

experts identified

Potential disadvantages 

experts identified

Increase accreditors’ focus 

on student achievement 

when they assess schools’ 

academic quality, with an 

emphasis on measuring 

student outcomes.a

• Emphasizing student achievement could 

shift focus from inputs to outcomes and 

create an opportunity for schools to 

continuously improve, and set goals that 

better serve students.

b

• Measuring outcomes could increase focus 

on aspects of school performance that 

students, employers, and other 

stakeholders care about, such as 

employment and earnings outcomes and 

student learning.c

• Accreditors could better identify schools 

and programs with performance challenges 

and hold them accountable.

• Accreditors’ individual efforts to focus on 

student outcomes could lead to shared 

terms and approaches among accreditors, 

better information for students, and a 

defined minimum acceptable level of 

performance for schools. 

• Emphasizing student achievement could present 

measurement difficulties as there is no single 

metric that captures both student outcomes and 

student learning, in part because academic 

quality varies within schools, as well as among 

schools.

• Available measures of student achievement tend 

to focus on graduation rates and financial 

outcomes, such as earnings and loan default and 

repayment rates. However, these measures may 

not provide a complete picture of certain types of 

schools, such as some community colleges.d

• Defining student achievement in federal law or 

via national or regional accreditors may pose a 

challenge, given the wide range of U.S. schools 

with different missions and programs. Because of 

the many fields of study and reasons students go 

to school, the challenge is defining student 

achievement in a way that will work equally well 

for all schools.e

Source: GAO analysis of information from GAO expert roundtable and survey responses, the Department of Education (Education) documentation, and literature. | GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from the 

expert roundtable and survey responses, Education documentation, and literature. It is not intended 

to represent the views of GAO or the entire expert roundtable, or suggest consensus. Neither GAO 

nor the roundtable participants as a whole recommend or endorse the adoption of any of the specific 

approaches selected for discussion.

a

Student outcomes—measures that can range from graduation rates to assessments of what 

students learn from their education—may reflect academic quality, according to GAO’s literature 

review, some roundtable experts, and GAO’s prior work. Currently, national, programmatic, and 

regional accreditors may use various measures of student achievement in their evaluation efforts, 

according to a few experts.

b

One paper explained that inputs, such as the student-teacher ratio, may indicate academic quality 

since a lower ratio could mean that students have better access to professors. However, such 

information may provide more insight on the funding or efficiency of the school rather than the quality 

of the academic experience it provides. See Ellen Hazelkorn, What We Know and Don’t Know About 

Quality (Washington, D.C.: April 2013). A few roundtable experts also commented that information 

about the conditions needed to promote academic quality may be helpful to consider. For example, 

one roundtable expert said that whether a school has sufficient financial or faculty resources may 

provide important information about academic quality. Information on student outcomes may also 

reflect academic quality. However, a few roundtable experts said that any comparison of schools 

based on student outcome measures should consider any differences in schools’ student 

demographic characteristics.

c

A few roundtable experts suggested that any student outcomes identified for schools nationally 

should reflect differences in program-level and school-level student outcomes, as well as differences 

in the type of school.

d

A few roundtable experts commented that available data collected by Education on such measures 

has limitations. One roundtable expert noted that Education’s data on graduation rates applies to firsttime, full-time students, which may account for a small percentage of students at community colleges. 

Another roundtable expert commented that without better data on these measures, implementing this 

approach may not be possible. In October 2017, Education announced the release of preliminary 
Page 40 GAO-18-5 Views on Higher Education Accreditation

data from a new survey that is designed to collect outcome data for non-traditional students, including 

those who are part-time and transfer students. According to the announcement, the final data for 

2015-16 will be released in early 2018.

e

A school’s mission identifies its unique goals and priorities, the students it seeks to serve, and 

reflects its vision for the future. For example, a community college’s mission may be to educate 

students who wish to transfer to other schools to pursue a degree. On the other hand, the mission of 

a research university may be to provide undergraduate, graduate, and professional education and 

research. Accreditors are currently required to have standards that assess, among other things, 

schools’ success with respect to student achievement in relation to the school’s mission. 20 U.S.C. § 

1099b(a)(5)(A).

Table 7: Summary of Expert Views on Expanding Accreditation Options

Description of potential 

approach

Potential advantages 

experts identified

Potential disadvantages 

experts identified

Create an additional category 

for schools’ accreditation 

status based on the results of 

accreditors’ reviews and 

modify schools’ eligibility for 

federal student aid 

accordingly.a An additional 

category for schools’ 

accreditation status could be 

schools that are accredited but 

need improvement.b Schools in 

this category would be partially 

eligible for federal student aid, 

and only current students 

would receive aid. Schools 

would not be eligible to provide 

federal student aid to new 

students.c

• Expanding accreditation options could provide 

greater flexibility that would allow schools with 

identified areas for improvement to remain 

accredited and receive varying levels of access to 

federal student aid, as determined by the 

Department of Education (Education).d

• More options could assist accreditors by allowing 

them to maintain their traditional quality 

improvement role while serving more effectively 

as gatekeepers of federal student aid funds.

• This approach could lead to students and the 

public getting more information about 

accreditation decisions and school quality and 

performance.

• Schools would be notified about performance 

challenges and accreditors would continue to work 

with schools to correct deficiencies.

• Reduced aid may result in many school 

closures, except for those with 

significant financial resources. 

Therefore, expanding accreditation 

options to allow for schools to receive 

reduced aid may not encourage 

accreditors to take actions against 

schools.

• Expanding accreditation options may be 

complicated for Education to 

implement.e

• Without more common language and 

definitions of actions across accreditors, 

a school being accredited but having 

limited access to federal student aid 

may confuse the public and add another 

layer of complexity to requirements for 

accreditors.

Source: GAO analysis of information from GAO expert roundtable and survey responses, Education documentation, and literature. | GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from the 

expert roundtable and survey responses, Education documentation, and literature. It is not intended 

to represent the views of GAO or the entire expert roundtable, or suggest consensus. Neither GAO 

nor the roundtable participants as a whole recommend or endorse the adoption of any of the specific 

approaches selected for discussion.

a

One of the requirements for a school to participate in federal student aid programs is that the school 

must be accredited by an accrediting agency that is recognized by Education as being a reliable 

authority as to the quality of education or training offered. 20 U.S.C. §§ 1001(a)(5), 1099b. Under the

current system, accreditors can take certain steps to differentiate accreditation of schools based on 

school performance, such as by modifying the number of years between accreditation reviews, 

requiring that a school under review submit data to the accreditor, or requiring a school to undergo 

more frequent site visits. In April 2016, Education sent a letter to recognized accreditors informing 

them of the flexibility they have to differentiate their reviews of schools and programs and 

encouraging them to use that flexibility to focus monitoring and resources on student achievement 

and problematic schools or programs.

b

Placing a school in the “accredited but needing improvement” category could more clearly distinguish 

it from a school with a stronger performance record than under the current accreditation system, in 

which a school either is or is not accredited, according to a few roundtable experts.

c

Another potential approach to expanding accreditation options, identified in our literature review, 

uses risk assessment and information on student outcomes to assign a school to an accreditation 
Page 41 GAO-18-5 Views on Higher Education Accreditation

category. For a risk assessment, quantitative and qualitative information is used to evaluate the risk a 

school poses to the financial investment of the federal government, students, and their families. This 

approach emphasizes using two types of outcome measures considered in accreditation reviews. 

Quantitative measures of school-level student outcomes would be based on data already collected by 

Education, such as graduation rates. Qualitative measures of student learning outcomes would be 

based on learning outcomes and assessment measures that the school selects, such as written 

exams. Reviewers would then use their professional judgement to assess the school’s risk to 

taxpayer and student investments and assign a school to a low, medium, or high confidence 

category. See EducationCounsel, Outcomes-Focused, Differentiated Accreditation, a Framework for 

Policy and Practice Reform (Washington, D.C.: April 15, 2016). Two international accreditation 

systems also use risk assessment and outcome measures, to some extent, according to a paper in 

the literature review. According to one paper reviewed, Australia’s Tertiary Education Quality 

Standards Agency, a centralized accreditation agency, uses a risk-based accreditation approach that 

includes evidence such as student characteristics and outcomes and documentation of schools’

financial viability. The paper also said that the United Kingdom is developing a framework for 

determining schools’ eligibility for government funding that also includes a risk assessment. The types 

of evidence reviewed include information from schools’ internal and external auditors and other public 

bodies. The United Kingdom is also planning to include outcome measures, according to the paper. 

See Coleman, Arthur L., Teresa E. Taylor, and Bethany M. Little, New Directions in Regulatory 

Reform: Prospects for Reducing Regulatory Burden Through Risk-Informed Approaches in Federal 

Law Governing American Higher Education (EducationCounsel, December 2014).

d

Schools may be subject to increased reporting or review by their accreditor.

e

Decisions about schools’ participation in federal student aid programs should be Education’s 

responsibility, not accreditors, according to one roundtable expert.

We identified four approaches in the literature—three of which were 

developed by roundtable experts—to establish new entities that would 

change the current structure of the accreditation system for overseeing 

academic quality and the responsibilities of accreditors and Education.92

These four approaches discussed more significant changes to the current 

accreditation system. The approaches ranged from establishing an 

independent authorizer that would assess innovative program providers’

eligibility for federal student aid to delegating all of Education’s 

accreditation responsibilities to a congressionally chartered entity.93 (See 

text box.) Appendix VI presents tables that provide additional details 

about the four approaches.

 92These approaches do not discuss changing the role of states in higher education 

oversight. The information in this report on these approaches generally summarizes our 

analysis of information from our literature review. We are not recommending or endorsing 

the adoption of any of the approaches identified.

