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STRENGTHENING ACCREDITATION TO 

BETTER PROTECT STUDENTS 

AND TAXPAYERS 

HEARING 

BEFORE THE

COMMITTEE ON EDUCATION 

AND THE WORKFORCE 

U.S. HOUSE OF REPRESENTATIVES 

ONE HUNDRED FIFTEENTH CONGRESS 

FIRST SESSION 

HEARING HELD IN WASHINGTON, DC, APRIL 27, 2017 

Serial No. 115–14 

Printed for the use of the Committee on Education and the Workforce 

( 

Available via the World Wide Web: www.gpo.gov/fdsys/browse/ 

committee.action?chamber=house&committee=education 

or 

Committee address: http://edworkforce.house.gov 

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(II) 

COMMITTEE ON EDUCATION AND THE WORKFORCE 

VIRGINIA FOXX, North Carolina, Chairwoman 

Joe Wilson, South Carolina 

Duncan Hunter, California 

David P. Roe, Tennessee 

Glenn ‘‘GT’’ Thompson, Pennsylvania 

Tim Walberg, Michigan 

Brett Guthrie, Kentucky 

Todd Rokita, Indiana 

Lou Barletta, Pennsylvania 

Luke Messer, Indiana 

Bradley Byrne, Alabama 

David Brat, Virginia 

Glenn Grothman, Wisconsin 

Steve Russell, Oklahoma 

Elise Stefanik, New York 

Rick W. Allen, Georgia 

Jason Lewis, Minnesota 

Francis Rooney, Florida 

Paul Mitchell, Michigan 

Tom Garrett, Jr., Virginia 

Lloyd K. Smucker, Pennsylvania 

A. Drew Ferguson, IV, Georgia 

Robert C. ‘‘Bobby’’ Scott, Virginia 

Ranking Member 

Susan A. Davis, California 

Rau ́l M. Grijalva, Arizona 

Joe Courtney, Connecticut 

Marcia L. Fudge, Ohio 

Jared Polis, Colorado 

Gregorio Kilili Camacho Sablan, 

Northern Mariana Islands 

Frederica S. Wilson, Florida 

Suzanne Bonamici, Oregon 

Mark Takano, California 

Alma S. Adams, North Carolina 

Mark DeSaulnier, California 

Donald Norcross, New Jersey 

Lisa Blunt Rochester, Delaware 

Raja Krishnamoorthi, Illinois 

Carol Shea-Porter, New Hampshire 

Adriano Espaillat, New York 

Brandon Renz, Staff Director 

Denise Forte, Minority Staff Director 

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(III) 

C O N T E N T S 

Page 

Hearing held on April 27, 2017 .............................................................................. 1 

Statement of Members: 

Foxx, Hon. Virginia, Chairwoman, Committee on Education and the 

Workforce ....................................................................................................... 1 

Prepared statement of ............................................................................... 3 

Scott, Hon. Robert C. ‘‘Bobby’’, Ranking Member, Committee on Education and the Workforce ............................................................................. 4 

Prepared statement of ............................................................................... 5 

Statement of Witnesses: 

McComis, Mr. Michale S., Executive Director, Accrediting Commission 

of Career Schools and Colleges .................................................................... 35 

Prepared statement of ............................................................................... 37 

Miller, Mr. Ben, Senior Director for Post-Secondary Education, Center 

for American Progress .................................................................................. 24 

Prepared statement of ............................................................................... 26 

Petrisko, Ms. Mary Ellen, President, Washington Association of Schools 

and Colleges, Senior College and University Commission ........................ 7 

Prepared statement of ............................................................................... 10 

Pruitt, Dr. George A., President, Thomas Edison State University ............. 13 

Prepared statement of ............................................................................... 15 

Additional Submissions: 

Ms. Petrisko: 

WASC Senior College and University Commission ................................ 82 

Article: Inside Higher Ed .......................................................................... 85 

WASC Senior College and University Commission: WSCUC’S Graduation Rate Dashboard .......................................................................... 89 

Dr. Pruitt: 

Homeroom .................................................................................................. 92 

Questions submitted for the record by: 

Chairwoman Foxx.................................................................................... 96, 112 

Roe, Hon. Phil, a Representative in Congress from the State of Tennessee ..................................................................................................... 98,113 

Messer, Hon. Luke, a Representative in Congress from the State 

of Indiana ............................................................................................... 100 

Rooney, Hon. Francis, a Representative in Congress from the State 

of Florida............................................................................................. 101, 113 

Response to questions submitted: 

Mr. McComis .............................................................................................. 96 

Ms. Petrisko ............................................................................................... 111 

Dr. Pruitt ................................................................................................... 122 

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(1) 

STRENGTHENING ACCREDITATION TO 

BETTER PROTECT STUDENTS 

AND TAXPAYERS 

Thursday, April 27, 2017 

House of Representatives 

Committee on Education and the Workforce 

Washington, D.C. 

The Committee met, pursuant to call, at 10:00 a.m., in Room 

2175, Rayburn House Office Building. Hon. Virginia Foxx [chairwoman of the committee] presiding. 

Present: Representatives Foxx, Roe, Thompson, Walberg, Guthrie, Messer, Byrne, Grothman, Stefanik, Allen, Lewis, Mitchell, 

Garrett, Smucker, Ferguson, Scott, Davis, Courtney, Polis, 

Bonamici, Takano, Adams, Norcross, Blunt Rochester, 

Krishnamoorthi, and Espaillat. 

Staff Present: Bethany Aronhalt, Press Secretary; Courtney 

Butcher, Director of Member Services and Coalitions; Emmanual 

Guillory, Professional Staff Member; Amy Raaf Jones, Director of 

Education and Human Resources Policy; Nancy Locke, Chief Clerk; 

Dominique McKay, Deputy Press Secretary; James Mullen, Director of Information Technology; Krisann Pearce, General Counsel; 

Jenny Prescott, Professional Staff Member; Alex Ricci, Legislative 

Assistant; Mandy Schaumburg, Education Deputy Director and 

Senior Counsel; Emily Slack, Professional Staff Member; Tylease 

Alli, Minority Clerk/Intern and Fellow Coordinator; Austin 

Barbera, Minority Press Assistant, Jacque Chevalier, Minority Director of Education Policy; Denise Forte, Minority Staff Director; 

Mishawn Freeman, Minority Staff Assistant; Christian Haines, Minority Senior Education Policy Counsel; Carolyn Hughes, Minority 

Deputy Director Health Policy/Senior Labor Policy Advisor; 

Veronique Pluviose, Minority General Counsel; Katherine Valle, 

Minority Education Policy Advisor; and Christopher Zbrozek, Minority Education Detailee. 

Chairwoman FOXX. A quorum being present, the Committee on 

Education and the Workforce will come to order. 

Good morning, and welcome to today’s hearing. 

Earlier this year, the committee met to examine some of the 

challenges facing America’s higher education system. Costs are rising at private and public institutions. Far too many individuals are 

failing to complete their education in a timely manner. Misguided 

CEWDOCROOM with DISTILLER

2 

rules are stifling innovation on campuses and creating new burdens on institutions across the country. 

At the same hearing, we discussed opportunities to help address 

these challenges, opportunities like empowering students to make 

informed decisions, simplifying student aid, and promoting innovation, access, and completion. 

Today, we continue our work to strengthen higher education by 

taking a closer look at another one of the key principles guiding 

our efforts, providing strong accountability for students and taxpayers. 

In higher education, one way we ensure accountability is the 

accreditation process. Accrediting agencies are voluntary private 

organizations made up of members from accredited colleges and 

universities. These agencies work with their member institutions to 

develop standards and criteria to determine what constitutes a 

high quality higher education institution. Then through a non-governmental system of peer review, the agencies decide if an institution meets those standards. 

By giving their stamp of approval, accreditation agencies provide 

students and parents with an assurance that an institution meets 

certain standards when it comes to delivering a high quality education. 

Families rely on accreditors to hold schools accountable for the 

education they provide, and to ensure these schools are producing 

results for their students. 

Congress also relies on accreditors. Accreditation helps determine 

which schools are permitted to participate in Federal student aid 

programs. These important programs allow students at eligible 

schools to receive Federal funds, and we need to know these hardearned taxpayer dollars are going only to institutions that are serving students well. 

The accreditation process is critical to providing accountability in 

the higher education system. However, like many aspects of higher 

education, accreditation is in need of improvement. 

It has never been and should never be the Federal Government’s 

role to judge the quality of a school’s education programs. Entrusting independent accrediting agencies with that responsibility protects academic freedom and student choice. 

However, in recent years, accreditors have been forced to focus 

on compliance rather than promoting academic integrity, undermining the process and its purpose. It is time for a better approach. 

We need to focus Federal accreditation requirements on academic 

quality and student learning. We need to ensure Federal rules are 

clear and easy to follow. We need to improve or do away with regulations that discourage or prevent innovation in higher education, 

and we need to make sure that the Administration, whether Democrat or Republican, does not have the power to recklessly secondguess the tough decisions accreditation agencies make. 

These are all things Congress can do to improve the accreditation 

process, but if we are going to see real change, accreditors have a 

job to do as well. 

It is not enough to refocus Federal rules. Accreditors must also 

embrace the commitment to high quality and improved outcomes. 

Students need an honest and accurate assessment when it comes 

CEWDOCROOM with DISTILLER

3 

to the quality of education a school provides. An accreditation agency’s stamp of approval means something to those students, or at 

least it should mean something. 

Accreditors also need to be open to innovation and the opportunities it can create in higher education. If we are going to roll back 

rigid Federal requirements, it is up to accrediting agencies to take 

the flexibility we are working to provide and do something meaningful with it. 

By working together, Congress and accreditors, we can improve 

the accreditation system, ensuring a balance between flexibility for 

institutions and accountability for students and taxpayers. 

We are here today to gain a better understanding of the challenges facing the accreditation system, as well as how we can tackle those challenges. 

I look forward to hearing from our witnesses and advancing solutions that will provide greater accountability in higher education, 

and ensure the accreditation process serves the best interests of 

students, families, and taxpayers. 

With that, I yield to Ranking Member Scott for his opening remarks. 

[The information follows:] 

Prepared Statement of Hon. Virginia Foxx, Chairwoman, Committee on 

Education and the Workforce 

Earlier this year, the committee met to examine some of the challenges facing 

America’s higher education system. Costs are rising at private and public institutions. Far too many individuals are failing to complete their education in a timely 

manner. Misguided rules are stifling innovation on campuses and creating new burdens on institutions across the country. 

At that same hearing we discussed opportunities to help address these challenges—opportunities like empowering students to make informed decisions; simplifying student aid; and promoting innovation, access, and completion. 

Today, we continue our work to strengthen higher education by taking a closer 

look at another one of the key principles guiding our efforts—providing strong accountability for students and taxpayers. 

In higher education, one way we ensure accountability is the accreditation process. Accrediting agencies are voluntary private organizations made up of members 

from accredited colleges and universities. These agencies work with their member 

institutions to develop standards and criteria to determine what constitutes a highquality higher education institution. Then, through a non-governmental system of 

peer review, the agencies decide if an institution meets those standards. 

By giving their stamp of approval, accreditation agencies provide students and 

parents with an assurance that an institution meets certain standards when it 

comes to delivering a high-quality education. Families rely on accreditors to hold 

schools accountable for the education they provide and to ensure those schools are 

producing results for their students. 

Congress also relies on accreditors. Accreditation helps determine which schools 

are permitted to participate in federal student aid programs. These important programs allow students at eligible schools to receive federal funds, and we need to 

know those hard-earned taxpayer dollars are only going to institutions that are 

serving students well. 

The accreditation process is critical to providing accountability in the higher education system. However, like many aspects of higher education, accreditation is in 

need of improvement. 

It has never been and should never be the federal government’s role to judge the 

quality of a school’s education programs. Entrusting independent accrediting agencies with that responsibility protects academic freedom and student choice. However, in recent years, accreditors have been forced to focus on compliance rather 

than promoting academic integrity, undermining the process and its purpose. It’s 

time for a better approach. 

We need to refocus federal accreditation requirements on academic quality and 

student learning. We need to ensure federal rules are clear and easy to follow. We 

CEWDOCROOM with DISTILLER

4 

need to improve—or do away with—regulations that discourage or prevent innovation in higher education. And we need to make sure the administration—whether 

Democrat or Republican—does not have the power to recklessly second-guess the 

tough decisions accreditation agencies make. 

These are all things Congress can do to improve the accreditation process, but if 

we are going to see real change, accreditors have a job to do as well. 

It’s not enough to refocus federal rules. Accreditors must also embrace a commitment to high-quality and improved outcomes. Students need an honest and accurate 

assessment when it comes to the quality of education a school provides. An accreditation agency’s stamp of approval means something to those students, or at least 

it should mean something. 

Accreditors also need to be open to innovation and the opportunities it can create 

in higher education. If we are going to roll back rigid federal requirements, it’s up 

to accrediting agencies to take the flexibility we are working to provide and do 

something meaningful with it. 

By working together—Congress and accreditors—we can improve the accreditation system, ensuring a balance between flexibility for institutions and accountability for students and taxpayers. 

We are here today to gain a better understanding of the challenges facing the accreditation system, as well as how we can tackle those challenges. I look forward 

to hearing from our witnesses and advancing solutions that will provide greater accountability in higher education and ensure the accreditation process serves the best 

interests of students, families, and taxpayers. 

Mr. SCOTT. Thank you, Madam Chair, and I would like to thank 

you for calling this hearing, and thank our distinguished witnesses 

for being with us today. 

The issue of quality in higher education is not one that we address often in Congress. The higher education system in the United 

States is one of if not the best in the world, and we frequently 

spend our time debating how to increase access to the system or 

how to make college more affordable, and not just in quality. 

While these are topics that I am sure we will continue debating, 

it is important to take a step back to determine if we are ensuring 

that our higher education system maintains its high level of quality 

across all sectors for all students. 

While the Federal Government and State authorizers both have 

important roles to play in assuring quality, independent accrediting 

bodies should be the true arbiters of quality in our higher education system. 

Their thoughtful peer review process is designed to ensure that 

institutions are living up to their educational mission, whether it 

is providing students with an education that will be the basis of 

lifetime learning, or preparing them to excel in a specific field or 

career. 

The title of this hearing alludes to the fact that while students 

depend on accreditors, taxpayers do as well. Over $150 billion in 

Federal student aid is disbursed every year, and it can only go to 

institutions of higher education that have been accredited by a federally recognized accreditor. As such, there are huge fiscal implications in the quality and rigor of the accreditation process. 

While the accreditation system works well for many schools, it 

must be improved. We know that there have been schools that 

were fully accredited up until the day they closed their doors, leaving students out in the cold and taxpayers holding the bag. 

We also know that there are schools that remain accredited while 

offering their students little chance to obtain a degree or get a credential that has little value in the marketplace. 

CEWDOCROOM with DISTILLER

5 

There is emerging research that shows that in some cases, the 

outcomes at some fully accredited schools are so poor that students 

would have been better off not going to school at all rather than 

attending those schools. 

The Federal Government has begun to respond to these problems 

in accreditation. The Federal Government has an interest in 

whether or not a school is accredited because of the billions of dollars in Federal aid, and if the accreditors aren’t doing the job, the 

Federal Government has to do the job, and that is where programs 

like Gainful Employment and other measures have come up. 

To the extent that the accreditors fail, we are going to have to 

come up with those kinds of answers. Over the last two years, the 

Department of Education has proposed actions to make the accreditation system more transparent, and to provide more information 

on standards that accreditors use to rate schools. 

Last year, the National Advisory Committee on Institutional 

Quality and Integrity derecognized the Accrediting Council for 

Independent Colleges and Schools, putting other accreditors on notice that subpar standards and a documented history of turning a 

blind eye to bad actors would not be tolerated. 

It seems like many accreditors got the message, and we have 

seen proposed reforms from accreditors based on recommendations 

from the previous Administration. 

I know accreditors want to improve, and they want to ensure 

that their members still provide a top-notch education, but we are 

at a crossroads. There is no guarantee that the new Administration 

is going to take a critical view on the need to improve accreditation, and I worry that the improvements we have seen of late could 

falter without the oversight and pressure from the Federal Government. 

Accreditation can be a peer-based program designed to foster 

self-improvement and be responsive to data on student outcomes. 

It can meet the needs of vastly different institutions but still use 

common terms and measures. 

It can respect the internal decisions and choices of an institution 

and still be transparent. 

We can have the best accreditation system in the world for the 

best higher education system in the world, and hopefully, our witnesses today will provide the perspective on how we can do just 

that. 

Thank you, Madam Chair, and I yield back. 

Chairwoman FOXX. Thank you, Mr. Scott. Pursuant to Committee Rule 7(c), all members will be permitted to submit written 

statements to be included in the permanent hearing record. 

Without objection, the hearing record will remain open for 14 

days to allow such statements and other extraneous material referenced during the hearing to be submitted for the official hearing 

record. 

[The information follows:] 

Prepared Statement of Hon. Robert C. ‘‘Bobby’’ Scott, Ranking Member, 

Committee on Education and the Workforce 

Good morning. I would like to thank Chairwoman Foxx for calling this hearing 

and I’d like to thank our distinguished witnesses for being here today. 

CEWDOCROOM with DISTILLER

6 

The issue of quality in higher education is one that we address often here in Congress. The higher education system in the United States is one of, if not the best 

in the world, and we frequently spend our time debating how to increase access to 

the system or how to make college more affordable. And while these are topics that 

I’m sure we will continue debating, it is important that we take a step back and 

determine if we are ensuring that our higher education system maintains its high 

level of quality across all sectors for all students. 

While the federal government and state authorizers both have important roles to 

play in assuring quality, accrediting bodies are the true arbiters of quality in our 

higher education system. Their thoughtful peer review process is designed to ensure 

that institutions are living up 

to their educational mission—whether it’s providing students with an education 

that will be the basis for a lifetime of learning or preparing them to excel in a specific field or career. The title of this hearing alludes to the fact that while students 

depend on accreditors, taxpayers do as well. Over $150 billion in federal student aid 

is disbursed every year, and it can only go to institutions of higher education that 

have been accredited by a federally recognized accreditor. As such, there are huge 

fiscal implications to the quality and rigor of accreditation reviews. 

While the accreditation systems works well for many schools, it must be improved. We know that there were schools that were fully accredited up until the 

point that they closed their doors, leaving students out in the cold and taxpayers 

holding the bag. We also know there are schools that remain accredited while offering their students little chance to obtain a degree, or a credential that has little 

value in the marketplace. There is emerging research that shows in the worst cases, 

the outcomes at some fully accredited schools are so poor that students would have 

been better off going to no school rather than attending. 

The federal government has begun to respond to these problems in accreditation. 

Over the last two years the Department of Education proposed actions to make the 

accreditation system more transparent, and provide more information on the standards that accreditors use to rate schools. Last year the National Advisory Committee on Institutional Quality and Integrity, (or NACIQI) derecognized the Accrediting Council for Independent Colleges and Schools (or ACICS), putting other 

accreditors on notice that subpar standards and a documented history of turning a 

blind eye to bad actors would not be tolerated. 

It seems like many accreditors got the message, and we have seen proposed reforms from accreditors based on recommendations from the previous administration. 

I know accreditors want to improve and they want to ensure that their members 

are still providing a top-notch education. But we are at a crossroads. There is no 

guarantee that the new Administration is going to take as critical a view on the 

need to improve accreditation, and I worry that the improvements that we’ve seen 

of late could falter without the oversight of the federal government. 

Accreditation can be a peer-based program designed to foster self-improvement 

and be responsive to data on student outcomes. It can meet the needs of vastly different institutions but still use common terms and actions. It can respect the internal decisions and choices of an institution and still be transparent. We can have the 

best accreditation system in the world for the best higher education system in the 

world, and hopefully our witnesses here today will provide perspective on how we 

can do just that. Thank you and I yield back the balance of my time. 

Chairwoman FOXX. We now turn to introduction of our distinguished witnesses. Dr. Mary Ellen Petrisko is President of the Senior College and University Commission at the Western Association 

of Schools and Colleges. Dr. Petrisko has extensive experience in 

institutional academic leadership and regional accreditation and 

State policy. 