93Currently, certain innovative programs, such as coding boot camps and massive open 

online courses, are generally not eligible to receive federal student aid. Coding boot 

camps are vocational training programs offered by private companies that teach students 

computer programming at less cost than a college degree in computer science. Massive 

open online courses are courses offered over the internet that are usually free, award no 

credit, and enroll large numbers of students. 

Changing the Structure of 

the Accreditation System
Page 42 GAO-18-5 Views on Higher Education Accreditation

Alternative Accreditation Oversight Structures Identified by Experts and GAO’s Literature Review

Independent authorizer: An authorizer would be approved by the Department of Education (Education) to help determine the federal 

student aid eligibility of innovative educational program providers.a The authorizer would adopt standards set by another independent 

entity—a nonprofit organization that would develop and maintain standards for student outcomes—but set thresholds for the 

programs it reviewed. Education would assess the effectiveness of the standards.

Third-party entities: The third-party entities would set standards and identify both the outcome measures and the threshold levels 

used to assess academic quality at the program level. Schools could choose to be reviewed under this new standard-setting system, 

or by an existing accreditor. If a school chooses to be reviewed under this new system, Education, rather than peer reviewers, would 

conduct the review.

Higher education quality assurance commission: A commission would coordinate and align the activities of existing accreditors. It 

would assume Education’s current responsibility for recognizing accreditors. The commission would set standards while allowing 

accreditors to tailor their reviews to the types of schools and programs they accredit. Accreditors’ role in assessing schools’ 

academic quality and in determining eligibility to access federal student aid funds via the accreditation process would not change.b

A congressionally chartered accreditation governance entity: The entity would assume Education’s current role and responsibilities in 

the accreditation process. It would recognize accreditors, create and maintain standards, and determine whether a peer review 

process would be used to assess and monitor schools’ improvement.c If peer review is used, the current accreditor role in making 

accreditation decisions that affect schools’ access to federal student aid funds would not change. 

Source: GAO literature review. | GAO-18-5 

a

Currently, certain innovative programs, such as coding boot camps that teach students computer programming and massive open online courses, 

are generally not eligible to receive federal student aid. Coding boot camps are training programs offered by private companies that teach students 

computer programming and can cost less than a college degree in computer science. Massive open online courses are non-credit courses offered 

over the internet that enroll large numbers of students. While tuition for some of these courses might be low or no cost, low income students may 

benefit from federal student aid that can be used to purchase resources such as laptops and high speed internet connections to participate in these 

courses, according to one expert.

b

Currently, accreditation is one of the requirements that helps determine schools’ federal student aid eligibility, but not the sole factor. To participate in 

federal student aid programs authorized under Title IV of the Higher Education Act of 1965, as amended, schools must meet various other 

requirements; for example, in addition to being accredited, schools must be authorized to provide postsecondary education by the state in which they 

are located and be certified by Education as meeting certain administrative capability and financial responsibility requirements. If schools are not 

accredited, they are not eligible to access federal student aid.

c

Peer reviewers, comprising a range of knowledgeable academic faculty and administrators, assess the academic quality of schools and provide 

schools with critical feedback on their weaknesses and areas for improvement, based on our literature review, expert roundtable discussion, and 

stakeholder interviews.

The different entities identified in the four approaches shared some 

features that could potentially address one or more challenges related to 

the oversight of academic quality identified by our roundtable experts. In 

all four approaches, new entities would set standards for assessing 

schools’ academic quality and receive federal funding to support their 

activities and operations. By assuming responsibility for setting standards,

and by receiving funding from the government rather than schools, the 

proposed entities could potentially help alleviate some of the challenges 

roundtable experts identified with the current accreditation system. For 

example, roundtable experts said these features could help alleviate the 

tension that accreditors face in the current system in performing the dual 
Page 43 GAO-18-5 Views on Higher Education Accreditation

role of facilitating schools’ self-improvement and serving as gatekeepers 

to federal student aid funds. Roundtable experts also thought these 

features could address the concern regarding accreditors’ potential 

conflicts of interest associated with overseeing schools from which they 

receive membership fees.

The approaches, however, differ with respect to how they assign 

responsibility for other accreditation oversight functions. For example, one 

approach would allow providers at the program level to choose between 

existing accreditors under the current accreditation system or Education 

under an alternative system to assess whether standards have been 

met.94 In contrast, two other approaches suggest reducing Education’s 

role in accreditor recognition by delegating this responsibility to an 

independent accreditation oversight entity.95

While these approaches for restructuring the current accreditation 

system, as well as those previously discussed by our roundtable experts, 

are in the conceptual phase of development, ensuring sound oversight of 

academic quality is critical to preserving the integrity and credibility of the 

U.S. accreditation system.96 Policymakers may need to determine which 

approaches, alone or in combination with others, best reflect the goals of 

 94This approach would establish third-party entities that would set standards and identify 

both the outcome measures and the threshold levels used to assess academic quality at 

the program level. One of our roundtable experts co-authored a paper developing this 

approach.

95One of the approaches that propose reducing Education’s role in accreditor recognition 

would establish a higher education quality assurance commission to coordinate and align 

the activities of existing accreditors. The commission also would assume Education’s 

current responsibility for recognizing accreditors. The other approach would establish a 

congressionally chartered accreditation governance entity that would assume Education’s 

current role and responsibilities in the accreditation process. 

96An initiative by the Quality Assurance Commons for Higher & Postsecondary Education, 

announced in September 2017, also would change the way accreditation is conducted. 

This initiative, a pilot project to assess higher education programs at 14 institutions around 

the country, plans to develop an approach to accreditation reform that focuses on 

students’ employability qualities—skills in collaboration and problem-solving. Because this 

initiative was recently announced, we have not included it in our review. 
Page 44 GAO-18-5 Views on Higher Education Accreditation

ensuring a strong accreditation system and protecting students’ and 

taxpayers’ investment in higher education.97

We provided a draft of this report to Education for its review and 

comment. Comments from Education are reproduced in appendix VII. In 

its written comments, Education stated that it is carefully reviewing the 

report as it works to improve access to postsecondary education 

opportunities for all students and to improve the role of the Department in 

the accreditation process continually. Education also provided technical 

comments, which we incorporated in the report, as appropriate. 

In addition, we provided excerpts of the draft report for technical review to 

the 18 roundtable experts and the authors of the four approaches from 

our literature review—three of whom were also roundtable experts. We 

incorporated technical comments from these individuals, as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to interested congressional 

committees, the Department of Education, and other interested parties. In 

addition, the report will be available at no charge on the GAO website at 

http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (617) 788-0534 or emreyarrasm@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VIII.

Melissa Emrey-Arras, Director

Education, Workforce, and Income Security Issues

 97In addition to the studies we reviewed, we also identified some accreditation-related bills 

introduced in the 113th or 114th Congress that reflected similar themes in their proposed 

changes to the current accreditation system, including proposals for the use of student 

outcome measures such as student learning and job placement rates, and the 

development of new oversight bodies.

Agency Comments
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-18-5 Views on Higher Education Accreditation

Our research objectives were to examine (1) the strengths and 

challenges of the current U.S. accreditation system in overseeing the 

academic quality of schools, and (2) potential approaches for improving 

the U.S. accreditation system’s oversight of academic quality. To address 

these objectives, we used a variety of data collection methods, including 

expert surveys and a roundtable discussion; interviews with Department 

of Education (Education) officials and other higher education 

stakeholders; a literature review; a review of relevant federal laws and 

regulations, and Education policies, guidance, and reports; and analysis 

of Education data on student outcomes. Key methods are described in 

greater detail below.

On September 29th and 30th, 2016, with the assistance of the National 

Academies of Sciences, Engineering, and Medicine (National 

Academies), we convened a 2-day roundtable of 18 experts to discuss 

the U.S. accreditation system’s strengths and challenges in oversight of 

academic quality of postsecondary schools and potential approaches for 

improvement.1 On the second day of the roundtable, we asked each 

expert to identify six potential approaches for further discussion from a 

longer list of options identified during stakeholder interviews, the expert 

pre-roundtable survey, and the roundtable discussion. We aggregated the 

responses for the approaches that were identified most frequently and 

grouped them into nine broad approaches for improvement. Then, 

experts exchanged their views on the nine approaches, which we discuss 

earlier in this report and in appendix V.

Appendix II provides a list of the 18 experts who participated in the 

roundtable, along with their affiliation.2 These experts represented a 

broad spectrum of views and backgrounds from Education and key higher 

education stakeholder groups, including associations and others 

representing accreditors, policy institutes, public and private 2- and 4-year 

 1

The National Academies is a private, nonprofit organization whose mission is to provide 

independent, objective analysis and advice to the nation and conduct other activities to 

solve complex problems and inform public policy decisions. Our meeting of experts was 

planned and convened with the assistance of the National Academies to better ensure 

that a breadth of expertise was brought to bear in its preparation. However, all final 

decisions regarding meeting substance and expert participation are the responsibility of 

GAO.

2

Six of the 18 roundtable experts are no longer in the position they held at the time of 

GAO’s roundtable. See appendix II for additional information.

Appendix I: Objectives, Scope, and 

Methodology

Expert Roundtable 

Discussion
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-18-5 Views on Higher Education Accreditation

schools, state higher education officials, and students.3 We selected 

experts based on their experience and knowledge of higher education 

accreditation issues, and recommendations from the National Academies.

To help identify any potential biases or conflicts of interest, we required 

each expert who participated in the roundtable to report his or her 

investments, sources of earned income, organizational positions, 

relationships, and other circumstances that could affect, or could be 

viewed to affect, his or her view on accreditation. Of the 18 roundtable 

experts, three reported potential conflicts of interest related to their prior 

accreditation work or their employer’s current efforts on 

accreditation. However, these individuals had expertise that we 

considered important for the success of the roundtable as a whole. In our 

review of the roundtable transcript, we analyzed the evidence these 

individuals presented with these disclosures in mind. We believe that the 

balance of experts represented in the roundtable overall mitigate any 

risks from these potential conflicts.