Dr. George Pruitt is President of the Thomas Edison State University. Dr. Pruitt has served in executive leadership positions at 

several postsecondary institutions, and is past chairman and a 

member of the Middle States Commission on Higher Education. 

Mr. Ben Miller is Senior Director for Postsecondary Education at 

the Center for American Progress. Mr. Miller’s work focuses on 

postsecondary education accountability, affordability, and financial 

aid, as well as for-profit colleges and other issues. 

CEWDOCROOM with DISTILLER

7 

Dr. Michale McComis is Executive Director at the Accrediting 

Commission of Career Schools and Colleges. As the Executive Director, Dr. McComis manages the day-to-day operations of ACCSC’s 

office and staff in overseeing the ACCSC accreditation process. 

I now ask our witnesses to raise your right hand. 

[Witnesses sworn.] 

Chairwoman FOXX. Let the record reflect the witnesses answered 

in the affirmative. 

Before I recognize each of you to provide your testimony, let me 

briefly explain our lighting system. We allow 5 minutes for each 

witness to provide testimony. When you begin, the light in front of 

you will turn green. When one minute is left, the light will turn 

yellow. At the 5 minute mark, the light will turn red, and you 

should wrap up your testimony. 

Members will each have 5 minutes to ask questions. 

I believe we are ready to begin. Dr. Petrisko, you are recognized 

for 5 minutes. 

TESTIMONY OF MARY ELLEN PETRISKO, PRESIDENT, WASHINGTON ASSOCIATION OF SCHOOLS AND COLLEGES, SENIOR 

COLLEGE AND UNIVERSITY COMMISSION 

Ms. PETRISKO. Chairman Foxx, Ranking Member Scott, and 

members of the committee, thank you for the opportunity to be 

with you today to testify. 

As noted, I am the President of the WASC Senior College and 

University Commission, which is an accrediting body serving public 

and private higher education institutions throughout California, 

Hawaii, and the Pacific, and a limited number of institutions outside of the U.S. 

The first accreditor of colleges and universities was founded in 

this country in 1885, when there were just 36 States in the Union. 

Just as our country has grown and developed over the past 130 

years, so, too, had accreditation changed to become what it is 

today, an outcomes-focused system of quality assurance that relies 

on voluntary peer review. 

The work of accreditation is grounded in standards aligned with 

those dictated by U.S. statute and regulations. Since 1952, related 

to the G.I. Bill, accreditors have been recognized as quality assurance agencies to protect the Federal Government’s investment in 

higher education. Accreditation has traditionally existed as part of 

a quality assurance triad, in collaboration with State and Federal 

Government. 

Colleges and universities in the United States have an international reputation for exceptional quality, as does our system of 

accreditation. Indeed, many institutions outside of the United 

States aspire to be accredited by U.S. accreditors, but the fact that 

our accreditation system is a strong and much admired system 

does not mean that it and our larger quality assurance system 

triad are perfect. 

Today’s hearing is focused on opportunities to improve accreditation. While I believe accreditors largely do a good job in protecting 

students, I also believe that steps could be taken in the reauthorization of the Higher Education Act to create a stronger accountability system and therefore better serve students. 

CEWDOCROOM with DISTILLER

8 

First, I’d like to tell you about some of the things we at WSCUC 

are doing to support student success and protect the public’s investment in higher education. 

At WASC, we define ‘‘student success’’ as student learning and 

retention and completion. With regard to the latter, let me note 

that the Federal IPEDS data only measured completion for first 

time full-time students at an institution. In the WASC region, 

IPEDS covers only about 360,000 of our 900,000 undergraduate 

students, making more than 500,000 students invisible. 

To address the insufficiency of these data, WASC has developed 

what we call the ‘‘Graduation Rate Dashboard,’’ a tool that enables 

us to see how many students graduate from an institution, and importantly, no matter their enrollment status or time to degree. 

Given that the majority of our students fall outside the IPEDS’ 

measure, this is an important development. The Dashboard can 

provide institutions with more complete and inclusive information 

regarding student success, shine light on enrollment, retention, and 

graduation patterns, and allow both WASC and the institution to 

better identify and address issues that affect student success. 

I’ve included additional information about this tool in my written 

testimony, as well as information about our work with the National 

Student Clearinghouse to expand our ability to assess institutional 

effectiveness. 

As student completion is important to all accreditors, the Council 

of Regional Accreditors, or C–RAC, recently launched a nationwide 

effort to place increased emphasis on graduation rates as part of 

our ongoing review of colleges and universities. 

Each accrediting body will use at a minimum a 15 percent 

IPEDS’ graduation rate for two year institutions, and a 25 percent 

rate for four year institutions—those numbers are about half the 

national average—as triggers to more closely examine institution’s 

student success and plans for improvement. 

Let me conclude by making three recommendations for the 

strengthening of our system of accountability related to innovation, 

transparency, and appropriate levels of regulation. 

First and foremost, I believe it is critical that the HEA reauthorization support the innovation necessary to serve current and especially future students, and that it will allow accreditors the flexibility to review and approve innovations in a safe zone as is allowed by current experimental sites. 

As our regional undergraduate population shows, the majority of 

students today do not go to one institution full-time or finish within four years. I hope that the reauthorization will keep these 

changing student demographics in mind. 

Secondly, whatever steps are taken to provide greater transparency should ensure that students can access accurate and relevant information on our institutions. Currently available data 

from the College Navigator and College Scorecard are sometimes 

inaccurate, sometimes in conflict with one another, and limited due 

to their reliance on IPEDS. Better information can help students 

make better choices and promote enhanced accountability. 

Understanding this, we at WASC have published all of our team 

reports and Commission action letters since July of 2012. 

CEWDOCROOM with DISTILLER

9 

Finally, I hope that excessive regulations, such as those related 

to substantive change and credit hour, will be addressed and moderated. Such regulations inhibit innovation, add costs and burden 

to institutions, and do not add value. 

Chairman Foxx, Ranking Member Scott, thank you very much 

for the opportunity to testify. I look forward to answering your 

questions. 

[The statement of Ms. Petrisko follows:] 

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10 

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Insert offset folio 1 here 25136.001

House Education and Workforce Committee Hearing 

"Strengthening Accreditation to Better Protect Students and Taxpayers" 

April 27, 2017 

Testimony of Dr. Mary Ellen Petrisko 

WASC Senior College and University Commission 

Chairwoman Foxx, Ranking Member Scott, and members of the committee: Thank you for the 

opportunity to testify today. My name is Mary Ellen Petrisko, and I am president of the WASC Senior 

College and University Commission, an accrediting body serving public and private higher education 

institutions throughout California, Hawaii, and the Pacific, as well as a limited number of institutions 

outside the U.S. 

The first accreditor of colleges and universities was founded in this country in 1885-when there were 

just 36 states in the union. Just as our country has grown and developed over the past 130 years, so too 

has accreditation changed to become what it is today: an outcomes-focused system of quality 

assurance that relies on voluntary peer review. 

The work of accreditation is grounded in standards aligned with those dictated by U.S. Statute and 

Regulations. Since 1952, related to the Gl Bill, accreditors have been recognized as quality assurance 

agencies that protect the federal government's investment in higher education. Accreditation has 

traditionally existed as part of a quality assurance triad, in collaboration with state and federal 

government. The traditional role of the state has been that of consumer protection; that of the federal 

government has been that of responsibility for the considerable federal expenditure on student aid. In 

recent years, both the state and federal government's responsibilities as part of this triad have 

increasingly been seen as the work of the accreditor. 

Colleges and universities in the United States have an international reputation for exceptional quality, as 

does our system of accreditation. Indeed, many institutions around the world aspire to be accredited by 

a U.S. accreditor. But the fact that our accreditation system is a strong and much-admired system does 

not mean that it and our larger quality assurance triad are perfect. 

Today's hearing is focused on opportunities to improve accreditation. While I believe accreditors largely 

do a good job in protecting students, I also believe steps could be taken in the reauthorization of the 

Higher Education Act to create a stronger accountability system and therefore better serve students. 

But first, I'd like to tell you about some things that we are doing to support student success and protect 

the public's investment in higher education. 

At WSCUC, we define student success as student learning AND retention and completion. With regard 

to the latter, let me begin by noting that federaiiPEDS data only measure completion for first-time fulltime students at an institution. In the WSCUC region, I PEDS covers only about 360,000 of our 900,000 

undergraduate students- making more than 500,000 students invisible. 

To address the insufficiency of these data, WSCUC has developed the Graduation Rate Dashboard, a tool 

that enables us to see how many students graduate from an institution- no matter their enrollment 

status or time to degree.' Given that the majority of our students fall outside the I PEDS measure, this is 

an important development. The Dashboard can provide institutions with more complete and inclusive 
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information regarding student success; shine a light on enrollment, retention and graduation patterns; 

and allow WSCUC and institutions to better identify and address issues that affect student success. 

The Dashboard can be seen as a sort of balance sheet that tracks how many credits are given out by an 

institution; how many are "cashed in" for a degree; and how many are left on the table. WSCUC collects 

six data points from institutions via our annual report, the baseline data tracked for all accredited, 

candidate and eligible institutions and referenced by WSCUC staff, peer evaluators and the commission 

during every accreditation review. On the basis of those data points, two completion measures are 

calculated: the "unit redemption rate"- i.e., the proportion of units granted by an institution that are 

eventually "redeemed" for a degree from that institution-and the "absolute graduation rate" -i.e., the 

proportion of students entering an institution who eventually graduate from that institution. The 

difference between the I PEDS graduation rate and the Dashboard rate can be significant: in the case of 

California State University Dominguez Hills, for example, the difference between a 30 percent I PEDS rate 

and a 60 percent Dashboard rate. 

WSCUC has also contracted with the National Student Clearinghouse to receive data on both regional 

and national completion rates. The Clearinghouse includes in its completion data both transfer students 

and students enrolled after the six-year period that I PEDS uses as the cutoff for measuring institutional 

cohorts' graduation rates. One of the benefits of the Clearinghouse data is that they, like IPEDS data, can 

be disaggregated by gender and ethnicity, as well as by institution type, which can be very beneficial in 

evaluating institutional effectiveness in supporting student success. 

As student completion is important to all accreditors, the Council of Regional Accreditors, or C-RAC, 

recently launched a nationwide effort to place increased emphasis on graduation rates as part of our 

ongoing review of colleges and universities. Each accrediting body will use, at a minimum, a 15 percent 

I PEDS graduation rate for two-year institutions and a 25 percent rate for four-year institutions-about Y, 

the national average-- as triggers to closely examine institutional student success and plans for 

improvement. 

Let me conclude by making three recommendations for the strengthening of our system of 

accountability, related to innovation, transparency, and appropriate levels of regulation. 

First and foremost, I believe it is critical that the HEA reauthorization support the innovation necessary 

to serve current and especially future students, and that it allow accreditors the flexibility to review and 

approve innovations in a safe zone, as is allowed by current experimental sites. As our regional 

undergraduate population demonstrates, the majority of students today do not go to one institution 

full-time and finish within four years. I hope that the reauthorization will keep these changing student 

demographics in mind. 

Secondly, whatever steps are taken to provide greater transparency should ensure that students can 

access accurate and relevant information on our institutions. Currently available data from the College 

Navigator and College Scorecard are sometimes inaccurate, sometimes in conflict with one another, and 

are limited due to their reliance on I PEDS data. Better information can help students make better 

choices and promote enhanced accountability across higher education. Understanding this, we at 

WSCUC have published all of our team reports and Commission action letters on our website since July 

2012. 
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Finally, I hope that excessive regulations, such as those related to substantive change and defining the 

credit hour, will be addressed and moderated. Such regulations inhibit innovation and add costs and 

burdens to institutions without adding value. 

Chairwoman Foxx and Ranking Member Scott, thank you again for allowing me to testify. !look forward 

to answering your questions and furthering the discussion around accreditation and higher education 

reform. 

' More Information is available on the WSCUC website: https://www.wscuc.org/resources/about-the-graduationrate-dashboard 
13 

Chairwoman FOXX. Thank you very much. Dr. Pruitt, you are 

recognized for 5 minutes. 

TESTIMONY OF GEORGE A. PRUITT, PRESIDENT, THOMAS 

EDISON STATE UNIVERSITY 

Mr. PRUITT. Thank you. Madam Chairwoman and members of 

the committee, in December, I completed three successive terms as 

Chair of the Middle States Commission on Higher Education. 

Prior to that, I served for almost 19 years, under five Secretaries 

of Education, under three Presidents of both parties, as a member 

of the National Advisory Committee on Institutional Quality and 

Integrity, otherwise known as NACIQI, but today I come before you 

to provide an institutional perspective. 

Thomas Edison State University is a specialty university. We 

were created with the mission of providing flexible, high quality 

collegiate learning opportunities for self-directed adults. The average age of our student body is approximately 40, and we do not 

regularly admit students under the age of 21 unless they are community college graduates or active duty military. 

With an enrollment of 17,500 students, we are the third largest 

college or university in the State of New Jersey. We were among 

the first institutions in creating what is now known as ‘‘prior learning assessment.’’ We were one of the first regionally accredited colleges or universities in the United States to offer complete degree 

programs online. 

While we are noted for our innovation in the serving of adult 

learners, we are proudest of the recognition we receive for the quality and integrity of our academic work. 

Regionally accredited institutions value their participation as 

members of quality assurance communities. While reasonable Federal oversight over the use of public funds is important and necessary, we believe that peer affirmation of quality tested against 

agreed upon standards promulgated by recognized academic authorities, has been essential in producing the finest set of academic 

institutions in the world. 

There are four basic things we would all like to see from our 

accreditors. First, standards that respect the rich diversity and institutional mission and the different student populations we serve 

through a process of self-study and peer review. 

Ten miles down the road from us is Princeton University, one of 

the finest institutions in the world, yet our two universities could 

not be more different. Both of high quality, but with very different 

missions serving two very different populations that require different analytics to understand us. 

Second, accreditation focused on objectively demonstrable student learning outcomes. 

Third, accreditation conclusions about institutional effectiveness 

that are based on objective evidence, appropriate metrics, and 

where possible, third party validation. 

The emphasis should be on appropriate metrics that are aligned 

with the individual mission of the institution, and not a one-sizefits-all template, using misplaced data, such as graduation rates. If 

graduation rate is the wrong metric, then what are some of the 

right ones? 

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14 

For example, Thomas Edison State University graduates 

achieved the highest pass rate of all New Jersey institutions on the 

National Public Accountancy Exam for three of the last five years. 

In 2012 and 2014, the graduates of our Accelerated Baccalaureate Nursing Program earned a 100 percent pass rate on the 

State licensure exam. In fiscal 2016, 77 percent of our graduates 

were admitted to graduate schools, and only 7 percent of the students that stopped out of our institution did so for academic reasons. 

The vast majority of students enrolled in American higher education today are over the age of 25 and attend college part-time. 

The traditional 18-year-old going to college full-time expecting to 

graduate in four years is a shrinking piece of the higher education 

pie. Accordingly, the metrics of accountability to be of any value 

must reflect this new reality. You’ll never get the right answer to 

the wrong question. 

Finally, accreditors should continue to oppose the substitution of 

compliance for quality assurance that is stemming from well-intentioned but misguided regulation by the Department of Education. 

I believe that Middle States and the other regional accreditors 

are meeting these four benchmarks. We all understand that there 

have been some well publicized examples of institutions that have 

lost their way, compromised the public trust, misused public resources, and hurt the students that were enlisted into their care. 

While these institutions should be held accountable by their 

accreditors, regulators, and consumers, the broad system of accreditation is fundamentally sound, but we must always be involved in 

a process of continuous improvement. 

Accreditation should not be expected to prevent the failure of institutions. Instead, it should be the proverbial canary in the coal 

mine, identifying weak institutions, strengthening them where possible, and alerting the regulators and protecting students when institutions become severely challenged. 

However, in our effort to improve the system, we must not impose remedies that do more harm than the maladies they seek to 

cure. 

Thank you. 

[The statement of Dr. Pruitt follows:] 

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STATEMENT OF 

DR. GEORGE A. PRUITT 

PRESIDENT, THOMAS EDISON STATE UNIVERSITY 

BEFORE THE COMMITTEE ON EDUCATION AND THE WORKFORCE 

UNITED STATES HOUSE OF REPRESENTATIVES 

April 27, 2017 

Madam Chairwoman and Members of the Committee, my name is George Pruitt and I am 

president of Thomas Edison State University in New Jersey. In December, I completed three 

successive terms as chair of the Middle States Commission on Higher Education. Prior to that I 

served for almost 19 years under five secretaries of education, under three presidents of both 

parties as a member of the National Advisory Committee on Institutional Quality and Integrity, 

otherwise known as NACIQJ, but today I come to share with you the perspective of a regionally 

accredited institution. 

Thomas Edison State University is a specialty university. We were created with the 

mission of providing flexible, high-quality collegiate learning opportunities for self-directed 

adults. The average age of our student body is approximately 40 and we do not regularly admit 

students under the age of21 unless they are community college graduates or active-duty military. 

With an enrollment of 17,500 students, we are the third largest college or university in the state 

of New Jersey. 

We were among the first institutions in creating what is now known as prior learning 

assessment. We were one of the first regionally accredited colleges or universities in the United 

States to offer a complete degree program "online." While we are noted for our innovation in 

serving adult learners, we are proudest of the recognition we receive for the quality and integrity 

of our academic work. 
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Pruitt 2 

Regionally accredited institutions value their participation as members of quality 

assurance communities. While reasonable federal oversight over the use of public funds is 

necessary, we believe that peer affirmation of quality, tested against agreed upon standards and 

promulgated by recognized academic authorities, has been essential in producing the finest set of 

academic institutions in the world. 

The process of institutional self-study is vital to self-renewal. Peer review by trusted 

expert peers is crucial to avoid institutional self-delusion. While some have criticized peer 

review as mutual backslapping, that point of view is not informed by the reality of a process 

which is robust, independent and comprehensive. That is not to say that the process cannot be 

improved. Accreditors should, and have moved to, simplify the standards, share common 

language in reporting and findings, place greater emphasis on student outcomes, provide for 

differential scrutiny between strong, healthy institutions and those that are more challenged, and 

use objective measures of institutional effectiveness that take into account the specific mission of 

the institution and the population they serve. 

There are four basic things we all would like to see from our accreditors: 

First, standards that respect the rich diversity in institutional missions and the diversity of 

the various populations we serve through a process of self-study and peer review. Ten miles 

down the road from us sits Princeton University, one of the finest institutions in the world. Yet 

our two universities could not be more different; both of high quality, but with very different 

missions serving two very different populations that require different analytics to understand us. 

Second, accreditation that is focused on student learning outcomes. 

Third, accreditation conclusions about institutional effectiveness that are based on 

objective evidence, appropriate metrics and where possible, third party validation. The emphasis 
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Pruitt 3 

should be on appropriate metrics that are in line with the individual mission of the institution, 

and not a one-size-fits-all template using misapplied data such as graduation rates. If graduation 

rates is the wrong metric, what are some of the right ones? For example, Thomas Edison State 

University graduates achieved the highest pass rates of all New Jersey institutions on the national 

public accountancy exam for three of the last five years. In 2012 and 2014, the graduates of our 

accelerated baccalaureate nursing program earned a I 00% pass rate on the state licensure exam. 

In fiscal year 2016, 77% of our graduates were admitted to graduate school, and only seven 

percent of the students that stopped out of our institution did so for academic reasons. The vast 

majority of students enrolled in American higher education today are over the age of 25 and 

attend college part time. The traditional 18 year old, going to college full time, expecting to 

graduate in four years, is a shrinking piece of the higher education pie. Accordingly, the metrics 

of accountability, to be of value, must reflect this new reality. There can never be the right 

answer to the wrong question. 

Finally, accreditors should continue to oppose the substitution of compliance for quality 

assurance that is stemming from well-intentioned, but misguided and inappropriate regulations 

by the Department of Education. 

I believe that Middle States and the other regional accreditors arc meeting these four 

benchmarks. We all understand that there have been some well-publicized examples of 

institutions that have lost their way, compromised the public trust, misused public resources and 

hurt the students that were enlisted into their care. While these institutions should be held 

accountable by their accreditors, regulators and consumers, the broad system of accreditation is 

fundamentally sound. However, we must always be involved in a process of continuous 

improvement. 
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Pruitt 4 

Accreditation should not be expected to prevent institutions from failing. Instead, it 

should be the proverbial "canary in the coal mine" identifying weak institutions, strengthening 

them where possible, and alerting the regulators and protecting students when institutions 

become severely challenged. However, in our efforts to improve the system we must not impose 

remedies that do more harm than the maladies they seek to cure. 

I hope you will consider the following points in the Higher Education Reauthorization 

Act: 

First, heed the admonition contained in the physician's oath: "first do no harm." While 

there have been some highly publicized examples of questionable institutional behavior, the 

system of regional accreditation is fundamentally sound. Regional accreditation is a dynamic 

process, constantly adjusting to changing realities. The few lapses in oversight by these 

accreditors have been responded to, and I doubt will reoccur. They are genuinely committed to 

being more vigorous in protecting our students and the public. 

Regulatory Relief 

As I indicated earlier, for almost 19 years, I worked with the Department of Education as 

a member of the National Advisory Committee on Institutional Quality and Integrity and its 

predecessor committee, under several administrations of both parties. I found that work 

challenging but productive, and I enjoyed my engagement with the Department staff. I come to 

my current position on the unfortunate recent changes in the regulatory culture and regime of the 

Department with no philosophical or ideological animus, but with a deep sense of 

disappointment. While it is not my intent to impugn anyone's goodwill, experience has taught 

me that sometimes bad things come from good intentions. Regulatory relief is needed in five 

areas: 
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Pruitt 5 

I. Credit hour. For the first time I can recall, the Department of Education is requiring 

colleges and universities to equate the number of credit hours awarded for a course to 

"the seat time" a student sits in a classroom. Colleges and universities assign credit 

awards based on the quality of academic content in courses, not the time spent in a 

classroom. What about laboratory work, studio time, independent study, online 

courses, thesis and dissertation research, internships, cooperative education, physical 

education activity courses, none of which requires classroom "seat time?'' As an 

undergraduate, I took a five-credit hour chemistry course. Between the· lectures, 

discussion sessions and lab time, I was 'in class' 15 hours a week. I took a one-hour 

physical education activity class that met three times a week in a bowling alley. By 

the Department's logic, the University of Illinois owes me 11 credits for those two 

courses. Of course they don't. Credit hours for a course are a function of the 'heft' 

of the syllabus, not the location of the student's posterior. Credit hour at its core is a 

matter of intrinsic academic judgement that must be left to the academy. This 

unfortunate application of federal regulation should be eliminated. 

2. State authorization. It is not unreasonable to assume that states should license and 

regulate the activities of post-secondary educational institutions operating within their 

borders. This is reasonable to assure that a minimum threshold of quality is met, as 

well as to protect the rights of the consumer. Unfortunately, the Department has 

attempted to extend state licensure requirements to colleges and universities that have 

absolutely no physical presence in the state by including 'online' courses, literature 

distribution, and in at least one case, a billboard. The regulation cripples the use of 

technology that increases access, shortens time to completion, and lowers costs. The 
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Pruitt 6 

community has responded under the leadership of the Higher Education Regional 

Compacts, which created the State Authorization Reciprocity Agreement (SARA). 

SARA has created a definition of 'state presence,' which is limited to actual physical 

presence in the state. I urge you to incorporate the SARA definitions into Higher 

Education Reauthorization. 

3. Defending regional accreditation from becoming "compliance franchises" of the 

Department of Education. Over the last several years, the Department of Education 

continually promulgated a series of increasingly intrusive, overreaching regulatory 

and reporting requirements and made the regional accreditors enforcers of these rules 

as a condition of federal recognition. When you hear college officials complain about 

the minutia and nitpicking by accreditors, it is usually caused by the compliance 

protocols forced on the accreditors, not the quality assurance practices developed by 

the accreditors. I will defer to my colleagues from the accrediting agencies to talk 

about NACIQI, but given my long personal involvement with that organization, I 

can't help but express my disappointment about the changes that have happened 

there. 

4. The Federal rating system or "score card." Colleges and universities are 

committed to providing easily accessible information about their institutions to allow 

educational consumers to make informed choices. However, when the Department of 

Education announced its intention to create a federal rating system or "score card" for 

colleges and universities, there was nearly uniform opposition from the higher 

education community. The reason for the opposition was not an aversion to 

disclosure, but because the task as stated is psychometrically impossible to achieve 
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Pruitt 7 

with any validity. Again, Thomas Edison State University and Princeton University 

are both very high quality institutions, but it is impossible to come up with a common 

set of metrics that could adequately describe both. The great strength of American 

higher education is its diversity and its quality, but that diversity makes a "score card" 

impossible. Nevertheless, the Department persisted and the "score card" it produced 

magnificently illustrates the point that the task is not feasible. Attached to my 

testimony is a document I printed from the Department website entitled, "23 Fouryear schools with low costs that lead to high incomes." That is great information if it 

were true. I hope you will look at the institutions on the list. It contains 23 of the 

most expensive and selective colleges and universities in the nation. The only public 

institutions I recognize are Georgia Tech, University of Michigan, and the University 

of Virginia. There is Princeton, Harvard, MIT, Stanford, Duke, etc. The criteria that 

the Department used was "out of pocket" cost for a Pell Grant recipient. It is true that 

if you are a low-income student who is fortunate enough to be admitted to one of the 

institutions on the list, they will make sure that your financial circumstances will not 

preclude you from attending. While I know the Department had good intentions, to 

suggest to a working-class family that a sound strategy to achieve a "low cost high 

income" education is to go to the most expensive, selective school, is irresponsible. 

am reminded of the quote by Peter F. Drucker: "There is nothing so useless as doing 

efficiently that which should not be done at all." 

5. Litigation costs. Accreditors are sometimes criticized for waiting too long in 

revoking the accreditation of struggling institutions. Sometimes this observation is 

valid. Accrcditors are loathe to take that final step not because they are timid or Jack 
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Pruitt 8 

resolve, but because the consequences are so severe, especially for the students who 

are left institutionally homeless, with credits that are difficult to transfer. These 

consequences can be devastating, inflicted most severely on the people who are most 

innocent in the institution's failure. It is not an action to be taken lightly and only as 

a last resort. Another consequence of revoking accreditation is that the accreditor will 

most likely be sued. When accreditation is revoked, the due process procedures of 

accreditors usually result in an outcome that is well documented and clearly justified. 

However, loss of institutional accreditation is usually a death sentence and schools 

often fight for their survival. Middle States recently revoked accreditation from one 

of its member institutions that had a great history and a wonderful mission, but had 

fallen on hard times financially. It could no longer demonstrate that it had sufficient 

resources to be sustainable. Accreditation was withdrawn and the institution went to 

federal court and requested a temporary restraining order to block the action. After a 

three-day hearing in federal court, the request for injunctive relief was denied. 

Middle States requested a summary judgement upholding its actions, which after the 

submission of briefs from both parties, was granted. The institution appealed the 

judge's ruling. After submission of briefs from both sides, the appeal was denied. 

The accreditor's action was upheld but it spent nearly a quarter of a million dollars in 

defending itself. As accreditors continue to follow the will of Congress and be more 

proactive and aggressive, costly litigation is an inevitable result. This will drive the 

cost of accreditation higher, making liability coverage more difficult to acquire, 

driving up college tuition as higher accreditation costs are passed on to the 
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Pruitt 9 

institutions. I urge Congress to take steps that will mitigate the unavoidable flood of 

lawsuits that will surely occur. 

Thank you. 
24 

Chairwoman FOXX. Thank you, Dr. Pruitt. Mr. Miller, you are 

recognized for 5 minutes. 

TESTIMONY OF BEN MILLER, SENIOR DIRECTOR FOR POSTSECONDARY EDUCATION, CENTER FOR AMERICAN 

PROGRESS 

Mr. MILLER. Thank you, Chairwoman Foxx and Ranking Member 

Scott for the opportunity to testify today. 

Every year, students and taxpayers invest billions of dollars in 

higher education, seeking better lives and a stronger economy. We 

trust a triad of States, the Federal Government, and accreditation 

agencies to ensure those investments pay off. The triad is failing 

us. 

While no part of the triad is blameless, accreditors have either 

stood by or acted with molasses-like speed while taxpayer dollars 

and student dreams got wasted. Every campus of Corinthian Colleges maintained accreditation until the day it closed or was sold, 

even as allegations of falsified job placement rates, altered grades, 

and inadequate education piled up. 

There are many schools of all types today that can proudly advertise their accreditation status while producing high levels of borrowing, low completion rates, and poor repayment outcomes. 

Do accreditors know about these problems? Yes. They wag their 

fingers and sometimes issue threats. They rarely pull the plug. 

Everyone in this room pays for this inaction. As taxpayers, we 

all pay when Federal loans are forgiven due to fraud or aid does 

not become a degree. 

Today, we are fortunate to hear from two of the most forward 

thinking accreditation agencies, but remember, the good things 

they are doing are voluntary. Many other agencies have not followed their lead. 

For example, WASC has required the publication of accreditation 

team reports for nearly a half decade. No other accreditor has done 

so. ACCSC requires independent verification of outcomes data. The 

other large national agency blew off the need for this action until 

its existence was threatened. 

And, just as the accreditation system contains WASC and 

ACCSC, so, too, did it have the Accrediting Council for Independent Colleges and Schools. ACICS served as a safe haven for 

troubled colleges fleeing scrutiny from other accreditors. Its quality 

assurance work was literal box checking. 

ACICS’ results were grim. It approved over a dozen schools that 

faced Federal or State investigations for wrongdoing. Those schools 

received $5.7 billion in Federal aid over just three years. 90 times 

ACICS named one of those campuses to its Honor Roll for an excellent understanding of the accreditation process. 

These problems persist because we have created a system of 

quality assurance that says success means doing the things you 

said you’d do, not the actual results achieved. 

So, what can Congress and accreditors do? First, Congress should 

make the system much more outcomes focused. Accreditors should 

judge schools primarily on the results of their students, and the 

Federal Government in turn should judge accreditors by how well 

they do, not just whether they have mandated standards in place. 

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25 

Second, the system needs to get a lot tougher on lower performing colleges. Institutions with abysmal completion rates or no 

evidence of learning need stricter scrutiny. They should pay much 

more up front for their reviews, giving accreditors resources needed 

for deeper dives. A greater focus on the bottom should also come 

with an easier approval process for schools at the top. 

Third, we need new alternative approaches to quality assurance 

that allow new providers with verifiably outstanding performance 

to access Federal aid. 

Here is the Center for American Progress’s idea for how that 

could work. Private third parties would propose indicators of student outcomes and financial health a program would have to meet 

in order to access Federal aid. Only the best should be able to clear 

the bars. 

The Federal Government would then verify whether the programs seeking aid meet those standards and take action to approve 

or deny a program accordingly. 

This approach marries the best elements of the current system 

while fixing many of its flaws. It preserves a role for third parties 

that have experience judging programs. It solves conflicts of interest by separating out who sets standards from who determines eligibility, and it leverages data the Federal Government already 

holds on earnings and loan outcomes to minimize the need for additional data collection. 

A high quality college education can unlock a lifetime of benefits, 

but low quality programs can cause financial ruin, especially if 

Federal student loans are involved. Students and taxpayers today 

trust accreditation as a stamp of quality that their money will be 

worth it. We have a ways to go to ensure that is true. 

Thank you very much, and I look forward to your questions. 

[The statement of Mr. Miller follows:] 

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Written Testimony of Ben Miller, Senior Director Postsecondary Education at the Center for 

American Progress 

"Strengthening Accreditation to Better Protect Students and Taxpayers" 

U.S. House of Representatives Education and the Workforce Committee 

April 27, 2017 

Dear Chairwoman Foxx and Ranking Member Scott, thank you very much for the opportunity to 

testify before you today about the importance of higher education accreditation in protecting 

students and taxpayers. 

Every year, millions of American students enroll at institutions of higher education. Most are 

seeking better economic opportunities for themselves and their families in addition to the 

knowledge they need to become engaged members of society. 

Regardless of whether they are attending the wealthiest college in the country, their local 

community college, or a beauty school down the street, these students are betting their futures 

on a quality education. That bet, in turn, depends upon a triad of oversight from state 

governments, the federal government, and private nonprofit agencies, all working in concert to 

guarantee quality. 

This triad is supposed to represent the best of both public-private partnerships and federalism. 

Unfortunately, a game of buck-passing amongst these three sectors has allowed a range of 

problematic institutions to continue taking money from students and taxpayers, and it has failed 

to encourage the innovations we need to make sure our postsecondary education system keeps 

up with the needs of a changing economy. 

While no part of the triad is without blame, accreditors must do better. They lack sufficient 

resources for meaningful accountability, do not always pay enough attention to student 

outcomes, and are unnecessarily opaque in their work. Though there are examples of good 

practices, accreditors often fail to follow best practices from peer agencies. Admittedly, 

Congress has done accreditors few favors by failing to grant the flexibility and protection needed 

to help these agencies operate better. 

There is no simple fix for these fundamental challenges. Accomplishing the dual goals of 

consumer protection and innovation requires reforming the current system of accreditation, as 

well as exploring alternative ways of conducting quality assurance. I will touch on both briefly. 

Reforming the current system 

Building an accreditation system that better serves students will require the following six 

reforms: 

1. Adopting consistent language 

2. Increasing resources for review of problematic colleges 
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3. Focusing more on student outcomes 

4. Addressing tensions between improvement and accountability 

5. Requiring more transparency 

6. Allowing for greater flexibility 

Adopting consistent language 

An accreditor's action against an underperforming institution can serve as a valuable warning 

sign to students and policymakers. Unfortunately, the current system lacks universal definitions 

and terminology necessary to help students and even government officials understand the 

extent of a problem when it occurs.' When some accreditors are close to the point of terminating 

an institution's approval, they place the college on "show cause." Other accreditors put the 

college on probation. Some offer warnings, others do not. 

Even when accreditors use the same terminology, the true meaning can be very different. Some 

accreditors remove most show cause orders within six months. Others may keep them in place 

for two years or longer. 

While the Council for Regional Accrediting Commissions (C-RAC) eased this problem 

somewhat by adopting common definitions among the regional accreditors,2 more must be 

done. In particular we recommend two changes: 

• Regionals and nationals should adopt common terminology and definitions. This 

includes the same progression of actions (e.g., warning, then probation, then show 

cause). 

• Accreditors should establish minimum timeframes for sanctions. Placing an 

institution on show cause due to serious problems only to remove that status in six 

months raises serious questions about how meaningful the oversight was in the first 

place. 

Increasing resources for review of problematic colleges 

In calendar year 2013, the 12 main regional and national accreditors spent just $75 million on 

quality assurance.3 That means every $1 spent by accreditors grants access to nearly $1,700 in 

1 Antoinette Flores, "Watching the Watchdogs: A Look at What Happens when Accreditors Sanction 

Colleges" (Washington, DC: Center for American Progress), availble at 

https:/lwww. americanprogress. org/issues/ed ucation/reports/20 16/06/21/139529/watching-the-watchdogs/ 2 Doug Lederman, "Getting Their Act(ion)s Together," Inside Higher Ed, April 20, 2014, available at 

https :1/www. insidehighered .com/news/20 14/04/1 0/regional-accreditors-alig n-their-actions-and-

~rocedures-they-use-impose-them 

Antoinette Flores, "Getting What We Pay for on Quality Assurance" (Washington, DC: Center for 

American Progress), available at 

https:l/www.americanprogress.org/issues/education/reports/2017/03129/427955/getting-pay-qualityassurancel 

2 
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federal financial aid. 4 As a result of this low spending, the 12 main agencies employed fewer 

than 400 people to oversee 7,000 institutions and campuses.5 

Agency spending per institution also varies widely. For example, the Western Association of 

Schools and Colleges, Senior Commission (WASC) spends over $30,000 per school per year. 

The Higher Learning Commission (HLC}, spends only about one-third of that amount.6 

To some extent, low spending is an intentional feature of the accreditation system. These 

agencies rely on volunteer peer reviewers to visit an institution and assess its compliance with 

standards. But a largely volunteer system with little funding is not up to the task of safeguarding 

$120 billion in annual federal financial aid. 

Insufficient revenue for quality assurance has numerous ramifications. First, it means agencies 

have to conduct detailed reviews of massive institutions of higher education in short periods of 

time. The average site visit, for example, lasts less than a week. 7 Second, a shortage of 

professional staff may mean that accreditors struggle to balance competing demands from 

multiple problematic institutions. Third, the lack of resources creates a substantial imbalance 

when problems arise. Schools that receive millions in federal aid that do not like an accreditor's 

findings can take them to court and potentially bleed them dry, forcing a settlement. 

Several reforms would improve accreditors' resources: 

• Greater attention to accreditor resources in federal reviews. Federal reviews of 

accreditors are already supposed to look at an agency's resources but tend to be 

relatively cursory. These should be strengthened to examine whether the ratio of staff to 

institutions overseen is too low, as well as whether spending per school is sufficient. 

• Increase fees for problematic colleges. Accreditors currently set their dues and fees 

schedules based upon factors such as the size of a school or its level of spending. None 

of them charge higher fees upfront for problematic colleges to reflect the higher costs 

required to closely review an institution with worrisome outcomes. Accreditors should 

work together to come up with performance-based fees that increase charges for 

problematic colleges (reflecting ability to pay) so that these agencies have the resources 

they need to devote more time to these schools. 

• Provide greater legal protections for accreditors. One way to equalize the resource 

imbalance between schools and accreditors is to give the agencies some legal 

protections that lessen the risk of lawsuits when they act. These protections should be 

structured in a way that respects institutional due process rights while also preventing 

teams of high-priced lawyers from undermining the quality assurance system. 

4 1bid. 

5 1 bid. 6 1bid. 

7 Higher Learning Commission, "Comprehensive Evaluation Visit," available at 

https://www.hlcommission.org/Accreditation-Processes/comprehensive-evaluation-visit.html; Accrediting 

Commission of Career Schools and Colleges, "Preparing for the On-Site Evaluation," available at 

http://www.accsc.org/UploadedDocuments/2016%20February/Biueprint%20for%20Success%20-

%20Preparing%20for%20the%200n-site%20Evaluation%20Finai%20Web%20030216.pdf 

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Focusing more on student outcomes 

Where accreditation agencies can offer valuable expertise that state and federal governments 

lack is in evaluating learning and academic outcomes. But too often, efforts to assess learning 

get bogged down in studying the bureaucratic processes on campus, and pay insufficient 

attention to actual student achievement. 

In addition, learning cannot be the only indicator of quality assessed. After all, how meaningful is 

what people learned if no one graduates? Or if few students can repay their loans? 

There have been some positive developments in this area, but they remain insufficient. For 

starters, all major national accreditation agencies have minimum thresholds on some measure 

of student outcomes, such as graduation and completion rates, exam pass rates, and job 

placement rates. But these thresholds are often based on a low bar that almost all institutions 

can pass--such as requiring programs and institutions to demonstrate a job placement rate of 

just 60 to 70 percent.8 This approach does not question whether overall results are good 

enough.9 

Second, regional accreditors recently announced they plan to study their institutions with low 

graduation rates. 10 While this process is encouraging, it is still in its early stages and so it is too 

early to tell whether it will amount to any real change. 

Certainly, other parts of the triad share the blame. The current standards for institutional 

performance on federal loan debt are too weak. Of the 593,000 students who entered 

repayment on a federal loan in 2013 and defaulted within three years, just 619 attended one of 

the 10 colleges at risk of losing access to financial aid due to high default rates.11 Judging 

colleges only on default fails to capture other debt problems, such as inability to repay loans, 

and are too easily gamed. If we really want accreditors to do a better job with the lowest 

performing schools, Congress and the Education Department must first act to remove the 

schools whose financial aid results are unacceptable. 

Below are policies that Congress and accreditors could enact to increase attention to student 

outcomes: 

8 U.S. Department of Education, "National and Programmatic Accreditors Summary of Student 

Achievement Standards Summary," available at https://www.ed.gov/accreditation 9 1bid. 