We administered two surveys—a pre- and post-roundtable survey—to the 

18 experts who participated in our roundtable.4 To inform our roundtable 

discussion, we surveyed experts prior to the roundtable to quantify their 

responses on key accreditation strengths and challenges, and obtain 

information on potential approaches for improvement.5 We also surveyed 

experts after the roundtable to collect additional information on the nine 

 3

We invited an association representing career postsecondary schools primarily in the forprofit sector to participate in the expert roundtable. The association declined to participate 

in the roundtable and related pre- and post-roundtable surveys; however, two 

representatives participated in an interview. Similarly, we invited an organization 

conducting projects related to higher education accreditation to participate in the 

roundtable. The organization was unable to participate in the roundtable; however, a 

representative participated in an interview and completed the pre- and post- roundtable 

surveys.

4

We pretested our pre-roundtable survey with the National Academies prior to 

administering the survey to help ensure our survey questions were clear. The questions in 

the post-roundtable survey were developed using the transcript of the expert roundtable 

on the nine approaches selected for discussion. In addition to the 18 experts who 

participated in the roundtable, we provided both surveys to the two experts who were 

unable to participate in the roundtable: the association representing career postsecondary 

schools primarily in the for-profit sector, and the organization working on accreditation 

issues. While the organization completed both surveys, the association declined to 

participate in the surveys.

5

We administered the pre-roundtable survey in September 2016.

Expert Roundtable 

Surveys
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-18-5 Views on Higher Education Accreditation

approaches they identified for discussion related to improving the 

accreditation system’s oversight of academic quality, and the advantages 

and disadvantages of these approaches.6 To ensure adequate response 

rates on both surveys, we conducted follow-ups with non-respondents. 

Eighteen experts responded to both the pre- and post- roundtable 

surveys.

To identify the strengths and challenges of the current accreditation 

system and potential approaches for improvement, we interviewed 

Education officials and other higher education stakeholders. Specifically, 

we interviewed stakeholders from organizations representing academia, 

policy organizations, accrediting agencies, states, and schools.7 We 

interviewed these stakeholders to obtain additional views on 

accreditation.8 For stakeholder interviews, we used semi-structured 

interview protocols, which included questions related to key accreditation 

strengths and challenges. We also asked questions related to 

international efforts to improve accreditation.

To provide additional information on key accreditation issues, we 

conducted a literature review of 52 research and policy papers using two 

data collection methods.9 First, we conducted a formal search of the 

literature on accreditation published from January 2015 to June 2016 to 

identify papers on key accreditation strengths and challenges and 

potential approaches for improvement. To identify relevant papers, we 

searched a variety of databases with the assistance of a research 

librarian, limiting our formal review to papers that were included in peerreviewed publications.10 We then reviewed the results and excluded 

 6

We administered the post-roundtable survey from October 2016 to April 2017.

7

Some stakeholders we interviewed also participated in our expert roundtable.

8

The information gathered from our interviews is not generalizable, but is useful in 

illustrating a range of views on key accreditation issues. 

9

In this report, we use the term “paper” to refer to the wide range of accreditation research 

and policy papers we reviewed. These papers included published papers by academic 

researchers, research and policy organizations, and other higher education associations. 

See appendix III for a list of the papers we reviewed.

10We searched a variety of databases, including Education Resources Information Center 

(also known as “ERIC”), ProQuest, and Scopus. Also, by limiting our formal review to peer 

reviewed publications, we excluded non-peer reviewed publications, such as dissertations 

and working papers.

Education and 

Stakeholder Interviews

Accreditation Literature 

Review
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-18-5 Views on Higher Education Accreditation

papers that were (1) technical or discipline-specific and case studies that 

did not have wide applicability across the accreditation system; (2) how-to 

guides for accreditation, such as implementation methods, instructions for 

schools, or strategies for obtaining accreditation, among other things; and 

(3) focused on improving curriculum delivery, revising accreditation 

standards, institutional governance, management, teacher preparation, or 

training options. Second, we identified additional accreditation papers 

through recommendations provided by stakeholders we interviewed or 

experts who participated in our roundtable. The types of papers identified 

by experts varied widely and included published papers by academic 

researchers, policy institutes and other organizations, and associations. 

(See appendix III for the list of research and policy papers we reviewed.)

To identify strengths and challenges of the accreditation system, we 

analyzed and synthesized information across the sources described 

above, including our literature review, expert surveys and roundtable 

discussion, and stakeholder interviews. We grouped the information by 

source and organized key issues related to our research objective into 

broader themes, such as oversight roles and responsibilities and 

communication and transparency. We used the literature review and 

stakeholder interviews to complement the information discussed in the 

pre-roundtable survey and expert roundtable. We shared our summary of 

the strengths and challenges with the roundtable experts to obtain their 

comments.

To inform our discussion of potential approaches, we reviewed and 

synthesized information on the nine broad approaches for improvement 

identified by experts at the roundtable and augmented by their survey 

responses. These nine approaches generally focused on modifying the 

current accreditation system. Through our review of the literature, we 

identified four additional approaches—three of which were developed by 

roundtable experts—to establish new entities that would change the 

current structure of the accreditation system for overseeing academic 

quality and the responsibilities of accreditors and Education. In our report, 

we provided descriptions of potential approaches from the various 

information sources to reflect the diverse range of options that have been 

proposed to improve the accreditation system. To ensure that we 

appropriately characterized the range of potential approaches for 

improving the accreditation system, we shared our summary of the nine 

approaches with the roundtable experts to obtain their comments. We 

also shared our summary of the four approaches from our literature 

review with the papers’ authors—three of whom were also roundtable 

Analysis of Multiple 

Information Sources
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-18-5 Views on Higher Education Accreditation

experts—to gain their views and perspectives. Neither GAO nor the 

roundtable participants as a whole recommend or endorse the adoption of 

any of the specific approaches selected for further discussion.

In this report, we use general quantitative terms to represent our 

estimates of the number of experts who identified a specific accreditation 

issue. We determined these estimates by analyzing experts’ survey 

responses and the roundtable discussion. We used the following terms to 

present our estimates of experts who identified an issue: a “few”

represents 2 to 4 roundtable experts; “some” represents 5 to 8; “many”

represents 9 to 13; and “most” represents 14 or more.

To supplement the information we collected from our expert roundtable 

and stakeholder interviews, we analyzed selected school-level academic 

outcome data from Education and summarized it by accreditor type by 

linking schools with their accreditors using documentation obtained from 

Education (see appendix IV).11 Specifically, we analyzed a range of 

student outcome measures from multiple Education sources from 2012 to 

2015—the most recent years the data were available at the time of our 

review.12 These measures included:

• Graduation rate (as of August 2015): the percent of first-time full-time 

degree/certificate-seeking students who completed a program within 

150 percent of the program length.

 11Accreditor type in our analysis refers to the three general types of accreditors 

recognized by Education to assess academic quality—regional, national, and 

programmatic. Regional accreditors accredit mostly nonprofit and public schools, while 

national accreditors generally accredit for-profit schools. Programmatic accreditors 

generally accredit specific programs within a school, such as a school’s law program. 

However, some programmatic accreditors can also accredit free-standing professional or 

vocational schools (such as law schools or schools of massage therapy). Additionally, 

Education refers to some accreditors as “specialized” accreditors, such as those that 

accredit faith-based and religious schools. For the purposes of this report, we generally 

include specialized accreditors in our discussion of programmatic accreditors.

12We analyzed outcomes data from four datasets maintained by Education. Specifically, 

graduation rates and retention rates are from Education’s Integrated Postsecondary 

Education Data System. Graduation rates are as of August 2015, and retention rates are 

as of fall 2015. The three-year cohort default rates are from Education’s Cohort Default 

Rate Database for fiscal year 2013. Three-year repayment rates are from Education’s 

accreditor performance dashboard released in June 2017. Five-year repayment rates are 

from Education’s College Scorecard released in January 2017. Lastly, median earnings of 

undergraduates are from Education’s accreditor performance dashboard released in June 

2017.

Selected Student Outcome 

Characteristics
Appendix I: Objectives, Scope, and 

Methodology

Page 50 GAO-18-5 Views on Higher Education Accreditation

• Retention rate (as of Fall 2015): the percent of first-time 

degree/certificate-seeking students who enrolled in one fall and either 

successfully completed their program or re-enrolled in the next fall.

• Three-year cohort default rate (fiscal year 2013 cohort): the percent of 

borrowers in default 3 years after entering repayment status.

• Three-year repayment rate (2-year pooled: fiscal years 2013-14 and 

2014-15): the percent of undergraduate borrowers at a school who 

were not in default on their federal student loans and who had paid 

down at least $1 of the initial balance on their loans 3 years after 

entering repayment.13

• Five-year repayment rate (2-year pooled: fiscal years 2013-14 and 

2014-15): the percent of undergraduate borrowers at a school who 

were not in default on their federal student loans and who had paid 

down at least $1 of the initial balance on their loans 5 years after 

entering repayment.

• Median earnings of undergraduates (2-year pooled: calendar years 

2012 and 2013): the earnings of students who received federal 

student aid, and were working and not enrolled 10 years after 

enrollment.

We included in our analysis schools that participated in federal student 

aid programs authorized under Title IV of the Higher Education Act of 

1965, as amended, and that were accredited by a regional, national, or 

programmatic accreditor recognized by Education, according to 

Education’s June 2017 accreditor dashboard data file.

14 To assess the 

reliability of this data, we interviewed knowledgeable Education officials, 

reviewed relevant documentation about the data and systems, and 

electronically tested the data for missing data, outliers, and errors, as 

appropriate. As a result of these efforts, we found the data to be 

sufficiently reliable for the purposes of our review.