10Andrew Kreighbaum, "Tougher Scrutiny for Colleges With Low Graduation Rates," Inside Higher Ed, 

September 21, 2016, available at https://www.insidehighered.com/news/2016/09/21/regional-accreditorsrefocus-institutions-low-grad-rates 

11 Ben Miller and CJ Libassi, "Sharing the Risk: A Plan for Colleges to Participate in the Costs of Student 

Loan Failure" (Washington DC: Center for American Progress), available at 

https:l/www .americanprogress.org/issues/education/reports/20 16/12/19/295187/sharing-the-risk/ 

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• Require accreditors to set minimum outcomes standards. Accreditors should work 

together to set minimum performance bars for outcomes, especially around completion 

and job placement. This should include common definitions, and does not need to be 

bound by existing formulas. These minimums must be set in a rigorous way that does 

not reinforce mediocrity for example by simply setting benchmarks at one standard 

deviation below the median. 

• Increase federal minimum requirements for student financial aid. Congress should 

consider whether existing student loan performance thresholds and metrics are of 

sufficient rigor. 

Addressing tensions between improvement and accountability 

By and large, accreditors see their primary role as helping institutions improve. However, the 

role they have come to play in the American higher education system demands that they accept 

responsibility for holding colleges accountable. Many times in the past few years, institutions of 

higher education have faced investigations from states' attorneys general or federal agencies. 12 

On other occasions, accreditors themselves have turned up evidence of troubling practices 

related to job placement rates, among other areas. 13 Either way, accreditors are not in the dark 

when these investigations start. Yet many accreditors struggle to take meaningful action when 

these problems occur. They may ask institutions about the investigations and institute some 

additional monitoring, or they may request institutions address a problem and then give them 

repeated opportunities to come into compliance. 

Failing to act when problems are first identified is a lost opportunity to protect students and 

taxpayers. A more proactive approach to red flags could possibly have prevented the flow of 

millions in federal dollars to institutions serving their students poorly. Accordingly, accreditation 

agencies should be held accountable if they fail to address issues that are -- or should be -- on 

their radar. 

Two changes would help with this improvement versus accountability tension: 

• Hold accreditors responsible for problems they fail to identify. The accreditor 

review process should look at instances where institutions approved by an agency faced 

investigations or other negative actions from other members of the triad. This should be 

limited to topics covered by an accreditor's standards (e.g. recruitment practices but not 

"slip and fall" problems). 

• Address challenges with institutions that have common ownership and multiple 

accreditors. Oversight of national college chains with accreditation through multiple 

agencies can fall through the cracks. A problem turned up at one agency may not be 

shared with another. And agencies may fail to look at what practices are driven by the 

12 Ben Miller, "ACICS Must Go" (Washington DC: Center for American Progress), available at 

https :I !www .american progress. org/issuesleducationlreports/20 16/06/06/138826/acics-must-go/ 13 Letter from Mary Gust to Jack Massimino, August 22, 2014, available at 

https:l/www.republicreport.org/wp-content/uploads/2014/081EdCoColtr822.pdf 

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corporate headquarters. This should be fixed by ideally moving to a system where 

commonly owned institutions do not have different accreditors. Until then, accreditors 

should conduct joint reviews--including of corporate headquarters--when they have 

institutions that receive approval through multiple agencies. The current proposal to sell 

the Education Management Corporation is an opportunity for accreditors to conduct a 

more centralized review of a large company with multiple accreditors. 

Requiring more transparency 

Accreditation agencies' decisions affect the flow of billions of taxpayer dollars. Accordingly, the 

public and policymakers should have a right to see the actual work conducted by these 

agencies. This includes self studies, team reports, and reasons for sanctioning or removing a 

sanction from a college. 

To its credit, WASC instituted a policy in June 2012 to publish these documents for the schools 

it oversees. 14 Yet in the nearly half decade since, no other major accreditor has followed its 

lead. Similarly, while many accreditors have released a list of their actions and occasionally 

provide some details for the steps taken, it was not until recently that the Department of 

Education began requiring the reporting of this information that it became available in a 

systematic way. 

Given the lack of action on this front despite years of interest, Congress should step in and 

require the publication of these accreditation documents. Many accreditors and institutions will 

likely resist, arguing college officials and their own staff and volunteers will not be candid without 

confidentiality, but this is a ruse. 15 For example, a review of several team reports from the most 

troubled accreditation agency-the Accrediting Council for Independent Colleges and Schools 

(ACICS) did not reveal candor. It showed a rudimentary "check-the-box" approach to review that 

could have been stopped years ago had policymakers been aware of the problem 16 

Allowing for more flexibility 

Many of the recommendations above call for greater consistency and standardization around 

terminology, formulas, and minimum performance thresholds for accreditors. But other parts of 

the accreditation system would benefit from greater flexibility. This is true of not just how 

accreditors review colleges, but also what level of access they grant to financial aid, and how 

the Department of Education reviews them. 

The accreditation process could pursue differentiation in several ways. 

14 WASC Senior College and University Commission, "Public Disclosure of Accreditation Documents and 

Commission Actions Policy," available at https:/lwww.wscuc.org/content/public-disclosure-accreditationdocuments-and-commission-actions 

15 Council for Higher Education Accreditation, "Position Paper: Regulatory Relief for Accreditation," April, 

2017, available at http://www.chea.org/userfiles/Occasionai%20Papers/Regulatory-Relief.pdf 16 Ben Miller, "ACICS Must Go." 

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• Differentiated institutional reviews. Accreditors should provide a path where highperforming institutions face streamlined reviews, with the resources freed up from this 

process redirected toward greater scrutiny around colleges with worrisome results. 

Several accreditors are currently pursuing different paths for institutional reviews. 

• Differentiated access to federal financial aid. Current accreditor approval for federal 

financial aid is binary. Institutions can either access all parts of the aid programs or 

nothing. This makes removal of federal student aid essentially a nuclear option that 

would likely force most schools to close. Accreditors should have the ability to grant 

different levels of access to federal aid. For instance, they could give new providers time 

to prove themselves by first allowing them to receive only grants, then greenlight them 

for loans if all has gone well. (This chronology would reflect the greater risks to students 

that come with debt.) Similarly, accreditors could first deny access to loans from failing 

colleges as a way of easing them out of the system without causing immediate closures. 

Granting accreditors the authority to pursue other changes at colleges--such as 

replacing leadership--could be another way to more effectively drive improvement. 

• Differentiated approval of accreditors. The current system fails to reward accreditors 

who want to be more rigorous. In fact, there are several instances among national 

accreditors of colleges seeking out weaker agencies after facing challenges from 

stronger ones. 17 When it reviews accreditors, the federal government should set up a 

different and less onerous track for agencies that have demonstrated that they conduct 

rigorous oversight and that the institutions they approve have strong outcomes. 

Establishing an alternative system of quality assurance 

Improving the current system is not enough. There is substantial experimentation outside the 

traditional system of higher education that may merit access to federal funding. Experimenting 

with new ways of assessing the quality of these providers could provide lessons for improving 

the existing system without creating too much disruption for the millions of students and billions 

of taxpayer dollars currently tied to accreditation. New models of quality assurance could seek 

ways to reduce the burden of quality assurance while still having strong protections for students. 

An alternative system should be predicated on a streamlined approval process available only for 

educational providers that can demonstrate exceptional student outcomes and financial health. 

It should be voluntary and not replace the existing system. This alternative should preserve 

what the current system does exceptionally well. It should also seek new approaches to solve 

some of the most pressing challenges of existing accreditors-the inconsistent presence of 

clear outcomes standards, the tensions between accountability and improvement, and 

difficulties in assessing the accuracy of claims made by institutions. 

Here is how CAP proposes accomplishing the goals above. First, the alternative system would 

continue to rely upon private third parties to determine appropriate standards for student 

17 Ben Miller, "ACICS Must Go." 

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performance and financial health. These actors would be called "standard setters." Much like 

today's accreditors, these bodies would submit an application to the U.S. Department of 

Education outlining the measures that they believe are necessary to deem an educational 

provider of sufficient quality for accessing federal financial aid. These standards would have to 

consist of quantifiable measures with clear thresholds. This includes outcomes such as student 

loan repayment, completion, job placement, and earnings. 

This system would also require greater upfront financial protections for all new providers. Those 

without a track record of success would be required to post either a letter of credit or a surety 

bond to ensure that taxpayers and students can be made whole if things go wrong. Upfront 

financial commitments also serve as a market test to judge whether private actors think a 

program is worth an investment risk. 

Admittedly, measures such as completion rates and earnings do not represent the full range of 

positive outcomes that can and should come from a high-quality education. These items, 

however, represent the minimum information the federal government must have to have 

confidence that allowing a provider's students to borrow loans and receive grants will not lead to 

unwanted results down the line. 

While we rely on third parties to set standards, the rest of the quality assurance work would be 

handled by the federal government. This includes collecting performance data from institutions, 

verifying that information is accurate, and approving providers that meet standards and denying 

or removing eligibility for those who do not. 

Having the federal government handle verification and enforcement improves on the current 

system in several ways. First, the federal government can already access much of the 

necessary information--such as earnings and loan outcomes--while accreditors cannot do so 

without additional data collection. Second, the federal government possess greater resources 

than accreditors, which gives it greater ability to verify that institutions are telling the truth about 

outcomes. Finally, having the federal government ultimately make the decision about approving 

or denying providers removes a major conflict of interest in the existing system whereby 

accreditors strive to both help colleges improve and hold them accountable. 

All told, this alternative system would marry the best of both worlds, with a role for private 

actors, and with increased rigor and oversight from the federal government. Additional details 

for our proposal can be found in "A Quality Alternative," which the Center for American Progress 

published in October 2016. 18 

18 Ben Miller, David A. Bergeron, and Carmel Martin, "A Quality Alternative: A New Vision for Higher 

Education Accreditation" (Washington DC: Center for American Progress) available at 

https :/iwww .a mericanprog ress .org/issues/education/reports/20 16/1 0/06/14 5152/ a-quality-alternative-anew-vision-for-higher-education-accreditation/ 

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Conclusion 

For students and families, a college education is likely the second biggest purchase they will 

make after a home. Taxpayers, meanwhile, invest over 120 billion a year for educational options 

beyond high school. The sums of money involved demand that we have a strong quality 

assurance system that ensures funds go to high-quality educations. 

The onus for quality assurance cannot fall entirely on accreditors, but that does not mean they 

are blameless, either. Accreditors must be expected to act when problems arise. They must do 

a better job working together to raise standards, promote consistency, and increase 

transparency -- or have Congress step in if they cannot. 

The steps above will make our higher education quality assurance system stronger and more 

meaningful. But they cannot be a replacement for action elsewhere in the triad. The federal 

government, especially, cannot back down from its efforts to hold institutions accountable 

through consumer protection rules. And Congress, too, must ask whether the current system of 

cohort default rates and other tools are sufficiently rigorous. In other words, accreditation 

improvements are a necessary, but not sufficient, step in guaranteeing all students can access 

a high-value postsecondary education. 

9 
35 

Chairwoman FOXX. Thank you. Dr. McComis, you are recognized 

for 5 minutes. 

TESTIMONY OF MICHALE S. McCOMIS, EXECUTIVE DIRECTOR, 

ACCREDITING COMMISSION OF CAREER SCHOOLS AND COLLEGES 

Mr. MCCOMIS. Good morning, Madam Chair, Ranking Member 

Scott, and members of the committee. My name is Dr. Michale 

McComis, and I’m the Executive Director of the Accrediting Commission of Career Schools and Colleges. 

I’m honored to appear before the committee this morning to discuss accreditation, the contributions it makes to the quality of education in this country, and the ways it might be improved. 

Accreditation has been relied upon for educational quality assessment purposes by the Federal Government for over six decades. Although accreditation has come under increased scrutiny by policymakers, accreditation can and should continue to serve in its 

gatekeeping capacity, albeit in a strengthened form. 

Accreditation employs a collaborative approach within a peer review network that identifies best practices and assesses how well 

an institution meets those best practice standards. It is not nor can 

it be a one-size-fits-all system with rudimentary metrics that do 

not take into account diverse objective and qualitative elements of 

an institution’s operations and success. 

Accreditation derives its strength from four essential pillars that 

are built upon a foundation of peer review, standards or best practices, self-evaluation, ongoing institutional improvement, and accountability. 

Accreditation serves a myriad of institutions accredited by agencies with different standards and expectations of student outcomes. 

This is both appropriate and necessary, and should be viewed as 

a strength to our system. 

But Congress should consider changes to the Higher Education 

Act that will strengthen accrediting agencies, however, without injecting undue Federal intrusion into the learning process or that 

might serve as a barrier to innovation. 

Judgments regarding the effectiveness of accreditation should not 

lose sight of the fact that the oversight of higher education is a 

shared responsibility amongst the triad partners, accreditors, 

States, and the Federal Government, working together, which 

strengthens the existing oversight system. 

So then, how can accreditation be strengthened through the 

Higher Education Act? The following are some suggestions that I 

hope the committee might consider. 

Outcomes. Outcome measures are not a one-size-fits-all solution 

and should not be mandated by Congress or the U.S. Department 

of Education. However, accreditors must define the right set of 

measures and metrics to evaluate institutional and student success. 

At ACCSC, we measure rates of graduation, employment, licensure, and required learning and competency assessment. 

Transparency. Accreditors should be expected to provide useful 

disclosures of the accreditation actions taken that can help the genCEWDOCROOM with DISTILLER

36 

eral public make informed decisions about the quality of an institution or program. 

Differentiation. Allow for differentiated levels of accreditation 

which could place schools in different categories and move beyond 

binary decisions regarding quality. 

Credit hour definition. Seat-time requirements for funding programs do not preserve academic integrity nor promote competencybased assessment, and as such, the Federal definition of a ‘‘credit 

hour’’ and the complex clock hour conversion formulas should be removed from the Federal regulations. 

Accreditation area of focus. It may be useful to expect accreditors 

to focus more narrowly on the types of institutions accredited in 

order to ensure a strong peer review foundation and solid measures 

related to outcomes and accountability. 

Transfer of credit. Accreditors should be expected to have and enforce standards that prevent institutions from unfairly or 

unjustifiably denying credit transfers. 

Change of accreditors. Institutions that have been subject to a 

monitoring sanction from one accreditor should not be allowed for 

Federal financial aid purposes to seek a new accreditor for some set 

period of time after the sanction has been lifted. 

Lastly, indemnification. Given the high stakes associated with 

the loss of accreditation and the ensuing loss of access to Title IV 

student financial aid funding, the Federal Government should consider affording accreditors some protection as a means to prevent 

specious and costly lawsuits from being brought against accrediting 

agencies. 

I’ve also included other areas for the committee to consider within my written testimony, and I hope the committee finds these recommendations useful as it goes about its work, and I’m happy to 

provide additional details regarding each. 

Thank you for the opportunity to testify before the committee 

this morning, and I look forward to continuing the dialogue on 

ways in which we can work together to strengthen our accreditation system. Thank you. 

[The statement of Mr. McComis follows:]22-32 

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Testimony of Dr. Michale S. McComis, Executive Director, 

Accrediting Commission of Career Schools and Colleges (ACCSC) 

Before the 

House Committee on Education and the Workforce 

For the Hearing 

"Strengthening Accreditation to Better Protect Students and Taxpayers" 

April25, 2017 

Madame Chair and members of the Committee, my name is Dr. Michale McComis and I 

am the Executive Director of the Accrediting Commission of Career Schools and Colleges 

(ACCSC), a private, non-profit independent national accrediting agency recognized by the United 

States Secretary of Education. ACCSC accredits over 650 career- and vocational educationoriented postsecondary institutions that annually serve over 150,000 students throughout the 

United States. ACCSC-accredited institutions offer programs in a diverse array of career and 

technical fields including traditional trades programs such as: plumbing; heating, ventilation and 

air conditioning; and welding; health care fields such as nursing; medical assisting; and dental 

assisting; and in the artisan crafts such as furniture making; preservation carpentry; and wooden 

boat buiiding. 

I am honored to appear before the Committee this morning to discuss accreditation and the 

contributions that it makes to the quality of education in this country as well as the ways in which 

accreditation can be strengthened and improved. 

Accreditation as an education quality assessment mechanism has been the hallmark of 

educational success in this country for over a century and has been relied upon by the federal 

government for this purpose for over six decades. Although accreditation has recently come under 

increased scrutiny by policy makers, accreditation can and should continue to serve in its gate-
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Testimony of Dr. Michale McComis - Accrediting Commission of Career Schools and Colleges 

Committee on Education and the Workforce: Strengthening Accreditation to Better Protect Students and Taxpayers 

April 25. 2017 

Page 2 of II 

keeping capacity, albeit in an enhanced form which I will describe later in my testimony. 

Accreditation employs an earnest and collaborative approach within a peer-review network that 

identifies best practices and assesses how well an institution meets those best practice standards. 

It is not, nor can it be, a one-size-fits-all system with rudimentary metrics that do not take into 

account both subjective and qualitative elements of an institution's operations. 

Accreditation has four essential pillars that are built upon a foundation of peer review. Those 

pillars are: I) standards or best practices, 2) self-evaluation and assessment, 3) on-going 

institutional assessment and improvement, and 4) accountability. 

I. Standards: Through peer review, best practices are established and mandated; 

2. Self-evaluation: Institutions are evaluated internally and externally and assessed as to how 

well they meet standards and can demonstrate success through student outcomes; 

3. On-going Institutional Assessment and Improvement: Expectations of significant and 

on-going institutional assessment and improvement are established; and 

4. Accountability: Institutions are held accountable for compliance with standards and 

outcomes- to include the loss of accreditation -when expectations are not met. 

Accreditation also takes different forms and serves many different kinds of institutions. National 

accreditors, such as the agency I represent, primarily accredit institutions that offer an array of 

career- and vocationally-oriented programs that are mainly non-degree and sub-baccalaureate 

degree with some baccalaureate, master's and doctoral degree programs. Regional accreditors, on 

the other hand, primarily accredit community colleges, 2 and 4 year colleges, and universities that 

offer degree programs in an array of liberal arts and professional fields as well as some non-degree 

and degree programs in vocational fields. Given the wide variety of accredited institutions, it 
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Testimony of Dr. Michale McCornis - Accrediting Conunission of Career Schools and Colleges 

Committee on Education and the Workforce: Strengthening Accreditation to Better Protect Students and Taxpayers 

April25, 2017 

Page 3 of II 

follows that institutions will be accredited by different types of accrediting agencies with different 

standards and different expectations of learning and outcomes. This is both appropriate and 

necessary. However, the differences among accreditors and the types of institutions they accredit 

do not make one type of accreditation "better" than another - the success of any accreditation 

agency is not based on the type of institution accredited but upon the strength of each of the 

fundamental pillars in the agency's system and the strength of the peer review foundation. All 

accreditors - regional or national and regardless of the types of institutions accredited -should 

enforce an accountability-based model that combines rigorous input standards with performance 

outcomes in categories such as student learning, student assessment, and student achievement. 

I recognize that the expectations of accreditors by the federal government are changing, 

such that accreditors are subject to far greater federal oversight than at any time in the past. 

Congress has a vested interest in ensuring that the strength of any accrediting agency is at an 

appropriate level before that agency may be recognized as a gatekeeper to Title IV funds. As such, 

the Congress should seek to enact changes to the Higher Education Act that will responsibly and 

appropriately provide such assurance; however, this should be done without injecting undue and 

inappropriate federal intrusion into the academic processes of higher education. 

Measures relating to performance and results are present in the existing accreditation 

system, although in a variety of forms and not always in easily packaged metrics. However, it is 

the variety of these measures that contribute positively and materially to the strength of our 

decentralized oversight of education in this country. Having said that, however, accreditors must 

do better at defining student achievement outcomes with greater transparency to show how these 

measures are applied so that the public and policy makers can rely on the results of those evaluation 
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Testimony of Dr. Michale McComis- Accrediting Commission of Career Schools and Colleges 

Committee on Education and the Workforce: Strengthening Accreditation to Better Protect Students and Taxpayers 

April 25, 2017 

Page 4 of 11 

processes. Accreditation, as the sector with the principle responsibility for quality assurance in 

higher education, needs to work earnestly toward moving the discussion of accreditation's 

effectiveness from that of skepticism to confidence. 