We conducted this performance audit from March 2016 to December 

2017 in accordance with generally accepted government auditing 

 13According to Education’s documentation, repayment rates are generally considered 

more sensitive than the cohort default rate, which measures the worst-case scenario for 

repayment outcomes and which can be manipulated through the use of allowable nonrepayment options like forbearances and deferments. 

14National Advisory Committee on Institutional Quality and Integrity (NACIQI), Recognized 

Institutional Accreditors: Federal Postsecondary Education and Student Aid Data (June 

20-22, 2017), accessed December 2017, https://sites.ed.gov/naciqi/archive-of-meetings/.
Appendix I: Objectives, Scope, and 

Methodology

Page 51 GAO-18-5 Views on Higher Education Accreditation

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Participants in GAO Expert 

Roundtable on Higher Education Accreditation

Page 52 GAO-18-5 Views on Higher Education Accreditation

Table 8: List of Expert Participants in GAO Higher Education Accreditation Roundtable Held September 29-30, 2016

Accreditors and their associations

1. Barbara Brittingham President, Commission on Institutions of Higher Education, New England 

Association of Schools and Colleges

2. Judith Eaton President, Council for Higher Education Accreditation 

3. Michale S. McComis Executive Director, Accrediting Commission of Career Schools and Colleges 

4. Joseph Vibert Executive Director, Association of Specialized and Professional Accreditors 

Association representing schools

5. Terry W. Hartle Senior Vice President, American Council on Education 

Association representing states

6. Julie Carnahan Vice President, State Higher Education Executive Officers Association 

Federal agency and other affiliates

7. Herman Bounds, Jr. Director, Accreditation Group, Office of Postsecondary Education, United 

States Department of Education

8. Susan Phillips Professor, University at Albany; Chair, National Advisory Committee on 

Institutional Quality and Integrity (formerly)a

9. Spiros Protopsaltis Deputy Assistant Secretary for Higher Education and Student Financial Aid, 

Office of Planning, Evaluation, and Policy Development, United States 

Department of Education (formerly)a

Researchers and subject matter experts

10. Peter T. Ewell President Emeritus, National Center for Higher Education Management 

Systems (formerly)a

11. Paul L. Gaston Trustees Professor, Kent State University (formerly)a

12. Kevin Kinser Professor and Department Head, Education Policy Studies, Penn State 

University 

13. Ralph Wolff Consultant, Ralph Wolff & Associates

Student representative 

14. Eileen Connor Director of Litigation, Project on Predatory Student Lending, Legal Services 

Center, Harvard Law School 

Policy institutes and other organizations 

15. Ben Miller Senior Director, Postsecondary Education, Center for American Progress 

16. Mary Clare Amselem Research Associate (formerly),a Domestic Policy Studies, The Heritage 

Foundation 

17. Terri Taylor Senior Policy & Legal Advisor, EducationCounsel (formerly)a

International subject matter expert

18. Ellen Hazelkorn Professor, Higher Education Authority, Ireland; Higher Education Policy 

Research Unit, Dublin Institute of Technology (formerly)a

Source: GAO. | GAO-18-5

Note: In addition to the experts listed, we invited an association representing career postsecondary 

schools primarily in the for-profit sector to participate in the expert roundtable. The association 

declined to participate in the expert roundtable and related pre- and post-roundtable surveys; 

however, two representatives participated in an interview. Similarly, we invited an organization 

Appendix II: Participants in GAO Expert 

Roundtable on Higher Education 

Accreditation
Appendix II: Participants in GAO Expert 

Roundtable on Higher Education Accreditation

Page 53 GAO-18-5 Views on Higher Education Accreditation

conducting projects related to higher education accreditation to participate in the expert roundtable. 

The organization was unable to participate in the roundtable; however, a representative participated 

in an interview and completed the team’s pre- and post-roundtable surveys.

a

At the time of GAO’s expert roundtable, the expert held the position identified in this table. After the 

roundtable, the expert’s position changed.
Appendix III: List of Research and Policy 

Papers GAO Reviewed

Page 54 GAO-18-5 Views on Higher Education Accreditation

To provide additional information on key issues related to accreditation of

postsecondary schools, we reviewed 52 research and policy papers 

identified through a formal search of the literature on accreditation 

published from January 2015 to June 2016, and recommendations 

provided by stakeholders we interviewed or experts who participated in 

our roundtable. See appendix I for more details about our literature 

review.

Alexander, Lamar. “Higher Education Accreditation Concepts and 

Proposals.” U.S. Senate Committee on Health, Education, Labor, and 

Pensions paper (2015).

Alphin Jr., Henry C. “Global Accreditation for a Knowledge-Oriented 

Community: Foundational Change Breeds Global Access to Educational 

and Economic Opportunity.” Handbook of Research on Transnational 

Higher Education, vol. 1-2 (2013).

American Council on Education. National Task Force on Institutional 

Accreditation. Assuring Academic Quality in the 21st Century: SelfRegulation in a New Era. 2012.

Bergeron, David. Time to Consider Alternatives: Options for Improving 

Quality Assurance in U.S. Higher Education. Center for American 

Progress presentation. August 2015.

Blanco Ramírez, Gerardo. “International Accreditation as Global Position 

Taking: An Empirical Exploration of U.S. Accreditation in Mexico.” Higher 

Education, vol. 69 (2015).

Blanco Ramírez, Gerardo. “Translating Quality in Higher Education: US 

Approaches to Accreditation of Institutions from Around the World.”

Assessment & Evaluation in Higher Education, vol. 40, no. 7 (2015).

Broad, Molly Corbett. Comments on Accreditation White Paper. American 

Council on Education letter. April 2015.

Bumphus, Walter G., and J. Noah Brown. Re: Higher Education 

Accreditation Concepts and Proposals. A letter from the American 

Association of Community Colleges and Association of Community 

Colleges Trustees. April 2015.

Appendix III: List of Research and Policy 

Papers GAO Reviewed
Appendix III: List of Research and Policy 

Papers GAO Reviewed

Page 55 GAO-18-5 Views on Higher Education Accreditation

Burke, Lindsey M., and Stuart M. Butler. Accreditation: Removing the 

Barrier to Higher Education Reform. No. 2728. The Heritage Foundation. 

September 2012.

Busby, Katie. “Co-Curricular Outcomes Assessment and Accreditation.”

New Directions for Institutional Research, no. 164 (2015).

Chen, Karen Hui-Jung, and Angela Yung-Chi Hou. “Adopting SelfAccreditation in Response to the Diversity of Higher Education: Quality 

Assurance in Taiwan and its Impact on Institutions.” Asia Pacific 

Education Review, vol. 17, issue 1 (March 2016).

Cheng, Nellie S. “A Comparison of Compliance and Aspirational 

Accreditation Models: Recounting a University’s Experience with both a 

Taiwanese and an American Accreditation Body.” Higher Education, vol. 

70, issue 6 (December 2015).

Christensen, Clayton M., Michael B. Horn, Louis Caldera, and Louis 

Soares. Disrupting College: How Disruptive Innovation Can Deliver 

Quality and Affordability to Postsecondary Education. Center for 

American Progress and Innosight Institute. February 2011.

Coleman, Arthur L., Teresa E. Taylor, and Bethany M. Little. New 

Directions in Regulatory Reform: Prospects for Reducing Regulatory 

Burden Through Risk-Informed Approaches in Federal Law Governing 

American Higher Education. EducationCounsel. December 2014.

Coleman, Arthur L., Teresa E. Taylor, Bethany M. Little, and Katherine E. 

Lipper. Getting our House in Order: Transforming the Federal Regulation 

of Higher Education as America Prepares for the Challenges of 

Tomorrow. EducationCounsel. March 2015.

Dickeson, Robert C. The Need for Accreditation Reform. Issue paper 5. 

The Secretary of Education’s Commission on the Future of Higher 

Education.

Dickeson, Robert C. Recalibrating the Accreditation-Federal Relationship. 

Council for Higher Education Accreditation. January 2009.

EducationCounsel. Outcomes-Focused, Differentiated Accreditation: A 

Framework for Policy and Practice Reform. April 2016.
Appendix III: List of Research and Policy 

Papers GAO Reviewed

Page 56 GAO-18-5 Views on Higher Education Accreditation

Entangled Solutions. Minimizing Conflict of Interest in Quality Assurance. 

August 2016.

Ewell, Peter T. Eleven Reform Proposals for Accreditation. National 

Center for Higher Education Management Systems. April 2015.

Ewell, Peter T. Accreditation and Student Learning Outcomes: A 

Proposed Point of Departure. Council for Higher Education Accreditation. 

September 2001.

Ewell, Peter T. Comments on Higher Education Accreditation: Concepts 

and Proposals.

Ewell, Peter T. Transforming Institutional Accreditation in U.S. Higher 

Education. National Center for Higher Education Management Systems. 

March 2015.

Gaston, Paul L. Higher Education Accreditation: How it’s Changing, Why 

it Must. Sterling, VA: Stylus Publishing, 2014.

Gaston, Paul L. The Challenge of Bologna: What United States Higher 

Education Has to Learn From Europe, and Why It Matters That We Learn 

It. Sterling, VA.: Stylus Publishing, 2010.

Gibbs, Graham. Dimensions of Quality. The Higher Education Academy. 

September 2010.

Harnisch, Thomas, Barmak Nassirian, Amber Saddler, and Art Coleman. 

Enhancing State Authorization: The Need for Action by States as 

Stewards of Higher Education Performance. Education Commission of 

the States. December 2016.

Hazelkorn, Ellen. What we Know and Don’t Know about Quality. A paper 

presented at the IA-HERO (Irish-American Higher Education Research 

Organization) meeting, organized by the Higher Education Authority 

(Ireland), Washington, D.C. April 2013.

Hegji, Alexandra. An Overview of Accreditation of Higher Education in the 

United States. Congressional Research Service. February 2016.

Horn, Michael B., and Andrew P. Kelly. Moving Beyond College: 

Rethinking Higher Education for an Unbundled World. American 

Enterprise Institute. August 2015.
Appendix III: List of Research and Policy 

Papers GAO Reviewed

Page 57 GAO-18-5 Views on Higher Education Accreditation

Jankowski, Natasha A. Unpacking Relationships: Instruction and Student 

Outcomes. American Council on Education. 2016.

Kelly, Andrew P., and Kevin James. Untapped Potential: Making the 

Higher Education Market Work for Students and Taxpayers. American 

Enterprise Institute. October 2014.

Kelly, Andrew P., Kevin J. James, and Rooney Columbus. Inputs, 

Outcomes, Quality Assurance: A Closer Look at State Oversight of Higher 

Education. American Enterprise Institute. August 2015.

Lang, Daniel W. “Self-Regulation with Rules: Lessons Learned from a 

New Quality Assurance Process for Ontario.” Quality Assurance in 

Education, vol. 23, no. 3 (2015).

McPherson, Peter, and Muriel A. Howard. Comments and 

Recommendations for Consideration on the Paper “Higher Education 

Accreditation Concepts and Proposals.” A letter from the Association of 

Public and Land-grant Universities and American Association of State 

Colleges and Universities. April 2015.

Miller, Ben, David Bergeron, and Carmel Martin. A Quality Alternative: A 

New Vision for Higher Education Accreditation. Center for American 

Progress. October 2016.

Nassirian, Barmak. Statement before the National Advisory Committee on 

Institutional Quality and Integrity. American Association of Collegiate 

Registrars and Admissions Officers. February 2011.

Park, Yoon Soo, Fred A. Zar, John J. Norcini, and Ara Tekian. 

“Competency Evaluations in the Next Accreditation System: Contributing 

to Guidelines and Implications.” Teaching and Learning in Medicine, vol. 

28, no. 2 (2016).

Parker, Craig W., and Margaret L. O’Donnell. Some Observations on the 

Federal Regulation of Higher Education. Issue paper 15. The Secretary of 

Education’s Commission on the Future of Higher Education. April 2006.

Reyna, Ryan. Complete to Compete: Common College Completion 

Metrics. National Governors Association. June 2010.

Schindler, Laura, Sarah Puls-Elvidge, Heather Welzant, and Linda 

Crawford. “Definitions of Quality in Higher Education: A Synthesis of the 
Appendix III: List of Research and Policy 

Papers GAO Reviewed

Page 58 GAO-18-5 Views on Higher Education Accreditation

Literature.” Higher Learning Research Communications, vol. 5, no. 3 

(2015).

Schoepp, Kevin, Maurice Danaher, and Leon Jololian. “Effective 

Alignment of Disciplinary and Institutional Accreditation and Assessment: 

A UAE Computing Case Study.” Advances in Engineering Education in 

the Middle East and North Africa, chap. 14 (2016).

Schomaker, Rahel. “Accreditation and Quality Assurance in the Egyptian 

Higher Education System.” Quality Assurance in Education, vol. 23, no. 2 

(2015).

Schray, Vickie. Assuring Quality in Higher Education: Key Issues and 

Questions for Changing Accreditation in the United States. Issue paper 4. 

The Secretary of Education’s Commission on the Future of Higher 

Education.

Schray, Vickie. Assuring Quality in Higher Education: Recommendations 

for Improving Accreditation. Issue paper 14. The Secretary of Education’s 

Commission on the Future of Higher Education.

Shireman, Robert. Perils in the Provision of Trust Goods: Consumer 

Protection and the Public Interest in Higher Education. Center for 

American Progress. May 2014.

Shireman, Robert. The Real Value of What Students Do in College. The 

Century Foundation. February 2016.

Taylor, Teresa E., Arthur L. Coleman, Bethany M. Little, and Amber N. 

Saddler. Getting Our House in Order: Clarifying the Role of the States in 

Higher Education Quality Assurance. EducationCounsel. September 

2016.

Tyszko, Jason A., and Robert G. Sheets. Changing the Debate on Quality 

Assurance in Higher Education: The Case for Employer Leadership and a 

Roadmap for Change. U.S. Chamber of Commerce Foundation. 2016.

U.S. Department of Education. A Test of Leadership: Charting the Future 

of U.S. Higher Education. The Secretary of Education’s Commission on 

the Future of Higher Education. September 2006.
Appendix III: List of Research and Policy 

Papers GAO Reviewed

Page 59 GAO-18-5 Views on Higher Education Accreditation

West, Charlotte. Leveraging Accreditation and Quality Assurance in 

International Higher Education. NAFSA Association of International 

Educators. 2013.

Yung-Chi Hou (Angela), Martin Ince, Sandy Tsai, Wayne Wang, Vicky 

Hung, Chung Lin Jiang, and Karen Hui-Jung Chen. “Quality Assurance of 

Joint Degree Programs from the Perspective of Quality Assurance 

Agencies: Experience in East Asia.” Higher Education Research & 

Development, vol. 3, no. 35 (2016).
Appendix IV: Student Outcomes by Accreditor 

Type

Page 60 GAO-18-5 Views on Higher Education Accreditation

Figure 6 below presents school-level student outcomes, by accreditor 

type. To assess the student outcomes, we analyzed selected school-level 

student outcome data from the Department of Education on 

postsecondary schools that participated in federal student aid programs 

authorized under Title IV of the Higher Education Act of 1965, as 

amended (Higher Education Act), and that were accredited by a regional, 

national, or programmatic accreditor recognized by Education as of June 

2017.1 See appendix I for more details on our methodology.

 1

Education also recognizes certain state agencies as accreditors. However, for the 

purposes of this report, we focus on regional, national, and programmatic accreditors and 

do not include state agencies in this figure. Additionally, Education refers to some 

accreditors as “specialized” accreditors, such as those that accredit faith-based and 

religious schools. For the purposes of this report, we generally include specialized 

accreditors in our discussion of programmatic accreditors.

Appendix IV: Student Outcomes by 

Accreditor Type
Appendix IV: Student Outcomes by Accreditor 

Type

Page 61 GAO-18-5 Views on Higher Education Accreditation

Figure 6: School-Level Student Outcomes for Regional, National, and Programmatic Accreditors’ Member Postsecondary 

Schools

Note: The figure includes regional, national, and programmatic accreditors recognized by the 

Department of Education (Education) as reliable authorities on assessing the academic quality of 

schools as of June 2017. The Accrediting Council for Independent Colleges and Schools is included 

in Education’s June 2017 data as a national accreditor. In September 2016, Education withdrew its 

recognition of this accreditor, and an appeal of Education’s decision is currently pending in federal 

court. Education refers to some accreditors as “specialized” accreditors, such as those that accredit 

faith-based and religious schools. GAO included these specialized accreditors in the programmatic 

accreditor category in the figure. Also, Education recognizes certain state agencies as accreditors; 

however, these agencies are not included in the figure.

a

The 3-year cohort default rate indicates the percent of borrowers in default 3 years after entering 

repayment status. Three-year cohort default rates are from the Education’s Cohort Default Rate 

Database for fiscal year 2013.
Appendix IV: Student Outcomes by Accreditor 

Type

Page 62 GAO-18-5 Views on Higher Education Accreditation

b

The graduation rate indicates the percent of first-time full-time degree/certificate-seeking students 

who completed a program within 150 percent of the program length. Graduation rates are from 

Education’s Integrated Postsecondary Education Data System as of August 2015.

c

The 3-year repayment rate reflects the percent of undergraduate borrowers at a school who were not 

in default on their federal student loans and who had paid down at least $1 of the initial balance on 

their loans 3 years after entering repayment. Three-year repayment rates are from Education’s 

accreditor performance dashboard released in June 2017.

d

The retention rate is the percent of first-time degree/certificate-seeking students who enrolled in one 

fall and either successfully completed their program or re-enrolled in the next fall. Retention rates are 

from Education’s Integrated Postsecondary Education Data System as of fall 2015.

e

The 5-year repayment rate reflects the percent of undergraduate borrowers at a school who were not 

in default on their federal student loans and who had paid down at least $1 of the initial balance on 

their loans 5 years after entering repayment. Five-year repayment rates are from Education’s College 

Scorecard released in January 2017.

f

Median earnings indicate the earnings of students who received federal student aid authorized under 

Title IV of the Higher Education Act, and were working and not enrolled 10 years after enrollment. 

Median earnings are from Education’s accreditor performance dashboard released in June 2017 and 

were calculated for each school by linking administrative data maintained by Education on students 

receiving federal student aid with tax records maintained by the Department of the Treasury. Earnings 

are defined as the sum of wages and deferred compensation from all W-2 forms received from 

employers for each individual, as well as self-employment earnings reported by individuals to the 

Internal Revenue Service.
Appendix V: Other Potential Approaches 

Discussed at GAO’s Expert Roundtable

Page 63 GAO-18-5 Views on Higher Education Accreditation

Tables 9 and 10 present two more approaches identified by roundtable 

experts for improving the current accreditation system for postsecondary 

schools and programs in addition to those discussed in our report. These 

approaches are (1) re-examining requirements for different types of 

accreditors, and (2) developing a common accreditation language. 

Specifically, a few experts suggested re-examining the requirements for 

accreditors who approve schools and those who approve programs as an 

approach that could improve the efficiency of Education’s oversight of 

accreditors. Additionally, a few experts identified developing a common 

accreditation language as an approach that could help accreditors use 

more consistent terminology to define the various actions they may take. 

While roundtable experts identified these approaches as possible 

improvements to the current accreditation system, experts generally did 

not discuss these approaches as ways to directly address broader 

challenges related to oversight of academic quality. Additionally, a few 

roundtable experts said these two approaches may be a lower priority for 

improving oversight of academic quality. The level of specificity in 

describing each approach varied, with some roundtable experts providing 

detailed information about how the approach would work and others 

providing more general descriptions.