My sincere hope is that any judgment regarding the effectiveness of accreditation not lose 

sight of the fact that the oversight of higher education, as set forth in current law and regulation, 

is a shared responsibility. Each member of the regulatory triad- state government, accreditor, and 

federal government has an essential role to play in the oversight of institutions. In this regard, 

the Committee should consider several of the recommendations made by the National Advisory 

Committee for Institutional Quality and Integrity (NACIQI) in its April20 12 Report, chief among 

them the need to clarity and to articulate common understandings about the responsibilities of each 

member of the triad, and foster increased communication among triad actors to achieve greater 

commonality across the quality assurance/eligibility enterprise. By continuing to work together in 

partnership with the various organizations within the regulatory triad, I believe we can strengthen 

the existing oversight system while retaining the positive qualities of accreditation and the 

expertise and nuance that peer-review represents and delivers. 

Moreover, for the sake of higher education's advancement, the higher education 

community- including accrediting agencies must be allowed to adapt and innovate in order to 

accommodate the diversity of students, student preferences, and learning styles. This supports 

reasons why there is not, and should not be, a one-size-fits-all system of accreditation. As higher 

education takes a more diverse shape, accrediting agencies and the peer review process should 

foster avenues for institutions to develop and deploy innovative approaches that both increase 

access to higher education and fundamentally change the manner in which education is delivered. 
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April 25, 2017 

Page 5 of II 

Ensuring the quality and integrity of these programs without undue regulatory burden must also 

remain a paramount goal. 

An Example of Federal Overreach in Accreditation: 

The federal definition of a credit hour, however, is an example of undue regulatory burden 

and intrusion into the academic process by the federal government that stunts innovation. In my 

experience, competency-based models of student assessment are superior to "seat-time" models of 

student fulfillment, particularly in "hands-on" fields such as welding or nursing. But, by creating 

the federal definition of a credit hour, the U.S. Department of Education federalized a basic 

academic concept and developed a complex and confusing system and then required accreditors 

to enforce this regulation. This serves as a prime example where accreditation has been co-opted 

to enforce federal overreach and blurs the lines between accreditation's self-defined quality 

assurance and institutional improvement role and the quasi-surrogacy federal enforcement role 

that the US Department of Education has foisted upon accrediting agencies. Moreover, the federal 

definition of a credit hour unintentionally serves as a barrier to innovation in educational delivery 

models such as a movement to competency assessment. Although the Department's position on 

"direct assessment" is a step in the right direction, it coexists in federal regulation with the federal 

definition of a credit hour, which causes uncertainty on how to move forward with more innovative 

models. Respectfully, the Congress should look at ways to create a focus on what students can do 

and in creating pathways that enable student to earn "badges" and engage in stair-step programs 

and life-long learning. 
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Aplil 25. 2017 

Page 6 of II 

Areas to Consider: 

So then, how can accreditation be enhanced through the Higher Education Act? The 

following are some suggestions for the Committee to consider: 

Macro Areas: 

I. Outcomes: Outcomes measures are an important part of the assessment paradigm for higher 

education institutions. But, outcomes measures are not a one~size-fits-all solution and while 

the Congress should expect accreditors to have rigorous outcomes measures, the measures 

themselves should be determined by the accreditors based upon the types of institutions 

accredited. Accreditors must find and define the right set of measures and metrics to evaluate 

institutional and student success. While program-level rates of graduation and employment 

work well for the types of institutions accredited by my agency, those same measurements may 

not be as appropriate in other types of institutions. Moreover, outcomes measures by 

themselves are not a panacea and alone cannot provide a sole assessment of the quality of an 

institution or its programs. Input standards are an equally important part of the assessment 

paradigm and serve to illustrate why accreditation is an important part of the higher education 

regulatory landscape. Outcomes measurements work best when complemented with rigorous 

input standards (e.g., standards pertaining to educational administration; curriculum design, 

development, and evaluation; faculty qualifications; learning resources; facilities; student 

services; student learning; student assessment; and other areas that contribute to quality 

education programs). 
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Page 7 of II 

Generally, outcomes measures should be a reflection of how well students learn and how well 

an institution performs relative to standards (i.e., best practices) and should minimally require 

institutions to assess: 

• Student learning and competency attainment; 

• Rates of retention or graduation; 

• Rates of employment and certification/licensure exam pass rates in career and 

professional programs and measures related to "employability"! in other program areas; 

and 

• Measures of student, graduate, and employer satisfaction. 

These kinds of outcomes taken together with an assessment of an institution's adherence to 

input standards provide the tools necessary to assess quality and value. 

2. Accreditation Area of Focus: It may be useful to expect accreditors to have a more focused 

scope regarding the types of institutions accredited as a means to ensure a strong peer-review 

foundation. This is known as the "bucket" approach whereby types of institutions are grouped 

into buckets with an accreditor that is focused on that specific type of institution e.g., careerand vocationally-oriented institutions, community colleges, liberal arts colleges and 

universities, research universities, etc. This approach may allow for better peer-to-peer 

evaluation and bring about better measures related to outcomes and accountability. 

3. Differentiation: An additional approach to consider to allow for differentiated levels of 

accreditation which could place schools in different categories. The primary purpose of 

1 By "employability" I mean assessments made by graduates and employers about how well the graduate was prepared to enter the 

workforce based on the education received. This could serve as an appropriate outcomes measure for students pursuing education 

in many liberal arts fields. 
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differentiated accreditation is to allow accreditors to continue to fulfill their traditional role of 

working with schools toward continuous improvement goals and meeting minimum standards 

while also serving as gatekeepers to various federal funding programs. Differentiated 

accreditation could allow for an institution to move in and out of eligibility for funding 

programs, which may be a better option than the "all or nothing" binary system that the Higher 

Education Act acknowledges and that the ensuing regulations currently employ. However, an 

accreditor could determine that a school can maintain its accreditation while working toward 

improvement, but at a "different-level" of approval than another accredited school approved 

at a higher level. This different level of approval could alter, limit, or suspend the federal 

financial aid available to students to use at that institution. This approach preserves a school's 

ability to regain full eligibility for federal financial aid while also not putting more students 

and tax dollars at risk at underperforming institutions. This type of differentiation of 

accreditation can also easily tell students how well a school is doing. 

4. Transparency: Accreditors should provide useful information regarding the accreditation 

actions taken by the agency that can help the general public make informed decisions about an 

institution or program. 

5. Transfer-of-Credit: Accreditors should have and enforce standards that prevent institutions 

from unfairly or unjustifiably denying credit transfer. This serves the best interest of students 

and represents a better use of federal tax dollars. Congress should expect accreditors to require 

of their accredited institutions transfer of credit policies that do not discriminate and which are 

fair and balanced. 
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6. Credit Hour Definition and Clock Hour Conversions: Seat-time requirements for funding 

programs do not preserve academic integrity nor promote competency assessment and as such 

the federal definition of a credit hour and the complex clock-hour conversion formulas should 

be removed from the federal regulations. If accreditors are going to be the purveyors of 

educational quality assessment, then accreditors should be given the discretion necessary to 

define the elements that go into the assessment paradigm. 

7. Changing Accreditors: Institutions that have been subject to a monitoring, Show 

Cause/Warning Order, or Probation Order from one accreditor should not be allowed, for 

federal financial aid purposes, to seek a new accreditor for some set period of time after the 

sanction has been lifted (e.g., three years). When institutions "run" from one accreditor's action 

to a clean slate with another accreditor, public interest is not served because applicants and 

parents are not aware of the his tory of performance at that schoo I. 

8. Indemnification. Given the high stakes associated with the loss of accreditation and the 

ensuing loss of access to title IV student federal financial aid funding, institutions feel as if 

there is no choice but to take the accreditors decision to the courts. This is an exceedingly 

costly process and can cause accreditors not to take swift and decisive action for fear of being 

dragged through painful and exceedingly costly litigation. Given the federal government's 

reliance and dependency on accreditation and the gatekeeping role that accreditation plays, the 

federal government should afford accreditors some protections as a means to prevent specious 

lawsuits from being brought against accrediting agencies. Accrediting agencies simply cannot 

afford to defend against multiple litigation processes (e.g., legal fees, litigation expenses, 

liability insurance premiums, human resources costs, opportunity costs, etc.). 
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Apri125, 2017 

Page lOofll 

Micro Areas: 

1. Appeals Process: The last reauthorization of the Higher Education Act yielded several 

significant changes to the process that accreditors must enact with regard to the appeal of an 

adverse accreditation decision. While I believe the Congress was well intentioned, the ensuing 

regulations have created a far more complex and cumbersome process that has not, in my 

experience, yielded greater due process for institutions. I suggest the Committee review the 

history of legislative intent and regulatory changes in this regard and consider reverting back 

to the pre-2008 requirements. 

2. Substantive Changes: The Committee should review the provisions that permit aecreditors to 

visit only a "representative sample" of additional locations if an institution operates more than 

three additional locations and that allow an institution to establish additional locations without 

prior approval from its accreditor. In my experience, growth of an institution, to include the 

addition of geographically distant campuses, should require greater oversight, not less. 

Accreditors should be required to visit and evaluate fully each campus or location where 

federal Title IV financial aid dollars may be spent by students. 

Conclusion: 

It is my hope that the Committee finds these suggestions to be a useful addition to the 

discussion regarding accreditation's continued role as a gatekeeper to federal financial aid 

programs and I will be happy to provide additional information as may be requested. 

As the Executive Director of a national accrediting agency, I can attest that my organization 

is keenly aware of the important role that accreditation plays as a gate-keeping entity in the triad 

and understands the impact that that role has on ensuring the reliability of our nation's current 
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higher education oversight system. I am also cognizant that questions remain from policy 

members, regulators, and the general public regarding whether accrediting agencies have been 

living up to our collective responsibilities, and whether or not accreditation has the appropriate 

level of rigor and outcomes assessments. To that end, I look forward to continuing the dialogue on 

ways to strengthen accreditation as a means to ensure that accreditation continues to fulfill its role 

as a gatekeeper to the Title IV federal student financial aid programs. 

Thank you again for the opportunity to testify before the Committee and I happy to answer 

any questions you may have. 
48 

Chairwoman FOXX. Thank you very much. You win the prize for 

coming in under time. I want to thank all of you for your testimony 

and your written testimony is even more expansive, and I am 

grateful for that. 

I will begin the questioning. Dr. Petrisko and Dr. McComis, I believe very strongly in ensuring accountability for hard-working taxpayer dollars. Right now, you and your colleagues are responsible 

for ensuring $128 billion the Federal Government sends out in student aid every year, is flowing only to high quality institutions. 

Can you explain to the committee how the current system of accreditation with the competing roles of quality assurance and continuous self-improvement is able to accurately measure and assure 

institutional quality and protect the taxpayer investment at the 

same time? 

Why should Congress, and more importantly, students and parents, continue to rely on your agencies as reliable authorities for 

the quality of institutions of higher education? 

Dr. Petrisko, I will start with you, and then come to Dr. 

McComis. 

Ms. PETRISKO. Thank you. It is certainly true that accreditors 

balance all the time in our decisions compliance with our standards 

and improvements at the institutions. As we do that, we are very 

keenly aware of the fact that many students have no other institution to attend if they are not able to attend the one where they are 

currently enrolled. 

So, we want to keep institutions strong, make them stronger, address the issues of non-compliance or weakened areas of compliance with a range of actions, not pulling the plug automatically, 

but with special reports, visits, and sanctions when necessary, that 

carry a real threat of loss of accreditation, but it is to maintain operations of those institutions that are supporting students and 

strengthening them at the same time. 

Chairwoman FOXX. Thank you. Dr. McComis? 

Mr. MCCOMIS. I’ll echo what Dr. Pruitt said along the lines of the 

many successes that we can point to, even amidst some of the failures that are present as well. 

Insofar as measuring quality, that is a difficult aspect to bring 

about, so the richness and the diversity, the types of institution, 

and the peer review network that brings about individuals coming 

together to establish those best practice standards, the key being 

really from there setting and establishing those outcome measures 

that really set to reflect what quality can or should be. 

So, for example, again with my agency, because we predominately work with vocational and career oriented institutions, we 

can look to measures like graduation rates. We can look to measures like employment rates. We can look to measures like licensure 

rates. But also, at the same time, acknowledging that in order for 

a welder really to graduate, they need to be competent. So, competency assessment measures as well. 

So, all of that woven together into a system that brings about a 

highly qualified graduate that can contribute to a highly qualified 

workforce is really the main aim here. 

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Chairwoman FOXX. Thank you very much. Dr. Pruitt, I agree 

with you that Thomas Edison is a special university and applaud 

the work your institution has done to serve adult learners. 

Can you discuss how a one-size-fits-all system of Federal accountability might jeopardize the crucial work your institution and 

other institutions like yours are doing to serve contemporary students? Why is it so important that accreditors have the flexibility 

to determine appropriate outcome metrics for ensuring the quality 

of institutions? 

Mr. PRUITT. Thank you, Madam Chairwoman. It is crucially important that metrics be mission sensitive. In the absence of that, 

metrics tend to assess the demographics of the student body and 

not the quality of the institution. 

I come back to my favorite subject about the graduation rates. 

I saw eyebrows raised from my colleague when we had a talk about 

graduation rates in the 20 something percent range, and everyone 

looked like, well, that’s too low. 

Well, it is too low if your assumption is that you’re going to college full-time and expect to graduate in four years. None of the 

17,500 students in my institution—none of them go full-time, none 

of them expect to graduate in four years. My colleague institution 

down the street, Princeton, all of them expect to go full-time and 

graduate in four years. 

So, to create one metric that you try to apply across the board 

to different institutions without regard to the individual mission of 

the institutions or the constituents that they are serving, distorts 

the picture of both institutions. 

So, the dreaded template never works for diverse institutions 

serving diverse populations. It actually misleads the public and 

looks for false indicators of quality that kind of confuses the conversation. That’s why it’s so important to have these indicators referenced to the specific mission of that particular institution against 

similar institutions and peers. 

You can do that. We have a track record of doing that. That’s the 

way it should be done, and not the dreaded template. Thank you. 

Chairwoman FOXX. Thank you very much, Dr. Pruitt. Mr. Scott, 

you are recognized. 

Mr. SCOTT. Thank you, Madam Chair. Dr. Petrisko, should the 

cost of the institution be a factor in accreditation? 

Ms. PETRISKO. Should the cost of the institution be a factor in 

accreditation? I want to say a couple of words about costs. There’s 

a lot of misunderstanding about costs in higher education because 

a lot of people take a look at the sticker price as opposed to the 

net price. 

There is a recent publication of the Association of Governing 

Boards, which I will be happy to put into the record, that talks 

about the reality of what the real costs are of education and what 

the rise in those costs have been. 

So, for example, at the four year institution level publicly, over 

the last 26 years, this is the highest rate of increase, the rate of 

increase of the net price has been about 3.7 percent. For community colleges, it’s been about 1 percent a year, and for the private 

institutions, it’s been less than 1 percent a year. That’s the net 

price. 

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50 

There’s a vast difference because of a lot of discounting at the 

private institutions to ensure that there is some flexibility in pricing schedules to allow students who would not have the wherewithal to pay the sticker price to attend that institution. 

So, there is a lot of misinformation out there and it’s a complicated issue, but the costs are not what some people might think 

they are. 

Mr. SCOTT. Basically, if two schools of equal quality, one charging two, three times more than the other, should that be a factor 

in accreditation? 

Ms. PETRISKO. I would say no, it depends on how the students 

are supported to pay for those costs, and they are supported in different ways, by loans, grants, and institutional aid. 

Mr. SCOTT. Should false advertising be a factor in accreditation? 

Some schools promise that if you go to their school, you’ll get a job. 

Others, if you come to school, you’ll get a good education, but you 

may not be able to get a job. 

Ms. PETRISKO. Absolutely. There is a form that our evaluators 

use to make sure that institutions are giving their students correct 

information about costs, what it really costs, what their job prospects are, and that their recruiting materials are accurate and 

true. So, we do require that be reviewed. 

Mr. SCOTT. I visited Dr. Pruitt’s school, and enjoyed the visit, Dr. 

Pruitt. He indicated it is inappropriate to judge a school’s outcomes 

without recognizing the difference in the demographics of the student body. One could have everybody coming from the top one percent, others could have high Pell-eligible . 

Can you have a student outcome measure that does not recognize 

the diversity in the student body demographics? 

Ms. PETRISKO. I do not think so. The 20 percent rate that Dr. 

Pruitt referred to, which is an IPEDS rate, when I talked about the 

Council of Regional Accrediting Bodies, we have examples at our 

institutions where the IPEDS rate goes 30 percent, and the actual 

rate, not taking enrollment into consideration, and not taking time 

to degree into consideration through this Dashboard that I’ve 

talked about in my testimony, the actual rate of one institution in 

the California State system with a very high percentage of parttime students and students taking a very long time to get their degrees is more like 60 percent. 

So, it absolutely is relevant, who the students are, what their 

paths to degrees are, and how long those paths take. Just seeing 

a certain percentage of an IPEDS rate, the national available rate, 

may be an indicator, it’s a trigger, as I said, to look further, but 

if that percentage, as was the case with one of the institutions I 

looked at in our region recently, if that percentage represents 4 

percent of the student population or for some institutions, like 

Western Governors, 0 to 1 percent, that is not giving you very good 

information, and judgments should not be made about the quality 

of the institution based on that data. 

Mr. SCOTT. How do you value the—how do you assess the value 

of a four year on-campus private liberal arts degree where most of 

the value in fact doesn’t even come from the classroom but from 

the college experience? 

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51 

Ms. PETRISKO. We expect every institution to state what its 

learning outcomes are. Institution learning outcomes, program 

learning outcomes, and if they provide evidence of the assessment 

of and the achievement of those outcomes. 

So, outcomes can be very large, very broad outcomes. We do expect at the institutions if they state those are outcomes for their 

students, that they show us how those students meet those outcomes. 

Mr. SCOTT. Finally, should we be assessing on a pass/fail basis 

or a relative basis throughout the spectrum? Because the question 

that we are addressing is whether you participate in financial aid 

or not. Should we have a pass/fail or have an assessment that differentiates all the way through the spectrum? 

Ms. PETRISKO. There are differentiations across the accreditors: 

status of accreditation, how long, in our case, a reaffirmation, it 

could be six, eight, or 10 years, depending on the strength of the 

institution, whether there is interim reporting, whether there are 

special visits in between those reaffirmation periods. 

But I would say for Federal aid purposes, I wouldn’t want to see 

differentiation there because the students are taking different 

paths to their degrees, and they should all have access to that support to be able to do so. 

Chairwoman FOXX. Thank you, Mr. Scott. Mr. Byrne, you are 

recognized for 5 minutes. 

Mr. BYRNE. Thank you, Madam Chairwoman. This was great. All 

your testimony was very helpful. 

Mr. Miller’s testimony hit some points that I think all of us 

would agree we need to talk about, honestly. 

I was a Chancellor for Postsecondary Education for Alabama, 

and my relationship with our accreditor was, I would call ‘‘appropriate,’’ which meant sometimes it was uncomfortable. For those of 

you who know Dr. Belle Whelan, you know she is very nice about 

making things uncomfortable, but she needed to make my life uncomfortable from time to time, and that is okay, so I value that 

about it. 

We have had some failures in our accreditation agencies. So, the 

question for us is do we come in with a more heavy handed Federal 

approach to get accreditors to do what they need to do, or is there 

a way for us to turn to the accreditors themselves and say value 

your independence, which I think is one of your great strengths, 

but at the same time tell you we have to police ourselves better, 

because there have been some key instances where we have not 

done our job right. 

I thought I would like throw it out to any one of you that want 

to jump in on that. I am really looking to the other three, because 

you sort of laid the critique out there. 

I would like for you to respond to that. Do you think the Federal 

Government playing a heavier hand is going to help, or is there 

something we can do within ourselves, all of us, to make it work 

better? 

Ms. PETRISKO. I think it’s very important that accreditors have 

the authority to take additional steps where necessary to improve 

what we do, learning from very close work with the institutions 

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52 

and the challenges they face, learning what we need to do to 

strengthen our own systems. 