Appendix V: Other Potential Approaches 

Discussed at GAO’s Expert Roundtable
Appendix V: Other Potential Approaches 

Discussed at GAO’s Expert Roundtable

Page 64 GAO-18-5 Views on Higher Education Accreditation

Table 9: Summary of Expert Views on Re-examining Requirements for Different Types of Accreditors 

Description of potential 

approach

Potential advantages 

experts identified

Potential disadvantages

experts identified

Re-examine and modify, as 

appropriate, statutory and 

regulatory requirements for 

recognized national, 

regional, and programmatic 

accreditors to account for 

the different types of 

reviews conducted at the 

school and program level.a

• Re-examining distinctions between accreditors 

who approve programs and those that approve 

schools would allow each type of accreditor to 

focus on where they will have the most impact 

and ability to add value.

• May allow the Department of Education 

(Education) to better focus its time and 

oversight efforts on institutional accreditors 

that make decisions that can affect schools’ 

eligibility for federal student aid as opposed to 

those programmatic accreditors who accredit 

programs within schools.b

• Accreditors could use different outcomes and 

requirements that better align with the purpose 

and mission of the schools and programs they 

accredit.

• Help educate and remind oversight bodies, the 

public, and policy makers about the 

distinctions that exist between different

accreditors.

• Does not take into account accreditors who 

review both schools and programs. Meeting 

two sets of requirements may pose challenges 

for some accreditors, particularly small 

accreditors.

• Could be used to weaken important 

requirements and potentially excuse low 

school or program performance.

• A programmatic accreditor might need to ask 

some of the same questions a national or 

regional accreditor would ask about a school, 

such as questions about financial 

sustainability.

• May lead to charges of inequitable treatment 

among different types of accreditors.

• Because it may require statutory or regulatory 

changes, it may be time consuming and 

difficult to implement. An additional set of 

standards may also be needed to 

accommodate different types of schools.

Source: GAO analysis of information from GAO expert roundtable and survey responses, and Education’s documentation. | GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from the 

expert roundtable and survey responses, and Education’s documentation. It is not intended to 

represent the views of GAO or the entire expert roundtable, or suggest consensus. Neither GAO nor 

the roundtable participants as a whole recommend or endorse the adoption of any of the specific 

approaches selected for discussion.

a

National and regional accreditors (also referred to as institutional accreditors) are generally 

responsible for accrediting schools, while programmatic accreditors are generally responsible for 

accrediting specific programs within a school, such as a school’s nursing or law program. Regional 

accreditors accredit mostly nonprofit and public schools, while national accreditors generally accredit 

for-profit schools. Some programmatic accreditors can also accredit schools if recognized by 

Education to do so. There are currently some differences in the recognition requirements for 

accrediting agencies that accredit schools compared to those that accredit programs, but this 

approach would further streamline and delineate these differences, especially for programmatic 

accreditors, according to one roundtable expert.

b

National and regional accreditors are recognized by Education to accredit schools for purposes of 

participation in federal student aid programs under Title IV of the Higher Education Act of 1965, as 

amended. Programmatic accreditors generally accredit specific programs within schools, such as a 

school’s nursing program. However, Education recognizes some programmatic accreditors to accredit 

schools for Tittle IV eligibility purposes, including free-standing professional or vocational schools 

(such as law schools or schools of massage therapy), and certain educational programs in noneducational settings, such as hospitals.
Appendix V: Other Potential Approaches 

Discussed at GAO’s Expert Roundtable

Page 65 GAO-18-5 Views on Higher Education Accreditation

Table 10: Summary of Expert Views on Developing a Common Accreditation Language 

Description of potential 

approach

Potential advantages 

experts identified

Potential disadvantages 

experts identified

Develop a common 

accreditation language to 

ensure terms for the various 

actions accreditors can take 

against schools are defined 

the same way.a

• Reduce confusion by increasing consistency and 

standardizing terms and definitions across 

accreditors. May also be easily implemented and is 

underway among some accreditors.b

• Potentially improve the quality of accreditation 

information to be provided to the public. Knowing 

that accreditors follow the same rules and use 

similar language may help consumers better 

understand accreditation.

• May be difficult to implement as 

accreditors may encounter challenges 

reaching agreement on common 

definitions and terms.

• Common language may not ensure 

that accreditors’ actions are 

consistently implemented and aligned 

with the terminology. 

Source: GAO analysis of information from GAO expert roundtable and survey responses, and other documentation. | GAO-18-5

Note: The information in this table generally summarizes GAO’s analysis of information from the 

expert roundtable and survey responses, and other documentation. It is not intended to represent the 

views of GAO or the entire expert roundtable, or suggest consensus. Neither GAO nor the roundtable 

participants as a whole recommend or endorse the adoption of any of the specific approaches 

selected for discussion.

a

Accreditors can take a range of actions under the current accreditation system and these actions 

may have different definitions, depending on the accreditor. For example, when an accreditor issues 

a “show-cause” order it may mean that a school must demonstrate to the accreditor why its 

accreditation should not be withdrawn, which would end the school’s eligibility for federal student aid. 

For other accreditors, it may mean that an accreditor will impose a sanction if the school cannot 

demonstrate why a sanction should not be imposed.

b

This approach could potentially focus on developing a common set of terms for sanctions with 

agreed-upon definitions to be used by accreditors, according to one round table expert. In April 2014, 

the Council of Regional Accrediting Commissions—a council representing seven regional accrediting 

agencies who generally oversee nonprofit and public schools—established a framework with common 

definitions to identify actions regional accreditors can take, such as issuing warnings when a school 

does not meet one or more standards for accreditation. The framework does not apply to actions 

taken by national accreditors, who generally oversee for-profit schools, or programmatic accreditors, 

who generally oversee specific programs within schools, such as a school’s nursing or law program.
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 66 GAO-18-5 Views on Higher Education Accreditation

Tables 11 through 14 present four potential approaches we identified in 

the literature—three of which were developed by roundtable experts—to 

change the current structure of the accreditation system.1 These 

approaches, which are discussed in the report, include establishing (1) an 

authorizer that would assess innovative program providers’ eligibility for 

federal student aid, (2) third-party entities that would set standards and 

thresholds based on outcome measures to assess academic quality at 

the program level, (3) a higher education quality assurance commission 

that would coordinate and align the activities of accreditors who assess 

schools’ academic quality, and (4) a congressionally chartered 

accreditation governance entity that would assume Education’s current 

role and responsibilities in the accreditation process. The level of 

specificity in describing each approach varied, with some experts 

providing detailed information about how the approach would work and 

others providing more general descriptions.

 1

These approaches do not discuss changing the role of states in higher education 

oversight. The information presented in the tables generally summarizes our analysis of 

approaches identified in the literature—three of which were developed by roundtable 

experts. GAO is not recommending or endorsing the views presented or the adoption of 

any of the approaches identified by experts.

Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 67 GAO-18-5 Views on Higher Education Accreditation

Table 11: Establishing an Independent Authorizer to Approve Innovative Educational Program Providers

Approach 

Description

Potential 

Improvements

Approach Features

Will new entity 

determine who 

will be 

recognized to 

assess 

schools’ 

academic 

quality?

Will new entity 

create 

accreditation 

standards for 

schools and/or 

programs, and 

assess standards’ 

effectiveness?

Will new entity 

oversee peer 

review and 

monitor 

schools’ 

improvement?

Will new 

entity enforce 

compliance 

with 

standards? 

What role will 

the new entity 

play in making 

accreditation 

decisions that 

may affect a 

school’s 

federal 

student aid 

eligibility?

How will the 

new entity 

be funded to 

support its 

operations?

Establish an 

independent 

entity—called an 

“independent 

authorizer”—to 

help determine 

the federal 

student aid 

eligibility for 

innovative 

educational 

program 

providers, and 

not for traditional 

educational 

programs.a The 

independent 

authorizer would 

be approved by 

the Department 

of Education 

(Education). 

However, it 

would be 

independent of 

Education and 

accreditors, and 

would have its 

own staff to 

support 

assessment 

activities.b

Would expand 

the range of 

higher education 

programs for 

students 

supported by 

federal student

aid.

Would increase 

students’ access 

to 

postsecondary 

programs and 

federal student 

aid.

No. Education 

would 

maintain 

responsibility 

for recognizing 

accrediting 

agencies. The 

independent 

authorizer will 

be recognized 

by Education.c

Yes, in part. For 

innovative 

program providers 

only, the 

independent 

authorizer would 

adopt standards 

set by another 

independent 

entity—a nonprofit 

organization that 

would develop 

and maintain 

standards for 

student 

outcomes.d 

However, the 

authorizer would 

set thresholds for 

the standards that 

were appropriate 

for the programs it 

reviewed, with 

input from 

business and 

industry 

representatives.e

Education would 

assess the 

effectiveness of 

the standards.

Yes, in part.

The 

independent 

authorizer 

would review 

innovative 

program 

providers to 

help determine 

their federal 

student aid 

eligibility. 

Existing 

accreditors 

would oversee 

peer review of 

traditional 

programs as a 

means of 

improving 

academic 

quality. 

Yes. The 

independent 

authorizer 

would 

enforce 

compliance 

with 

standards for 

the 

innovative 

program 

providers that 

it oversees. 

Accreditors 

would 

enforce 

compliance 

for all other 

traditional 

schools and 

programs.