There has already been mention made of the failed institutions 

recently, and I can tell you one of the big changes in higher education, from which we have all learned recently, has been the tremendous growth in the for-profit sector. 

I don’t think that’s a secret, that public institutions are very 

strapped, many non-profit institutions are also financially challenged and are very concerned with selectivity. A great deal of 

growth has been in the for-profit sector. 

Just in our Commission, we currently have of our accredited institutions about 13 percent are for-profits. That’s 23 now. Six years 

ago, we had one. If you go to the candidates, it’s about 33 percent, 

if you go to the eligibles, it is about 35 percent, the ones that are 

just applying, it’s about 50 percent that are for-profits. 

So, we are very keenly aware of the fact that we need to have 

better and more inclusive information about what’s going on. 

So, accordingly, what we have done learning this is we have commissioned work from PRAGO, a firm that’s created the ratio analysis in higher education, this is what the credit analysis has done 

in higher education, pretty much across the country on the basis 

of seven financial ratios. 

We’ve worked with them to give us a better foundation. We’re 

still in the process of getting this report. Getting a better foundation for how to look not just at institutions but with their parent 

companies to get the information from them as well, on governance 

and finances, so that we can see how decisions are being made that 

are affecting the institution, where the resources are going, and 

how those are being allocated. 

I think this is a good example of the fact that we are stepping 

up as accreditors when we recognize there are issues that we are 

not covering. 

Mr. BYRNE. That is really not my question. You are doing your 

job. We know there are instances where it has not been done. I 

want to find the right balance here, because there is a tension 

here. Mr. Scott, I think, has done a good job of stating the tension. 

How do we address the balance? Dr. Pruitt, do you have a 

thought about that? 

Mr. PRUITT. Well, there are institutions that fail, and they 

should be held accountable, but the whole system shouldn’t be 

changed. There are accreditors that have failed, and they should be 

held accountable, but the whole system shouldn’t be changed. 

Mr. BYRNE. How do we hold them accountable? 

Mr. PRUITT. Well, the institutions that have failed have lost accreditation, they’ve gone out of business. 

Mr. BYRNE. I am talking about the accreditors. 

Mr. PRUITT. I think if they failed, they should be held accountable, too, and their recognition should be lost as well. 

Mr. BYRNE. That would come from the U.S. Department of Education? 

Mr. PRUITT. Yes. 

Mr. BYRNE. So, I guess the question is, Dr. McComis, this is 

something I was interested in from you, sometimes it falls most 

heavily on the sector that you deal with, how do we assess an 

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53 

accreditor? What is the basis on which we say an accreditor is 

doing its job or not doing its job? 

Mr. MCCOMIS. In this regard, there are a whole set of Federal 

regulations that we go through— 

Mr. BYRNE. Yes, but are they good? 

Mr. MCCOMIS. Largely, I think, they are. Consistency would be 

one area that I would point to and the application of those. The National Advisory Committee on Institutional Quality and Integrity, 

NACIQI, they are working toward their own expectations around 

that, and I think those expectations are changing, and when we get 

to a point of greater consistency so that accreditors better understand what those expectations are. 

There currently exists Federal regulations that say accreditors 

need to have outcomes around graduation rates or completion rates 

and licensure rates, things of that nature, and what is the consistent application. 

The only thing that I would say with regard to that is your first 

question about can we rely upon the accreditation system, what is 

really rich about it, to Dr. Pruitt’s point, is you can set benchmark 

outcome standards, and not everybody is going to meet that standard every single time, but what is the process that the institution 

is going through. 

That’s the richness and the qualitative nature of this process 

that accreditors should be expecting and that the Federal Government should be expecting accreditors to partake with their institutions to move that quality forward. 

So, holding accreditors accountable for the way they work with 

their institutions and establish those outcome standards, I think, 

is key. Any direction and guidance that the Congress can give to 

the Department in the establishment of those regulations, to talk 

about the consistent application across all the creditors, would be 

useful. 

Mr. BYRNE. My time is up. Thank you, Madam Chairwoman. I 

yield back. 

Chairwoman FOXX. Thank you. Ms. Davis, you are recognized for 

5 minutes. 

Mrs. DAVIS. Thank you. Thank you very much for the panel. I 

know you all recognize the differences in our educational institutions today. You mentioned more for-profits, other apprenticeship 

programs, lots of different ways, I think, that we need to really 

support people when they are going through postsecondary and just 

everything that is higher ed, everything that is after high school, 

but how specifically do you think accreditors could be involved in 

reviewing and accrediting the apprenticeship programs, as one example, that may be different from other accreditations? How do we 

do that? How do we apply that differently? 

I think the other question may be, and perhaps we can learn 

from programs that are more traditional, how do we listen to the 

people that are involved in this, peer review at schools is something that is a good thing on many levels, but I know from peer 

reviewers, a lot of this makes them crazy, and yet they feel they 

cannot track our students well enough to really be able to evaluate 

their educational experiences as they go into the work world. 

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54 

How do we do that? How do we train them? Do you think there 

is a good way of doing that today? 

Mr. MCCOMIS. I’ll tackle your first question about apprenticeships and other kinds of programs, because I mentioned this a little 

bit in my written testimony and briefly in the oral, and that is 

looking for ways for accreditors and for institutions to have competency-based systems supported through the Federal financial aid 

system as opposed to seat-time measures or requirements. 

So, while there’s some allowances there, I think that in some 

ways, the requirements that currently exist can serve as those barriers to innovation. 

My agency is very much interested in working with institutions 

that work more closely with the employment community, that work 

more closely in apprenticeship programs, and the question that 

arises is how does that fit into an overall educational program that 

can be supported for students with their Title IV student financial 

aid dollars. And so, where I think there’s some tension that exists 

there in trying to create programs that really can support students’ 

success. 

So, I would encourage the committee to think about ways that 

those programs can be thought about in a bit of a broader way. 

Mrs. DAVIS. Mr. Miller, do you have any thoughts about that? 

Mr. MILLER. I want to touch on the student part of it and sort 

of the student feedback. I think there are a couple of challenges 

here. One is as we talk about students are increasingly older, going 

part-time, they’re not on campuses much. 

So, if you go and conduct your visit during working hours, you 

may not be able to find all the students you have. They’re busy; 

if you sort of say come to this room at this time and talk to us, 

you’re not going to catch everyone you need to catch. 

Part of it is we need student feedback, not just sort of in the moment for people who are enrolled somewhere. We should be talking 

to people long after they’ve left, and seeing, you know, did this result in what you thought it would? 

People in the moment don’t necessarily know until they leave. 

We have seen this with a lot of the troubled schools. They thought 

they were getting a good education in the moment. They left, tried 

to find a job, found out it totally didn’t work. 

The other thing I would just say really quick here is this is why 

we have the experimental sites flexibility within the Higher Education Act to allow Federal aid to test out sort of new types of approaches. 

There is one right now that says maybe we don’t need to have 

programs be 15 weeks in length to get Federal aid, because there 

may be quick training programs that are valuable. 

Unfortunately, the current Administration is terminating them 

on June 30 without much warning or any information about what 

they’ve learned or anything like that. 

Mrs. DAVIS. Thank you for that. Please, go ahead. I had another 

question to ask you as well. 

Ms. PETRISKO. First, I hope everybody realizes that as far as the 

regional accreditors are concerned, we are limited in the types of 

institutions that we accredit, so degree granting institutions within 

a certain geographic scope. 

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55 

So, providers that are not degree granting providers, and we do 

recognize the world of education is bigger than degrees, it certainly 

is, but if they’re not degree granting providers, they do not fall 

within the scope of what we can do. 

Could accreditors do more with different types of programs with 

expanded scopes? I believe so because the basic principles are what 

are you promising, what are you delivering, how sustainable is this 

operation? 

Mrs. DAVIS. Could I turn really quickly to trade schools, and I 

know my time is almost up, because I think there is a concern and 

certainly maybe it is a misperception, that when you strengthen accreditation standards that you harm good actors in these fields. 

You put additional burdens on them to show, you know, that they 

are following through with their promises. 

Do you think that is a problem? Dr. Pruitt? 

Mr. PRUITT. Yes, that’s a problem. 

Mrs. DAVIS. How do we fix it? I think my time is up. Thank you. 

Chairwoman FOXX. Thank you very much. I think you touched 

on a subject we need to talk a little bit more about. Mr. Guthrie, 

you are recognized for 5 minutes. 

Mr. GUTHRIE. Thank you, Madam Chair. Dr. Petrisko, I am 

pleased to hear that regional accreditors have launched a nationwide effort to place increased emphasis on graduation rates as part 

of their ongoing reviews of colleges and universities. 

If you may, please provide the committee more information about 

how the graduation rate information will be used as part of the review process, and why did the regional accreditors decide to undertake this effort, and what successes have you seen so far? 

Ms. PETRISKO. Okay. So, the last part first, why it was decided 

to do this, because there are seven different regional accreditors 

and we do things in our own ways, a lot of alignment, a lot of similarities and overlap, but we do things with definitions and things 

in our own ways, it became clear that without a national statement 

and a national initiative, that there would still be a lot of misunderstanding or lack of understanding of what we’re doing, and 

that we take graduation rates seriously. 

So, we spent a long time thinking about how to set those rates, 

and as I said, the rates were set at about half the national average, 

and again, they are IPEDS rates, so they are not reflective of the 

full student population, but it was decided that going with those 

numbers of half the national average was a good starting point as 

a trigger to say let’s go further now and see with the institutions 

that we accredit, which ones fall in that band, and let’s go further 

and see are those data accurate. If they’re not accurate, why aren’t 

they accurate, let’s get them accurate. 

If they are accurate, let’s take a look across institutions of similar types and see how well are institutions doing, which institutions are doing better that we could learn from, and when institutions are not doing as well as they should be doing, what actions 

are the appropriate actions to take, not just to get more information, although more information is always good, but what are the 

appropriate actions to take to require institutions to do better. 

There’s a lot that has been learned about high impact practices, 

for example, to assist students in completing and doing better in 

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their work, so not just to encourage but to expect institutions to 

build on the rates once we have the accurate information, to make 

sure they are as strong as possible. 

Mr. GUTHRIE. Thank you. I want to move to another question. 

Dr. Pruitt, good to see you again. In your testimony, you highlight 

the importance of peer review as an affirmation of quality. 

Please discuss why you believe peer review is a crucial aspect of 

the quality assurance process even among every different types of 

institutions, and are there ways the peer review process can be improved? 

Mr. PRUITT. Because all professions look to be calibrated against 

the standards set by their profession, and the only way you can get 

those standards developed are by other people that are in your profession. 

So, if you’re a surgeon, you want the College of Surgeons to set 

the standards and evaluate you on your proficiencies. That’s pretty 

much true of every profession. 

So, we look to our colleagues from other institutions to come in 

and one, set the standards and the process. Standards are set by 

using the institutions that are members of the association. The application of those standards are done by peer reviewers from other 

institutions that understand the particular mission and purpose of 

that particular institution so there’s no misapplication of the standards. 

At the end of the day, accreditation was formed way before it 

was a gatekeeper function, because colleges want the approval of 

others in their profession as a process for continuous improvement, 

so the peer review process is essential as opposed to the review of 

some external third party coming in to do a compliance measure 

to see how many wastebaskets you have or how many seats you 

have or how many library books or test tubes you have. 

So, at the core, the strength of the system is self-study and introspection, where you are testing yourself against commonly identified standards, so that you’re not self-delusional, and then external 

review to keep you honest against standards that both the reviewers and the reviewee have bought into as appropriate measures of 

quality. 

Mr. GUTHRIE. Thank you. Dr. McComis, because your organization accredits many vocational-focused schools and programs, you 

understand maybe better than some others do the role of education 

in preparing students for jobs. 

Please talk about how the ACCSC maintains a focus on student 

outcomes and how other accreditors can learn from your expertise, 

and what work are you doing to ensure that graduates from the institutions your agency accredits are properly prepared to enter the 

workforce with skills needed. 

Mr. MCCOMIS. Thank you. So, as I said earlier, we almost view 

it as a luxury that we work with such mission-centric institutions 

that are really focused on employment outcomes. 

For two decades, we’ve had quantitative standards around graduation rates, employment rates, and most recently we’ve added a 

quantitative measure for licensure rates as well. 

We’ve been able to collect that data. 

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We’ve been able to use it again as a benchmark, not as a floor 

but as a benchmark to say anything that falls below this, we’re 

going to begin to really ask questions around the quality of the institution and how you’re really meeting that mission, and how 

you’re really fulfilling expectations for graduates. 

The use of that information is then coupled with competency assessments so that we can and the institution can have some relative assurance that graduates that go out into the employment 

community are actually able to perform the tasks that they set out 

to do. 

So, adding those two elements together, student learning and 

competency assessment piece, so at that institution it’s a process 

they have to engage in, with the quantitative measures and the opportunity for institutions to then provide qualitative responses to 

their own performance, we find to really be the indication of what 

sets an accreditable institution apart from one that’s not able to 

meet that benchmark. 

Mr. GUTHRIE. Thank you. My time is up. 

Chairwoman FOXX. Thank you. Mr. Courtney, you are recognized. 

Mr. COURTNEY. Thank you, Madam Chairman, and thank you for 

holding this hearing. It is another example of why we need to do 

a Higher Education Reauthorization Act, because what we are 

hearing, I think, from all the witnesses is just how much change 

has happened since 2008, which is the last time Congress re-upped 

the law. 

Mr. Miller, I wanted to spend a minute just in terms of some of 

your testimony and writings in terms of alternative accreditation 

to try to deal with non-traditional sort of programs that are out 

there. 

This is kind of near and dear to Eastern Connecticut. We have 

a National Theater Institute, which is also known as The Eugene 

O’Neill Theater, it has been around for 50 years, it is non-profit. 

If you went there, it looks like a campus. There are dormitories, 

there are rehearsal halls, classrooms, et cetera, but it does not 

have tenured faculty because it is actors, writers, directors, and the 

term sometimes is just a semester stint that some of the students 

attend while they are there. 

However, its graduates, people who have come through there include Meryl Streep, Michael Douglas, Lin-Manuel Miranda did his 

first play, In the Heights, while he was at Eugene O’Neill Theater, 

John Krasinski, Jim, in The Office, that you may recall, Jennifer 

Garner. 

Again, its batting average is just outstanding, but it cannot get 

accredited. It cannot extend opportunity through Title IV to a lot 

of kids who could really turn into tomorrow’s Broadway stars or 

movie stars. 

How does your sort of ideas maybe connect with programs like 

that? 

Mr. MILLER. Yes, I think that’s a perfect example of the type of 

thing that we think would be a good fit for an alternative system, 

basically saying, you know, this is something that is shorter term, 

it doesn’t necessarily end in something that we recognize as much 

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as being a clear-cut degree or certificate, but there’s clearly value 

in it. 

What we would basically say is if you can show there’s value 

there, if you can show that the people who enroll are able to complete whatever you’re offering and they do okay on the back end 

in terms of we’re not sort of leading them into financial risk and 

ruin, why should we care as much about all these other things we 

look at right now. 

Part of the reason we look at all those things right now is because we’re not as confident about those outcomes on the back end, 

so we use sort of up front input checks to deal with that problem. 

What we’re saying basically let’s just look on the back end and 

see what happens. Obviously, yes, there are a range of outcomes 

that are useful to higher education beyond just did you pay your 

loans or things like that. 

We’re only concerned about is this a good financial bet for the 

government. Should we invest in this, do we think it promotes opportunity, and when you think about it that way, you can sort of 

set aside some of the more complex things that get used right now 

in the current system as sort of proxies for other things. 

Mr. COURTNEY. Go ahead, Dr. Pruitt. 

Mr. PRUITT. Congressman, this is a wonderful opportunity to 

point out a rule that just drives me nuts; it’s the credit hour rule. 

The credit hour rule says that accreditors are required to ask colleges and universities to first of all, award credits in credits, and 

then to define ‘‘credits’’ by the number of hours spent in a seat. 

Now, please tell me how an accreditor could apply that rule to 

the institution that you just described. It just would be impossible. 

So, there needs to be flexibility and communities that come and 

allow institutions like that to prosper and succeed, but it can’t happen unless the regulatory context that accreditors have to function 

in allow it to make it happen. 

Mr. MILLER. May I mention the credit hour? I think one thing 

that is important to realize here is part of the reason why we needed this rule was we had colleges out there that were inflating credit hours to get more financial aid, so we had schools claiming they 

were offering courses worth nine credits that did not have the 

amount of learning behind that. 

When you do that, students pull down more financial aid than 

they should, so they’re going to exhaust their lifetime eligibility 

sooner, and we’re going to pay money out to schools faster than we 

should. 

So, there is credit hours from the sense of measuring how much 

learning and things like that, and then there’s credit hours in the 

sense that we want to make sure that schools aren’t essentially 

taking in more money than they should, making it harder for students to get enough money to finish their whole program. 

Mr. COURTNEY. Thank you. Again, I think as we hopefully get 

closer to putting pen to paper in terms of a proposed bill, we would 

encourage you to continue to share with us your ideas about ways 

you can actually sort of structure it so that there are safeguards, 

but on the other hand, we are not denying kids who could be the 

next author of Hamilton the opportunity to learn and succeed. With 

that, I yield back. 

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Chairwoman FOXX. Thank you, Mr. Courtney. Mr. Lewis, you are 

recognized for 5 minutes. 

Mr. LEWIS. I thank the chair and thank the panel for coming 

today. A couple of questions. Let’s start with a follow up to Dr. Pruitt on innovation. 

Right now, the accreditation process is compromised, and I do 

not want to use the term ‘‘status quo,’’ but employees or members 

of the traditional system of higher education that we have used for 

so long and so successfully. 

How do we get independence or maintain independence of 

accreditors without Federal Government micromanaging, and at 

the same time, open up the system to these new delivery methods 

we are talking about, for instance, competency-based education as 

opposed to just seat-time? 

So, on the one hand, we have a system of current traditional education, and on the other hand, we do not want any Federal intervention, but we want independence, too. How do we get there? 

Mr. PRUITT. You get there by focusing on the student learning 

outcomes, because these are all processes getting to a commonly 

agreed upon destination. 

The issue needs to be not how you get there or how the learning 

takes place or what form does the learning take place in, but does 

the learning take place, and can you certify it through some valid 

and reliable assessment process at the end so that you know the 

standard gets met. 

The regionals have opened up on that. It used to be that was a 

problem. If I had been here 10/15 years ago, which I think I probably was, I would be complaining about a rigidity from the accrediting community that stifles innovation. 

That has pretty much changed in the regional area. The problem 

we have now is not so much with our regional accreditors, but with 

the regulations that are coming from the Federal Government. 

Mr. LEWIS. Can you give me an example, for instance, on the 

massive open online courses, the MOOC classes, and accreditation? 

Is there an issue there? Is there resistance there? 

Mr. PRUITT. Well, no, not from the accreditors. Students that go 

through those experiences can come to Thomas Edison, and if 

they’re willing to go through an assessment process to say I went 

through a MOOC and I was stimulated, I learned all this stuff, and 

I want credit for that, they can come to Thomas Edison, and there’s 

an assessment process you can go through, and if you can verify 

that you in fact achieved competencies that you would have 

achieved had you taken the course, you can get credit for that. 

We work with StraighterLine and a whole lot of other non-traditional providers where students that acquire competencies through 

the non-traditional providers can come, and if they’re willing to 

subject themselves to a valid and reliable assessment process, demonstrate that the learning was acquired, they can get credit for 

that. 

The key is the assessment of the learning outcome at the back 

end and not the process of how you get there. 

Mr. LEWIS. Very good. I want to shift gears a little bit, Dr. 

Petrisko, and ask you a question that may be off the beaten path 

a little bit. 

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The Higher Education Act requires accreditors to consistently 

apply and enforce standards that respect the stated mission of the 

institution. 

Much of this hearing and much of our work here focuses on the 

rigors of curriculum and making certain there is academic competence and all that. 

A crucial part of a classic liberal education is preparing citizenship or preparing good citizens. I have to say I am very concerned 

with what I see lately and what appears to be a very highly 

charged political environment on our Nation’s campuses that I 

think is turning into a bit of a threat to free speech and academic 

freedom. 

Again, may be off the beaten path, but is that part of the accreditation process, to ensure that we have open and free dialogue? 

Ms. PETRISKO. If you look at our standards for what we expect 

for an undergraduate education and for graduate education as well, 

there are certain things that are stated within those standards. 

In our case, five core competencies, including one which is critical 

thinking, which I think would certainly relate to what you’re talking about. 

We have asked institutions and expect institutions to give us evidence of the fact that their graduates actually have achieved these 

core competencies, which are going to look different across institutions. 

What Cal Tech is going to do with regard to quantitative reasoning is going to be quite different than what a seminary would 

do, for example, the broad diversity of institutions we have. 

Participation in society and citizenship is something that we do 

expect from our institutions, that students get a broad education 

and part of that is being part of society and a peaceful society, and 

a society where they can have interaction. 

So, I do find it disturbing that there have been a number of cases 

recently where there have been issues of what’s been perceived as 

restriction of free speech on campuses, and I understand from the 

campuses’ perspective that there was safety and security concerns, 

which they balance. 

From an accreditation perspective, I think that’s what we expect 

our institutions to do, to recognize what they exist to do and to do 

that in a way while maintaining a campus or an institution where 

people are safe and secure, so how to balance those. We do expect 

that from our institutions. 

Mr. LEWIS. Thank you. My time has expired. I yield back. 

Chairwoman FOXX. Thank you, Mr. Lewis. Mr. Polis, you are recognized. 

Mr. POLIS. Thank you, Chairwoman Foxx, and thank you to 

Ranking Member Scott for this great hearing. Accreditation is an 

issue that frankly receives too little attention for its importance in 

higher education, and we really need to make sure that we have 

an accreditation system that allows for the kind of innovations to 

create an effective 21st century higher education system. 

Mr. Miller, as you know, competency-based education allows for 

innovation in higher education, and credits can be awarded based 

on competency. It allows for more efficient and better forms of pedCEWDOCROOM with DISTILLER

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agogy that are not tied to seat-time requirements, allowing students to move faster or slower through their degree. 

I was pleased that in 2015, C–RAC recognized the uniqueness of 

competency-based education and announced a framework for approving competency programs. 

Can you share why it is important for accreditors to consider the 

distinct qualities of different types of education, specifically about 

CBE, what are some areas where accreditors should take a closer 

look? 

Mr. MILLER. Sure. I think competency-based education is one of 

the most exciting things that’s happening in higher education today 

because it’s moving beyond the sense of did you just stay there long 

enough to eventually get a degree versus can you actually show 

that you learned things and that we’re confident you got the knowledge you need to succeed? 

So, I think it’s still obviously developing, and it’s slow going because, obviously, every time there is new sort of charted areas, 

we’re looking at that. 

I think probably the next space to look at is to think a little bit 

more about flexibility on what constitutes a program. So, right 

now, we’re seeing students who maybe are acquiring knowledge 

from multiple different areas and how can we sort of cobble that 

together into something that represents a program. 

I don’t think we should get down to the level of like accrediting 

individual courses. I think in general the return from any given 

course is probably not great enough to merit that. We should think 

about when you’ve got things coming from multiple areas— 

Mr. POLIS. Does that not also allow for kind of new combinations 

of courses, even changing the definition of a ‘‘course’’ in terms of 

ways of getting to a particular outcome? 

Mr. MILLER. Correct. The thing you have to do to make sure this 

all works though, is you have to keep a laser like focus on outcomes 

on the back end. 

Mr. POLIS. Thank you. I wanted to go to Dr. Petrisko quickly. As 

a member of C–RAC, and can you share a little bit about your perspective on the guidance you are working on for competency-based 

education? 

Ms. PETRISKO. I’d love to talk about competency-based education. 

It is one of the areas where accreditors really are partnered with 

institutions to support the innovation that they have seen as important in reducing time to degree and allowing for flexibility and 

affordability. 

This is one of the areas where I hope there will be attention paid 

in the Higher Education Reauthorization Act. A number of 

accreditors, including us, have been sort of caught, as have the institutions, in supporting this innovation and at the same time, 

when we had an Office of the Inspector General coming to audit 

how we do this, being caught with the regular and substantive faculty initiated interaction. 

These programs work differently. We as accreditors make sure 

that all the things that have to be taken care of to ensure the quality and protect the students are done. They are going to be done 

in different ways for different programs. 

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But, the Office of the Inspector General looked at this and said 

well, these programs don’t have the same kind of regular and substantive interaction that its faculty initiated, so there was some 

back and forth on that. That’s just not helpful. 

Mr. POLIS. So, what we can get with competency-based is we care 

about the outcome, regardless of if you find a way to do it with different interactions with faculty, we care about what the actual outcome is rather than the inputs. 

Ms. PETRISKO. Exactly. 

Mr. POLIS. Back to Ben Miller, I wanted to address another innovation in higher education, coding boot camps and boot camps in 

other fields that relate to job related certifications. 

In Colorado, there are a number of boot camps like Turing School 

and Galvanize. They have great track records of placing students 

into great jobs, after completing their program, which are usually 

a few months of intensive work. 

Unfortunately, these programs are not accredited, not eligible for 

Federal aid. That means the students either have to take out higher cost private loans or the programs are limited to students who 

can pay for them themselves. 

I am very supportive of allowing programs to be eligible for Federal aid so they can serve more at-risk students, but only if these 

programs have a track record of success, and the transparency and 

accountability that comes along with it. 

Can you share your ideas on supporting innovative models like 

Turing and Galvanize, and making sure actors do not take advantage of flexibility, and at the same time, we give our more at-risk 

population a chance to attend these types of academies? 

Mr. MILLER. Again, this is something that really hits on part of 

why we felt the need for an alternative system that is really outcomes-focused would be helpful. 

A couple of things on that. One is obviously is you keep track of 

outcomes, then you can have greater confidence that it’s okay to 

sort of lend there, to ease them in. We think it’s important that 

these new providers have some degree of financial commitment up 

front, so that we have some sense that maybe a boot camp that is 

only a year old actually has the financial capability to sustain 

itself, so that we don’t run into a situation where we open up the 

aid programs, lend to people, and then being shut down overnight. 

I think the other thing is this really speaks to we need to think 

more intelligently about how we ease people into the system, because right now it is basically like we approve you, and then you’re 

eligible for everything right away, and you can get as much money 

as you can get students. 

We should probably think about easing people in, letting them 

try it with a few students, a little bit more sustainable growth, that 

acknowledges maybe you shouldn’t go from 100 to 1,000 people 

overnight, and things like that. 

Mr. POLIS. Thank you. I yield back the balance of my time. 

Chairwoman FOXX. Thank you very much. Mr. Smucker, you are 

recognized for 5 minutes. 

Mr. SMUCKER. Thank you, Madam Chair. Dr. Pruitt, I would like 

to learn a little more about the peer review process. I just recently 

met with the presidents of several local private colleges, and I am 

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in Pennsylvania, and with the association that represents many of 

the private colleges. They have both been part of the peer review 

process, in evaluating other colleges, and have participated in their 

own organizations. 

By the way, they spoke very highly of the Middle States process. 

With your expertise, your experience working as an accreditor, and 

your experience in higher ed as well, how have your views on the 

peer review process changed or been shaped by working on both 

sides? 

Mr. PRUITT. Well, first, peer review is more than just peer review. It’s peer review. Peer review has to be honed so that the 

peers that are evaluating you are peers from comparable institutions that really understand your institution. 

It is true that sometimes—I’m fairly aggressive about talking 

about mission differentiation, being evaluated by peers that share 

your same mission, sometimes institutions can hide behind that, so 

how do you have people that are evaluating you that can call on 

your own stuff if you’re not being really candid and are hiding behind a broader definition of your mission. 

So, you have to have peers that come in, that are not only from 

other institutions, but other institutions that understand your kind 

of institution, so they know when to probe, when to test. They 

know what kind of data to look for, that if one set of metrics isn’t 

the right set of metrics, what is the right set of metrics. 

The peer process starts with the developing of the standards, the 

development of the processes, and the implementation, and then to 

the teams that evaluate it, and then after the team does a report, 

that report goes back to the accrediting body and gets reviewed 

again by a different set of peers to keep some distance and objectivity. 

The other thing you’ll find, and I know it from Middle States, 

and I believe it’s true of the other regionals, the institutions that 

are in it overwhelmingly support it. There is anecdotal evidence 

about people that are ticked off about this or that process, and it’s 

always going to be the case, but when you look at an objective evaluation of the data, and we evaluate everything, including how our 

institutions are satisfied with the process, it’s overwhelmingly supported by our members. 

So, it works very well. It really does. 

Mr. SMUCKER. Thank you. You also made the comment and I appreciate it, that compliance is not the substitute for quality. You 

mentioned there may be compliance things that accreditors can 

look at now required by either the law or regulation that Congress 

could potentially remove in the reauthorization of the Higher Education Act. I would like you to expand on that. 

Mr. PRUITT. In my testimony, there are three that I suggested 

need to go away. The first was credit hour, for reasons I’ve already 

spoken to. The second is State authorization. 

There was earlier discussion about the triad. The triad does need 

to be strengthened, and it is reasonable that States should exercise 

licensure authority over the colleges and universities that operate 

in their States, and there are a number of States, unfortunately, 

that have no licensure and no oversight, and that should be 

changed. 

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The current definition of ‘‘State authorization’’ extends that to 

online courses and even literature. That’s just absurd. It destroys 

the use of technology that shortens time to completion, and kills innovation. 

The third one is the score card, and I’d love to talk about that, 

where the Federal Government has come up with a template to try 

to evaluate colleges and universities, and the results are bizarre. 

So, those are three things that I’d like to see go away right away. 

Mr. SMUCKER. Thank you. 

Chairwoman FOXX. Thank you, Mr. Smucker. Ms. Bonamici, you 

are next. 

Ms. BONAMICI. Thank you very much, Chairwoman Foxx and 

Ranking Member Scott. This is an excellent discussion we are having this morning. 

I know like many of my colleagues I am concerned about institutional quality, and we have heard so much about places like Corinthian and ITT Tech that provide these recent examples of financially unsound institutions that were allowed to operate as accredited schools for way too long. 

I know the policy group, Third Way, just noted in a report issued 

this year that more than 130 accredited colleges and universities 

graduate fewer than 10 percent of new full-time students. 

I appreciate the good work that accreditors are doing, but there 

is no doubt that we should look for opportunities to work together 

so the accreditation process is really helping to make sure that students and families who invest in higher education are not taking 

unnecessary risks with their future. 

I think Mr. Polis left, but I wanted to follow up briefly on his 

comment about the coding boot camps. I know that many of them 

have now joined a coalition and developed a framework called the 

Council on Integrity and Results Reporting, to just try to get some 

consistency out there with what they are doing. That is a conversation we need to have with alternatives like that. 

Mr. Miller, I wanted to ask you, the Department’s guidance from 

November 2016 encouraged accreditors to provide more information 

about the actions they take, and some of the information is made 

available on the Department’s database of accredited institutions. 

So, what could the Department do to further this effort, and is 

the database useful for consumers? 

Mr. MILLER. So, this is a really important first step, but it still 

has a ways to go. We actually try to look at accreditor actions, and 

before this comprehensive reporting was required, it was a total 

mishmash. You could look in some places and you could see things 

for a year, you look at others, they would have it for five years. The 

reasons why actions were taken were sometimes very clear, sometimes they weren’t clear at all. 

So, getting the information is a crucial starting point. Unfortunately, the database now is not exactly the most user friendly, and 

I think expecting a student to actually find it is unlikely. You have 

to download a spreadsheet, and then click through to a link that’s 

contained in the spreadsheet, so nobody is going to get it there. 

I think the starting point is the Department needs to make sure 

it’s starting to use that information, too. A big part of that is the 

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posed to be able to conduct more investigations and feed in information from third parties about problems, and there are real concerns now about whether or not that enforcement unit will be continued in the current Administration, and whether or not it will 

truly be effective. 

Ms. BONAMICI. I want to follow up. I know that in April 2016, 

there was a letter to federally recognized accrediting agencies sent 

by then Under Secretary Ted Mitchell, outlining the power that 

accreditors have to differentiate in their reviews of institutions 

under current law. 

Do you know what steps if any you are aware of that accreditors 

have taken in response to that letter? 

Mr. MILLER. I know there are many accreditors that are considering different differentiated processes. WASC is in the middle of 

working on one. I believe the Higher Learning Commission has one 

as well. I think that’s a really important first step. 

It would be nice to see it go further because I think we should 

be discussing whether or not there should be differentiated levels 

of approval for Federal financial aid. Right now, it’s so all or nothing that it makes it hard to ease people in, and also ease them out, 

and we should recognize that a loan is riskier for a student than 

a grant. 

I think it’s still a little early to tell because we haven’t seen exactly how these play out yet, and the process for accreditation is 

such a long cycle that it’s hard to know, you know, if you do something over 10 years, we won’t know right away. 

Ms. BONAMICI. And did you want to respond to that, Dr. 

Petrisko? 

Ms. PETRISKO. Well, just to note that indeed I anticipate that at 

the next Commission meeting we will approve a process that will 

allow for institutions that have very strong histories of clear financial sustainability, good learning outcomes, graduate rates, et 

cetera, that they would have a reduced burden as far as visit and 

as far as reporting is concerned. 

Ms. BONAMICI. Thank you. Mr. Miller, in 2014, the GAO report 

found that the Department of Education does not consistently use 

accreditor sanction information for oversight. After that, the Department agreed to develop better internal information sharing 

systems to enable its analysts to use the information about sanctions from accreditors to inform the Department’s oversight. 

Do you know if this change has been effective, and what more 

can the Department be doing to align oversight and enforcement 

responsibilities? 

Mr. MILLER. So, there hasn’t been a ton of public information to 

judge the effectiveness of this. We do know that last fall one of the 

reasons why the Department decided to take action against ITT 

Technical Institute was because of some concerns that came from 

the accreditor. 

It is possible that some of the actions against Corinthian may 

have started with accreditors raising concerns about the accuracy 

of job placement rates, but the Department has not been completely transparent on it, and again, if the Department does not 

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ing at the information coming in from accreditors, it will be for 

naught. 

Ms. BONAMICI. Thank you. As I yield back, I want to recognize 

Madison, who is here today shadowing me with Girls, Inc. She is 

a junior in high school, and I hope she found this conversation 

helpful. Thank you, Madam Chair. 

Chairwoman FOXX. Thank you, Ms. Bonamici, and Madison, we 

are very glad to have you with us today. Mr. Walberg, you are recognized for 5 minutes. 

Mr. WALBERG. Thank you, Madam Chair. Thank you to the 

panel. I think it has been a very helpful panel today. 

Before I ask my questions, Dr. Pruitt, thank you for helping us 

to understand very clearly that unless we ask the right question, 

we will not get the right answer. Thank you for the part you play 

in really stimulating us to think in new directions, think what 

works in the present world, not what worked well in the past, that 

is fine, and because of what you and others are doing, I think both 

Princeton, University of Michigan, in my case, Michigan State, will 

be better and will not rest on laurels because of the competition of 

new ideas that entities like your own bring about, so thank you. 

Dr. Petrisko, past actions by regional accreditors have raised concerned that some agencies may be acting inconsistently with the 

HEA’s requirement that accreditors, and I quote, ‘‘Consistently 

apply and enforce standards that respect the stated mission of the 

institution of higher education, including religious missions.’’ 

I am of the opinion that there may not be a war on, but certainly 

a battle taking place in society today against some traditional missions, religious values, First Amendment liberties, that are not 

good in continuing freedom in this country. 

Certainly, in academia, there ought to be a high priority in saying while we may not agree with you, your mission statement is 

extremely important for what you are providing for your students. 

Can you discuss how your agency makes accreditation decisions 

in light of institutional missions, and particularly religious missions? 

Ms. PETRISKO. I think it is probably going to be surprising to 

some that about 40 percent of our institutions are actually faithbased institutions in the WASC region. 

Mr. WALBERG. A lot of them are feeling put upon. I mean across 

the Nation. 

Ms. PETRISKO. Yes, I understand. We absolutely do respect mission, and we understand when institutions make decisions and set 

goals and set their curricular objectives, et cetera, in line with their 

mission, that is to be respected. 

There have been cases where there have been internal struggles 

at institutions amongst faculty about evolution, for example, and 

how to deal with that, what should be taught, what may be taught, 

what may not be taught. 

We have watched those things closely, but ultimately it is our position that the institutions must allow for that sort of discussion 

with integrity and honesty while supporting its mission, so not to 

forbid the conversation but to put forward the tenets of the faith 

as they see that, but allow that to be discussed. 

Mr. WALBERG. Or to change the mission. 

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Ms. PETRISKO. Pardon? 

Mr. WALBERG. Or to change the mission also, is that your position, you are not there to change the mission of that particular institution. 

Ms. PETRISKO. We are not there to change a mission, absolutely 

not. Sometimes institutions themselves on who they want to serve 

and how they want to serve them will amend their own missions, 

but that’s not our job. 

Mr. WALBERG. Thank you. Dr. McComis, how does your agency 

determine and set standards for your institutions and what they 

are required to meet, and secondly, how do you and other 

accreditors update your standards to ensure progress? 

Mr. MCCOMIS. Well, again, that is all done within the peer review foundation and establishment for the agency. So, it’s really 

looking at what are the best practices in a particular area, and 

then utilizing those in such a way that they promote quality, that 

they promote an opportunity to assess how well an institution 

meets those standards, and then going back and evaluating ourselves for whether or not those standards actually do what they intended. 

So, again, it’s a process whereby experts/peers come together, say 

these are the practices we want to hold ourselves and our fellow 

institutions to, and then creating a process by which assessment 

can be done for an institution’s adherence to and promotion of 

those best practices. 

Mr. WALBERG. Thank you. I yield back. 

Chairwoman FOXX. Thank you, Mr. Walberg. Mr. Takano, you 

are recognized for 5 minutes. 

Mr. TAKANO. Thank you, Madam Chair. As has already been 

mentioned, last year, the National Advisory Council for Institutional Quality and Integrity recommended that the Department of 

Education withdraw its recognition of the Accrediting Council for 

Independent Colleges and Schools, otherwise known as ACICS, 

which the Department did last year. 

ACICS accredited over 200 for-profit institutions with over 800 

locations, including several very large online for-profit networks, 

notably ITT Technical Institute, which shut down in September 

2016. They also accredited Corinthian Colleges before the school 

shut down two years ago today. 

The abrupt closures of ITT Technical Institute and Corinthian 

Colleges left thousands of students burdened by loans for degrees 

they did not complete. This especially impacted student veterans 

who lost their post-9/11 G.I. Bill benefits, because they were unable 

to complete their courses or gain transfer credits. 

I do not believe accreditors should be—I do believe accreditors 

should be in the business of protecting students, and ACICS in this 

case clearly was not protecting the students. 

My question first is for Mr. Miller, and anyone else who would 

like to chime in. Mr. Miller, the Obama Administration took steps 

to strengthen accreditation standards, but what more could be done 

to ensure that bad actors in the for-profit industry are held accountable? 

Mr. MILLER. So, within accreditation, part of it really needs to 

be looking more at the outcomes of accreditors and the quality of 

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their standards when they come before review. Unfortunately, the 

current process of reviewing standards tends to mostly be around 

do you have something that credibly fills a requirement in law, not 

is that requirement any good. 

For example, one of the things we saw with ACICS was it was 

able to persist with weaker outcomes measures than other national 

accreditors because it had something that filled the box that just 

said there’s an outcomes measure there. 

The second thing is we need to make sure the rules that are in 

place right now are enforced, so we need to ensure that if a school 

has—I’m sorry, a vocational program has too high debt relative to 

the earnings of its graduates, that it is held accountable for that, 

because we need to make sure they are sort of moved out of there. 

The other big thing is we don’t pay enough attention to the possibility of failure and what might happen there, so one is the Department of Education is not nearly aggressive enough in demanding 

financial commitments from large schools that might go under. As 

a result, when schools close, taxpayers have to foot the bill and students are out of luck. 