The 

independent 

authorizer 

would make 

decisions that 

help to 

determine if 

the innovative 

programs it 

reviews are of 

a quality to be 

eligible for 

federal 

student aid 

and then 

petition 

Education for 

approval.f

Federal 

funding

Source: Michael B. Horn and Andrew P. Kelly, Moving Beyond College: Rethinking Higher Education Regulation for An Unbundled World, (August, 2015); David Bergeron and Steven Klinsky, “Debt-free 

Degrees,” Inside Higher Ed (October 28, 2013); and GAO’s analysis of Education documentation, information from interviews with stakeholders, and other documentation. | GAO-18-5

Note: The information presented in this table generally summarizes GAO’s analysis of literature 

recommended by experts who participated in GAO’s roundtable or interviews. GAO is not 

recommending or endorsing the views presented or the adoption of any of the approaches identified.

a

Currently, certain innovative programs, such as coding boot camps and massive open online 

courses, generally are not eligible to receive federal student aid. Coding boot camps are vocational 

training programs—usually 8 to 12 weeks—offered by private companies that teach students 

computer programming at less cost than a college degree in computer science. Massive open online 
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 68 GAO-18-5 Views on Higher Education Accreditation

courses are courses offered over the internet that are usually free, award no credit, and enroll large 

numbers of students. While tuition for some of these courses might be low or no cost, low income 

students may benefit from federal student aid that can be used to purchase resources such as 

laptops and high speed internet connections to participate in these courses.

b

The authors cited the Modern States Accrediting Agency as another example of the independent 

authorizer concept from the literature. Under this approach, the Modern States Accrediting Agency 

would be a new entity that would be recognized by Education to accredit individual innovative courses 

and be operated by a voluntary association of philanthropic and nongovernmental organizations. The 

agency would be funded by contributions from association members that would include employers 

who benefit from having assurance that graduates have the knowledge, skills, and abilities necessary 

for employment. For the Modern States Accrediting Agency approach, see David Bergeron and 

Steven Klinsky, Debt-free Degrees.

c

Currently, to be eligible to participate in federal student aid programs under Title IV of the Higher 

Education Act of 1965, as amended (Higher Education Act), schools must be accredited by an 

agency recognized by Education. The Higher Education Act and Education’s regulations require 

accreditors to meet certain criteria and have certain operating procedures in place to be “recognized”

by Education as reliable authorities on assessing academic quality.

d

Currently, the Higher Education Act identifies specific areas—such as student achievement and 

curricula—in which recognized accreditors must have standards and accreditors are required to 

assess member schools’ compliance with these standards to ensure the quality of education offered. 

However, under this approach, an entity other than the independent authorizer would maintain a set 

of accreditation standards based on student outcomes, such as program completion, placement, 

student satisfaction, and post program earnings. Auditors would verify that outcomes reported by the 

schools are correct.

e

A threshold would specify the minimum level at which a school would be expected to perform. For 

example, if a standard was set concerning graduation rates, the threshold might specify that a school 

should achieve a 60 percent graduation rate annually.

f

Currently, accreditation is one of the requirements that helps determine schools’ federal student aid 

eligibility, but not the sole factor. To participate in federal student aid programs authorized under Title 

IV of the Higher Education Act, schools must meet various other requirements. For example, schools 

must be authorized to provide postsecondary education by the state in which they are located and be 

certified by Education as meeting certain administrative capability and financial responsibility 

requirements.
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 69 GAO-18-5 Views on Higher Education Accreditation

Table 12: Establishing Third-Party Entities to Set Standards and Thresholds, Based on Student Outcomes

Approach 

Description

Potential 

Improvements

Approach Features

Will new 

entities 

determine 

who will be 

recognized to 

assess 

school 

academic 

quality?

Will new 

entities create 

accreditation 

standards for 

schools and/or 

programs, and 

assess 

standards’ 

effectiveness?

Will new 

entities 

oversee peer 

review and 

monitor 

schools’ 

improvement? 

Will new 

entities 

enforce 

compliance 

with 

standards?

What role will 

the new 

entities play in 

making 

accreditation 

decisions that 

may affect a 

school’s 

federal student 

aid eligibility?

How will the 

new entities 

be funded to 

support their 

operations? 

Establish thirdparty entities that 

set standards 

and thresholds 

for assessing 

academic quality 

at the program 

level. Programs 

could choose to 

participate in this 

new system or be 

reviewed by the 

current system.a

Standard setters 

could include 

organizations 

such as 

programmatic 

accreditors, or 

professional 

academic 

membership 

organizations.

Would relieve 

the tension in 

accreditors’ dual 

role—helping 

schools improve 

and making 

decisions that 

can affect 

programs’ 

access to 

federal student 

aid.b

Would reduce 

potential conflict 

of interest 

concerns 

regarding fees 

paid to 

accreditors by 

schools for 

accreditation 

services.

No. The 

Department 

of Education 

(Education) 

would 

continue to 

recognize 

accreditors to 

assess 

schools’ 

academic 

quality.c

Yes, in part. 

The third-party 

entities would 

set standards 

and identify 

both the 

outcome 

measures and 

the threshold 

levels to be 

used to assess 

academic 

quality.d

Education 

would assess 

whether or not 

the standards 

set by the thirdparty entities 

were identifying 

poor performing 

programs.e

No. If a 

program 

chooses to be 

reviewed under 

this system 

and the set of 

standards set 

by the thirdparty entities, 

Education, 

rather than 

peer reviewers, 

would review 

programs. 

Education 

would review 

programs’ 

performance 

data, including 

those not 

collected by 

Education such 

as job 

placement 

rates. Such 

data should be 

audited before 

submission to 

Education.

No. Education 

would have 

responsibility 

for enforcing 

compliance 

with 

standards. If 

Education 

determined 

that the thirdparty entities’ 

standards 

have not been 

met, 

Education 

would take 

action once it 

verifies that 

an 

educational 

provider fails 

to meet 

standards.

f

If a program 

chooses to be 

reviewed 

under this 

system and 

the set of 

standards set 

by the thirdparty entities, 

Education, 

rather than 

peer 

reviewers, 

would review 

programs. The 

third-party 

would 

contribute to a 

decision about 

a program’s 

accreditation 

only through 

the standards 

that it set. 

Education 

would make 

the final 

determination 

for programs’ 

federal student 

aid eligibility.g 

The thirdparty entities 

would receive 

federal 

funding and 

could receive 

funds from 

other 

sources. For 

example, if 

the third-party 

entity was a 

professional 

society, the 

entity could 

receive 

membership 

dues. It would 

not collect 

fees from the 

programs that 

are reviewed 

against its 

standards.

Source: Center for American Progress, A Quality Alternative: A New Vision for Higher Education Accreditation (October 2016); and GAO’s analysis of Education documentation, information from expert 

roundtable discussion, literature, and other documentation. | GAO-18-5

Note: The information presented in this table generally summarizes GAO’s analysis of literature 

recommended by experts who participated in GAO’s roundtable or interviews. GAO is not 

recommending or endorsing the views presented or the adoption of any of the approaches identified.

a

Currently, to be eligible to participate in federal student aid programs under Title IV of the Higher 

Education Act, of 1965 as amended (Higher Education Act), schools must be accredited by an 

agency recognized by Education. The Higher Education Act and Education’s regulations require 

accreditors to meet certain criteria and have certain operating procedures in place to be “recognized”

by Education as reliable authorities on assessing academic quality. Recognized accreditors are 
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 70 GAO-18-5 Views on Higher Education Accreditation

responsible for assessing schools to determine if they meet standards to become one of their 

member schools. The Higher Education Act identifies specific areas—such as student achievement 

and curricula—in which recognized accreditors must have standards and accreditors are required to 

assess member schools’ compliance with these standards to ensure the quality of education offered.

b

Some roundtable experts and papers GAO reviewed said the tension in accreditors’ dual role—

helping schools improve their performance and serving as gatekeepers for federal student aid—may 

make some accreditors hesitant to take action, such as imposing sanctions that could affect schools’

access to federal student aid.

c

Currently, recognized accreditors are responsible for assessing schools to determine if they meet 

standards to become one of their member schools. Accreditors generally re-evaluate their member 

schools at least every 10 years (depending on the accreditor and the school) using a process that 

involves volunteer peer reviews, generally with evaluators from other member schools, selected by 

the accreditor.

d

Student outcomes—measures that can range from graduation rates to assessments of what 

students learn from their education—may reflect academic quality, according to our literature review, 

some roundtable experts, and our prior work.

e

For example, Education would evaluate the performance of all educational providers being approved 

for federal student aid through a particular third-party entity and see how that entity’s results 

compared to the results of other third-party entities. This would include determining if a set of 

standards allow too many providers with low repayment rates, earnings, completion rates, or other 

key indicators.

f

Currently, Education may take enforcement action against a school for failure to meet any 

requirement of the Higher Education Act or its regulations, including requiring a school to submit 

additional documentation, such as detailed student information, before receiving federal student aid 

funds.

g

Currently, accreditation is one of the requirements that helps determine schools’ federal student aid 

eligibility, but not the sole factor. To participate in federal student aid programs authorized under Title 

IV of the Higher Education Act, schools must meet various other requirements. For example, in 

addition to being accredited, schools must be authorized to provide postsecondary education by the 

state in which they are located and certified by Education as meeting certain administrative capability 

and financial responsibility requirements. If schools are not accredited, they are not eligible to access 

federal student aid.
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 71 GAO-18-5 Views on Higher Education Accreditation

Table 13: Establishing a Higher Education Quality Assurance Commission to Coordinate with Accrediting Agencies

Approach 

Description

Potential 

Improvements

Approach Features

Will new entity 

determine who 

will be 

recognized to 

assess 

schools’ 

academic 

quality? 

Will new entity 

create 

accreditation 

standards for 

schools and/or 

programs, and 

assess 

standards’ 

effectiveness?

Will new entity 

oversee peer 

review and 

monitor 

schools’ 

improvement? 

Will new 

entity 

enforce 

compliance 

with 

standards?

What role will 

the new entity 

play in making 

accreditation 

decisions that 

may affect a 

school’s 

federal 

student aid 

eligibility?

How will the 

new entity be 

funded to 

support its 

operations?

Establish a Higher 

Education Quality 

Assurance 

Commission 

(commission), 

with its own staff 

that coordinates 

and aligns 

activities of 

accreditors who 

assess schools’ 

academic quality. 

The commission 

would establish 

requirements that 

accreditors use 

common terms for 

accreditation 

actions, and align 

school 

performance 

measures.a

Would allow 

accreditors to 

(1) develop a 

response to 

some of the 

criticism from 

policy makers 

and the public, 

share 

accreditation 

expenses and 

develop new 

accreditation 

approaches, and 

(2) develop 

consistent terms 

for accreditation 

actions to 

assess schools.

Yes. The 

commission 

would replace 

the National 

Advisory 

Committee on 

Institutional 

Quality and 

Integrity 

(NACIQI) and 

Department of 

Education 

(Education) 

staff in the 

accreditor 

recognition 

process.

b

Commission 

staff would 

identify criteria 

for recognition 

and 

recommend 

recognition 

decisions.c

Yes. The 

commission 

would set 

standards while 

allowing 

accreditors to 

tailor their 

reviews to the 

types of schools 

and programs 

they accredit.d

The 

commission

also would 

assess 

accreditors’ 

effectiveness by 

determining the 

proportion of 

schools 

accredited by a 

given accreditor 

that achieve 

designated 

thresholds for 

student 

outcomes such 

as graduation 

or completion 

rates, or 

licensure exam 

pass rates.

No. Accreditors 

would continue 

to oversee peer 

review of 

schools and 

monitor 

schools’ 

improvement.e

No. 

Accreditors 

would 

continue to 

enforce 

standards by 

issuing 

sanctions or 

taking other 

actions when 

schools do 

not meet 

their 

standards.

The current 

accreditor role

in making 

accreditation 

decisions that 

could affect 

schools’ 

access to 

federal 

student aid 

funds via the 

accreditation 

process would 

not change.f

Education 

would 

continue to 

carry out the 

department’s 

current 

oversight 

functions that 

do not involve 

recognition.

Federal 

funding

Source: Peter Ewell, Transforming Institutional Accreditation in U.S. Higher Education (Boulder, CO: March 2015); and GAO’s analysis of Education documentation, information from interviews with a 

roundtable expert, and other documentation. | GAO-18-5

Note: The information presented in this table generally summarizes GAO’s analysis of literature 

recommended by experts who participated in GAO’s roundtable or interviews. GAO is not 

recommending or endorsing the views presented or the adoption of any of the approaches identified.

a

Currently, accreditors use different language and terms to describe similar accreditation-related 

actions and decisions.
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 72 GAO-18-5 Views on Higher Education Accreditation

b

NACIQI, a committee of 18 members appointed by Congress and Education, advises Education on 

matters related to accreditation.

c

Currently, to be eligible to participate in federal student aid programs under Title IV of the Higher 

Education Act of 1965, as amended (Higher Education Act), schools must be accredited by an 

agency recognized by Education. The Higher Education Act and Education’s regulations require 

accreditors to meet certain criteria and have certain operating procedures in place to be “recognized”

by Education as reliable authorities on assessing educational quality.

d

Currently, the Higher Education Act identifies specific areas—such as student achievement and 

curricula—in which recognized accreditors must have standards and accreditors are required to 

assess member schools’ compliance with these standards to ensure the quality of education offered.

e

Accreditors generally re-evaluate their member schools at least every 10 years (depending on the 

accreditor and the school) using a peer review process that involves volunteer peer evaluators, 

generally from other member schools, selected by the accreditor.

f

Currently, accreditation is one of the requirements that helps determine schools’ federal student aid 

eligibility, but not the sole factor. To participate in federal student aid programs authorized under Title 

IV of the Higher Education Act, schools must meet various other requirements. For example, in 

addition to being accredited, schools must be authorized to provide postsecondary education by the 

state in which they are located and certified by Education as meeting certain administrative capability 

and financial responsibility requirements. If schools are not accredited, they are not eligible to access 

federal student aid.
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 73 GAO-18-5 Views on Higher Education Accreditation

Table 14: Establishing a Congressionally Chartered Accreditation Governance Entity

Approach 

Description

Potential 

Improvements

Approach Features

Will new entity 

determine who 

will be 

recognized to 

assess schools’ 

academic 

quality? 

Will new entity 

create 

accreditation 

standards for 

schools and/or 

programs, and 

assess 

standards’ 

effectiveness? 

Will new entity

oversee peer 

review and 

monitor 

schools’ 

improvement? 

Will new 

entity enforce 

compliance 

with 

standards?

What role will 

the new entity 

play in making 

accreditation 

decisions that 

may affect a 

school’s 

federal 

student aid 

eligibility?

How will the 

new entity 

be funded to 

support its 

operations?

Establish a 

congressionally 

chartered entity 

that would 

assume the 

Department of 

Education’s 

(Education) 

current role and 

responsibilities in 

the accreditation 

process. 

Specifically, the 

entity would 

assume 

Education’s role 

in recognizing 

accrediting 

agencies and 

play a major role 

in communicating 

accreditation 

information to the 

public.a

Would increase 

transparency 

and clarify 

information 

communicated 

to the public.

Would help 

elicit public trust 

in accreditation 

by 

communicating 

accreditation 

decisions to the 

public.

Yes. The entity 

would have 

responsibility 

for recognizing 

accreditors, 

including 

assuming the 

responsibilities 

of the 

independent 

National 

Advisory 

Committee on 

Institutional 

Quality and 

Integrity 

(NACIQI) and 

Education.b 

Yes. The entity 

would create 

and maintain 

standards for 

assessing 

schools’ 

performance.c

The entity 

would 

determine if 

procedures for 

assessing the 

standards’ 

effectiveness 

are needed.

Yes. The new 

entity would 

determine 

whether a peer 

review process 

would be used 

to assess 

schools and 

monitor 

schools’ 

improvement.d

Yes. The 

entity would 

have 

responsibility 

for 

enforcement 

actions.e

If the entity 

determines 

that a peer 

review 

process would 

be used to 

assess and 

monitor 

schools’ 

improvement, 

as they do 

currently, 

accreditors 

would make 

decisions that 

may affect 

schools’ 

student aid 

eligibility.f 

Funding 

would be 

determined 

by the 

legislation 

creating the 

entity.

Source: Robert C. Dickeson, Recalibrating the Accreditation-Federal Relationship (Washington, DC: Council for Higher Education Accreditation, Jan. 27, 2009); and GAO’s analysis of Education 

documentation, information from interviews with stakeholders, roundtable discussion, literature, and other documentation. | GAO-18-5

Note: The information presented in this table generally summarizes GAO’s analysis of literature 

recommended by a higher education stakeholder. GAO is not recommending or endorsing the views 

presented or the adoption of any of the approaches identified.

a

Currently, to be eligible to participate in federal student aid programs, under Title IV of the Higher 

Education Act of 1965, as amended (Higher Education Act), schools must be accredited by an 

agency recognized by Education. The Higher Education Act and Education’s regulations require 

accreditors to meet certain criteria and have certain operating procedures in place to be “recognized”

by Education as reliable authorities on assessing academic quality.

b

NACIQI is a committee of 18 members appointed by Congress and Education that advises 

Education on matters related to accreditation.

c

Currently, the Higher Education Act identifies specific areas—such as student achievement and 

curricula—in which recognized accreditors must have standards and accreditors are required to 

assess member schools’ compliance with these standards to ensure the quality of education offered.
Appendix VI: Summary of Approaches for 

Changing the Structure of the Accreditation 

System

Page 74 GAO-18-5 Views on Higher Education Accreditation

d

Peer reviewers, comprising a range of knowledgeable academic faculty and professionals, assess 

the academic quality of schools and provide schools with critical feedback on their weaknesses and 

areas for improvement, based on GAO’s literature review, expert roundtable discussion, and 

stakeholder interviews. The author did not offer an alternative option for assessing and monitoring 

schools’ improvement other than peer review.

e

Currently, when a member school does not meet accreditor standards, its accreditor may impose 

sanctions, such as issuing probations or warnings. Accreditors can also take a variety of other 

actions, such as requiring the school to furnish annual reports on finances or enrollment, interim 

reports on how it is meeting certain standards, or reaccrediting the school for a shorter amount of 

time. If the school is unable to meet accreditor standards, the accreditor can terminate the school’s 

accreditation. Currently, when a school loses its accreditation, Education terminates the school’s 

access to federal student aid. This practice would not change under this approach.

f

Currently, accreditation is one of the requirements that helps determine schools’ federal student aid 

eligibility, but not the sole factor. To participate in federal student aid programs authorized under Title 

IV of the Higher Education Act schools must meet various requirements. For example, schools must 

be authorized to provide postsecondary education by the state in which they are located and certified 

by Education as meeting certain administrative capability and financial responsibility requirements.
Appendix VII: Comments from the Department 

of Education

Page 75 GAO-18-5 Views on Higher Education Accreditation

Appendix VII: Comments from the 

Department of Education
Appendix VIII: GAO Contact and Staff 

Acknowledgments

Page 76 GAO-18-5 Views on Higher Education Accreditation

Melissa Emrey-Arras, (617) 788-0534 or emreyarrasm@gao.gov.

In addition to the contact named above, Tranchau (Kris) Nguyen 

(Assistant Director), Ashanta Williams (Analyst-in-Charge), Sarah 

Cornetto, Holly Dye, Aimee Elivert, Sara Edmondson, Jeffrey G. Miller, 

John Mingus, Walter Vance, and Jessica L. Yutzy made significant 

contributions to this report. Also contributing to this report were James 

Bennett, Deborah Bland, Tim Bober, Carlos Diz, Timothy Guinane, Sarah 

Gilliland, Teresa Heger, Jennifer McDonald, Ellen Phelps Ranen, Sheila 

McCoy, Ronni Schwartz, Katherine Siggerud, Stephen Sanford, Jonathan 

Still, and Eve Weisberg.

Appendix VIII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100737)
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