And, the second thing is the teach-out plan provisions are not 

strongly enough verified, essentially. When you have these large 

operators, you need to make sure that the plan for what happens 

if it closes is actually a real plan and not a piece of paper, so when 

you’ve got a place like Corinthian that shuts down overnight, if you 

just have a plan and no one has actually tested to see if the school 

that supposedly will take students actually will, then you are putting yourself at a real risk that you might be caught unaware and 

have serious trouble. 

Mr. TAKANO. Well, the Obama Administration also finally issued 

the gainful employment rule. In your estimation, does this rule 

help accreditors ensure that institutions are best serving students? 

Mr. MILLER. I think it absolutely does. First of all, it puts out 

there numbers that we never saw before about the actual earnings 

of graduates, which is a very important outcomes measure that we 

didn’t have before. 

I think it could go further. The biggest risk is it doesn’t look 

enough at how many students are actually finishing, so it’s only focused on graduates, so essentially if a program enrolls 1,000 people, 10 make it through, it may look okay on gainful employment 

even though there are a host of other problems that aren’t captured 

there. 

It should be providing a wealth of additional information for 

accreditors and giving them cover because something else is going 

to step in and remove a problematic actor so they might not have 

to. 

Mr. TAKANO. Dr. Petrisko, you look like you want to say something. 

Ms. PETRISKO. I did want to say something about Corinthian and 

ITT, just to remind everyone that accreditors do not accredit the 

parent company of these institutions. We accredit the institutions. 

We have learned from the past failures that we must have the 

information from the parent that is going to affect those institutions. 

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What was also the case with regard to Corinthian was the Department of Education had information that we did not have as 

accreditors, so there’s an issue about who has what information at 

the State level, the Federal level, and the accreditors, how is that 

information shared appropriately, may it be shared, what can be 

shared, so that any of the players in that triad have a good foundation for the actions that they take. 

Mr. TAKANO. I do not have enough time to get an answer, but 

I do want to put the question out there and maybe take it for the 

record. 

I am interested in the programmatic accreditors and what I see 

as possible inflation or credential inflation. I am thinking of community colleges who used to be able to offer physician assistance 

programs, those programs are now requiring Master’s level work, 

and also the movement towards the bachelor’s of nursing degree. 

I realize there is interplay with industry here, but I want to be 

able to get reactions from some of you about whether or not you 

believe there is inflation of credentials. 

I yield back. I am sorry for going over my time, Madam Chair. 

Chairwoman FOXX. Thank you, Mr. Takano. Dr. Roe, you are recognized. 

Mr. ROE. Thank you. Thank you all for being here, and thank 

you, Madam Chairwoman and Ranking Member Scott. 

Obviously, the idea in Tennessee, we are very committed to education and training our people, community college is free in our 

State to residents there, and we have a Drive to 55, where you can 

go to either a Tennessee college or applied technology and get a 

certificate or a degree, and we found that in those particular 

schools, 90 percent secure a job upon graduation in their field, 

whether it is nursing assistant or phlebotomist, whatever it may 

be. 

I was 18 years old when I started college. I did not have a clue 

what I was going to do. Vietnam war focused that pretty quickly 

for me. I decided I was going to do something in college. 

Dr. Pruitt, your students are different, and there are people I see 

every day in my community who have lost their jobs or whatever 

and are going back while they are working to try to get some skills 

so they can take care of their families. 

I applaud you for what you are doing at your university. I think 

it is incredibly valuable. 

I guess for the accreditation part, once I figured out what I was 

going to do, could my college get me into medical school. That is 

what I was interested in. If I could pass the courses, could I then 

pass exams. I had a plan. It could. I did not know whether it had 

an accreditation or not, but it provided those assets and benefits 

for me as a student because I had an idea about what I wanted 

to do. 

I think in doing the accreditation, I watch it in medicine today, 

how you measure success, how is that done, and then how do you 

define it. I think defining it could be graduation rates, it can be 

certificates, it can be a lot of things. I think that definition needs 

to be broadened, and certainly, how do you simplify the reporting. 

I will give you an example, a 2015 Vanderbilt report on the cost 

of regulations in higher education estimated that the accreditation 

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costs of compliance was $3.4 billion a year for regional accreditation. 

Does that actually bring value to me because I know who is paying for it, the students. I have written a lot of checks to colleges 

for my kids to go to school. 

It is not nearly as affordable as it used to be, so does it really 

bring value. I want to stop and just ask these three questions 

quickly, and I will let you take the rest of the time. 

What are the regulations that are preventing accreditors from focusing on student outcomes? Number one. 

Number two, are there duplicative data collection requirements 

the Education Department makes on accreditors and schools? 

Number three, how can innovation in accrediting be encouraged? 

Those three, any of you can take off on any of them. I will pick 

on you, Dr. Pruitt. 

Mr. PRUITT. Well, there’s a long answer to that. There are a lot 

of things that need to be changed. I think how you define ‘‘success’’ 

is relative, and that’s also very important. I certainly think if you 

go to a school, either a professional school or a graduate school or 

proprietary school that is preparing you for a profession, you ought 

to expect that if you meet the requirements of the institution, that 

you ought to be able to pass the licensure exams to participate in 

the profession. 

If you go to medical school, they have like a 98 percent pass rate. 

If you go to medical school and graduate from medical school, 

you’re not worried about whether you’re going to pass the exam to 

participate in your profession. 

Mr. ROE. Actually, yes, I was worried, but I did pass it. 

Mr. PRUITT. I’m going to take a risk because my data is about 

nine years old, but when I was on NICIQI, I had a real problem 

with the bar association because law schools are very selective and 

very expensive, but the national pass rate from accredited institutions, law school, was around 70 percent. In some cases, it was 

lower than that. John Kennedy graduated from Harvard and 

couldn’t pass the bar exam. There is something wrong with that. 

If you’re going to a school to be a nurse or a teacher, you ought 

to be able to pass your licensure exam. Your ability to participate 

in the profession that you’re going into ought to be a factor in accreditation in terms of being able to value the accreditation that 

you get. 

The regulatory environment takes good ideas. The rules that I’m 

complaining about, in their concept, they make sense. I think gainful employment in its concept makes sense, but the way it got 

operationalized doesn’t make sense. 

If you look at the list of bad actors under gainful employment, 

Harvard is on that list. So, the challenges, how you take something 

conceptually sound, the rules that we have to execute make no 

sense. 

There needs to be a reengagement between the regulators and 

the community, and we used to have that. We lost that. That reengagement needs to happen again so we can take the good ideas, 

work through the consequences and operationalize in a way that 

satisfies the public interest and also meets the needs of the professions. 

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Mr. ROE. Thank you. I yield back. Thank you very much. 

Chairwoman FOXX. Perhaps the witnesses would be willing to 

give Dr. Roe answers to his questions in writing. That would certainly be very helpful. 

Ms. Adams, you are recognized. 

Ms. ADAMS. Thank you, Madam Chair. Thank you, Ranking 

Member Scott. Thank you to all the witnesses for being here. Dr. 

Pruitt, good to see you again. 

Mr. Miller, how was the Department’s decision to publish 

accreditor’s standards for evaluating student outcomes improve the 

accreditation system, and could this be constituted as an overreach? 

Mr. MILLER. I don’t think it is. I mean basically what the Department of Education did was went on the websites of all accreditors 

that already make their standards public and essentially put them 

all in one place. I think it’s more of a useful starting point in the 

conversation because you can start to see how things vary and understand maybe there’s a good reason why something varies, but 

also start to raise questions about why is it that a branch of one 

publicly traded for-profit college has to hit a 70 percent placement 

rate at say ACCSC, and maybe only needs to hit 60 percent at a 

different accreditor. 

So, I think it’s a good starting point to start to ask why do things 

vary and where is the right line between consistency versus variation? 

Ms. ADAMS. Thank you. In your testimony, Mr. Miller, you mentioned that one way to improve student outcomes through the accreditation process is to increase Federal minimum requirements 

for student financial aid. 

Would you explain what the current student loan performance 

metrics are, and how you would recommend that Congress 

strengthen these metrics? 

Mr. MILLER. I mean, the big problem we have right now is the 

only real measure of student loan performance we use is what’s 

called the cohort default rate, which essentially asks what percentage of borrowers default within three years of leaving school. The 

problem is right now it’s just a cliff. So, essentially if you’re nowhere near that 30 percent rate, you don’t have to worry, and functionally basically nobody fails this. 

So, in the most recent data, I believe it was 10 schools that had 

about 600 and some odd borrowers total—sorry, borrowers in default total, that failed that test. So, 99 and some odd percent of 

schools and borrowers aren’t affected by this rule. 

So, I think the big thing we need to think about is measuring 

other problematic loan outcomes that aren’t captured now, particularly people who can’t repay their loans, because one of the problems we’re seeing is students maybe aren’t defaulting, but they’re 

not making any progress actually getting rid of their debt, and the 

only other fix we have available to those people is we say to them 

in 20 years, basically half your working lifetime, if you do the right 

things and keep up with all this paperwork and stuff, we’ll forgive 

your loan, and that’s a long time to make people wait if they have 

borrowed a loan that’s not helping them. 

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Ms. ADAMS. So, what steps could the Department of Education 

take right now to encourage accreditors to begin working with an 

institution before it has to close and students have to look for a 

new school? 

Mr. MILLER. So, I think one is really trying to take a more riskbased approach to say, you know, we have some schools here that 

maybe they only have 100 students, so if they close, the risk and 

the complexity is not that high, but once we get schools that have 

thousands and tens of thousands of students, we should say what 

are the plans in place in case these things go under? 

It is almost actually some of the same conversations we had 

around the big banks, like are we stress testing schools to make 

sure they are sound, do we have a plan in place in case they fail, 

and are we actually testing that plan? 

So, are we calling those schools listed on that teach-out plan to 

see how many would you actually take, and will you actually take 

them? Are we making sure that the places that are on that teach 

out plan actually have good results, and we’re not going to basically 

kick students from one school that had a bunch of bad outcomes 

to another that also got a ton of challenges as well, and actually 

make sure we are thinking about what happened and we are taking risk into account. 

You know, a place that gets $1 billion in Federal financial aid 

is a much bigger risk to taxpayers and to students than one that 

might get $500,000 in Federal aid. 

Ms. ADAMS. Thank you very much. I spent 40 years teaching on 

the college campus in Greensboro, North Carolina, been through 

many, many accreditations. I have learned a lot here today, and I 

thank you very much, Madam Chairman, and I yield my time back. 

Chairwoman FOXX. Thank you very much. Mr. Allen, you are recognized for 5 minutes. 

Mr. ALLEN. Thank you, Chairwoman, and thank you so much for 

your insight today as far as the college level. Dr. Pruitt, I am particularly interested in what you are doing at Thomas Edison State 

University based on your testimony. 

I called all of our school superintendents or met with them while 

we were in the District, just to find out about the school year, how 

it is going, graduation rates, that sort of thing. 

The highest graduation rate we have is in a rural county. I said 

how are you doing this. He said well, we are actually teaching the 

children to get an education, to get a job first. We are also giving 

them the skills that if they want to go to college, they can do that, 

too, rather than the other way around. In other words, rather than 

teaching students to go to college, we are teaching them the reason 

they are getting an education is to get a job. 

It sounds like based on your student population that most of 

your students have careers or what not, and are now saying you 

know, I want to learn more to move up the career track. 

I know even with my own children, they entered college on one 

track and said well, I do not know if that is what I want to do, 

so they are kind of back and forth. They had worked in our business, but that was kind of all they had done. Well, I think I want 

to do this. 

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We are spending a lot of money on education. Of course, I hear, 

too, that the career tracks are very successful as far as graduation 

rates. In other words, if you can get young people to understand 

kind of where they want to be in life early, they just get on that 

track and they are energized and motivated, and that sort of thing. 

Tell me how that is working, and I want to ask the accreditors, 

do you look at that as far as accreditation. Go ahead, Dr. Pruitt. 

Mr. PRUITT. Most people ask- see our student body, they want to 

know why are your students there, because they are older, most of 

them are all working. They are very diverse in their characteristics. We have students that are 25. We have had a graduate that 

was 92. 

When you ask them why are you here, it’s one thing that comes 

back; it’s unfinished business. They started college—pretty much 

90 percent of our graduates come to us with previous college. They 

started college and life got in the way, or they weren’t ready, or 

there were financial issues. 

There weren’t institutions like ours around that could accommodate them. So, it was an unfilled life objective, and that’s who most 

of our students are. They are self-directed, they are well motivated, 

they are there because they want to be there, and they have powerful outcomes. 

I’ve given you the data. A lot of that is because of them, because 

they are self-directed goal oriented. They are there because they 

want to be there. Most of them are paying their own way, so they 

take the experience very seriously. 

But you raised a really good question. We have to not over simplify things. To ask an 18-year-old to know what they are going to 

do for the rest of their life is not wise. Most 18 year old’s don’t have 

a clue. Only 22 percent of the people in this country are in professions related to their undergraduate major. Seventy-eight percent 

of us are in areas that had nothing to do with our undergraduate 

major. 

I think higher education ought to be accessible and an opportunity for everyone, but that doesn’t mean everyone needs to go to 

colleges and universities. 

You could make a good case in terms of economic benefit—Mr. 

McComis’ graduates outperformed teachers, nurses, doctors, lawyers. I know I am paying a lot of money to a diesel mechanic right 

now. 

The issue is—I don’t want to get too preachy, but if you go back 

to Thomas Jefferson, Jefferson said, and I’m paraphrasing, but basically the future of the country is dependent upon the quality of 

the human capital, of our people, and education is the vehicle developing that human capital. 

So, the issue is if you create and build the capacity of an educated person, let them have choices and options about how they 

want to pursue and develop their life, be it higher education, be it 

vocational, technical training, and have them prepared to be able 

to make those choices, the country will be okay. 

Mr. ALLEN. That gets back to accreditation. I think in some colleges, they are misleading these young people. Did you have a comment on that? 

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Ms. PETRISKO. I just wanted to say there are many paths 

through life, many paths to and through education. Some students 

will know when they are six years old what they want to do and 

what they want to be and they follow that through forever. Others 

don’t know, change their minds, change careers, find the wrong institution, et cetera. 

I think accreditors absolutely recognize the diversity, we recognize the diversity of institutions, we recognize the diversity of students. I don’t think institutions mislead students. I think institutions provide opportunities for students to figure out what they 

want to do and how they want to get there, and provide the support to do that. They don’t force them. They support them. 

Mr. ALLEN. I think we could do a better job. As usual, I am over 

time. I yield back. 

Chairwoman FOXX. Ms. Blunt Rochester, you are recognized. 

Ms. BLUNT ROCHESTER. Thank you, Madam Chairwoman and 

Ranking Member Scott. I want to thank the panel. This has been 

a really great conversation, the questions, across the aisle. It’s been 

incredible. 

When I think of accreditation, I think of not just the institution 

but I think of parents, as a parent of college students, I think of 

the students. I think of employers. There are so many pieces to 

this. 

I stepped out of the room for a moment because Delaware’s 

Teacher of the Year, Wendy Turner, is here, and she actually started her career as a teacher later in life, so it was a career change. 

My question touches on Congresswoman Bonamici and Congressman Polis’ comments about the boot camps. In Delaware, we actually have a great program. It is called Zip Code Wilmington. It is 

a non-profit. It is a 90-day intensive software development boot 

camp. It was developed both with the employer community, both 

local and nationally. It actually is in partnership with Wilmington 

University and participated in the U.S. Department of Education’s 

Educational Quality Through Innovative Partnerships, or EQUIP 

Program. 

The great thing about it is there are Pell eligible students that 

get to participate in it. I guess my question is for Mr. Miller but 

others can answer as well, about these kinds of programs that are 

unique. It is a partnership between a non-accredited program, 

teaching entity, and an accredited university. They even can get 

college credits and go on to get a Master’s degree or Bachelor’s degree. The success rate is incredible. 

How should we evaluate the success of programs like these that 

partner career training programs with accredited institutions? 

Mr. MILLER. I think fortunately because these are short term 

programs and they have very clear discernable goals, you really 

start with the question of are people finishing them and what is 

happening to them after they finish. 

We just want to make sure, you know, are most people walking 

in the door graduating, and then are they able to get jobs and sort 

of sustain themselves. 

I think the trick here is we should ask that question not just 

three weeks after they leave, but try to look at it over time, too, 

so we can see is this really worthwhile, is it working, et cetera, and 

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that we need a process in place to sort of verify if those outcomes 

are true. 

I think this is also a good example of where we should be experimenting more. I mean there is flexibility in the Higher Education 

Act around trying out sort of new methods, new models, et cetera, 

and EQUIP is a perfect example of it. 

And I think this safe space for Innovation with flexibility that 

says, you know, you’re a good actor, you have good outcomes, we’re 

going to trust you a little bit more to try something new, is how 

we should approach it. Unfortunately, what we have done in the 

past, we sort of tried something, we think it kind of works, and we 

blow the doors open to everybody, so your first 15 actors are great, 

your next 15 are so-so, and then your final 15 after that are bad, 

and you sort of ruin the model for the good actors because the bad 

ones have come in and sort of exploited it. 

Ms. BLUNT ROCHESTER. Quickly, are there any concerns that you 

have about programs like this? 

Mr. MILLER. I mean I think the only major concerns is just that 

they are pretty new, so we just don’t have a great sense as to what 

the long term outcomes look like, and we don’t have a great sense 

of their financial stability. 

The other thing I would just say is some of the other boot camps 

got started really sort of educating people who often already had 

a Bachelor’s degree and maybe had a couple of years of work experience, so you probably are looking at changing the population in 

some of these places, and I think we just want to make sure that 

they are figuring out how to serve people who might be slightly different learners than the ones they had at first, and their model is 

also working for them, or if it’s not, they are adapting it accordingly, and they’re not sort of saying this worked over here, let’s try 

to do something with completely different people and just assume 

it will work. 

Ms. BLUNT ROCHESTER. Anyone else? If not, I just want to say 

you guys, this was a great panel. Thanks, Dr. Pruitt, for the history and the preaching, too. That was good. 

Mr. MCCOMIS. We have had some experience. We have had some 

interest and inquiry from some coding boot camps. We have also 

received some cautionary tales from some other States, not as successful as Delaware, in this particular regard. 

So, on one hand, accreditors do serve a risk aversion role and a 

protection role. So, finding the right balance between those new entrants, those new providers, how to bring them into the system, I 

think as Mr. Miller said, slowly and with some eye towards potential success without having a whole lot of past success to rely upon, 

which is really what accreditors use now in making their assessments about who gets into the process and who gets to go to the 

next step. 

Ms. BLUNT ROCHESTER. Thank you. I yield back my time. 

Chairwoman FOXX. Thank you very much. Mr. Grothman? 

Mr. GROTHMAN. Great. A general question. This can be for any 

of you. I do not believe we have touched on this, because there are 

criticisms of the accreditation programs in a variety of areas. 

I have heard some evidence in which people feel there are arbitrary standards and universities sometimes have to spend money 

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on things that may be unrelated to the actual development of the 

student. 

Can any of you comment on that or think of any anecdotes that 

would apply to? 

Mr. PRUITT. You know, one of the things that Middle States did 

through its last process was to listen to its critics. We invited critics from all over the country to talk to us. We took our standards 

and threw them in the wastebasket, and we started all over again 

and completely redid them. 

Most of the criticisms we got came from the things that we were 

forced to do because of the compliance issues of the Department. 

So, on the new standards, we bifurcated them. We basically said 

here are the things that we don’t think are particularly useful, and 

you know, you don’t think are particularly useful, but we have to 

do them because we’re required to do them. 

Here is the quality assurance piece that your peers have put together that says these are the things we think you have to do to 

meet our qualitative standards. 

Probably 90 percent of the problems that we had were from people that were concerned about the compliance side of the house, 

which we had no control over, and once we separated them, it had 

a remarkable outcome on the buy-in we got from our 500 and so 

institutions on the assessment side, because they saw their community was really looking at the right things. 

Mr. GROTHMAN. Can you think of examples of things that universities had to do in the past that you felt cost them money but had 

nothing to do with quality of education? 

Mr. PRUITT. If you go back a little bit, accreditation was an 

input-based system, how many books did you have in the library, 

what was the square footage ratio, what were the student/faculty 

ratios. 

A lot of things that weren’t necessarily tied directly to learning 

outcomes. That has pretty much changed, and certainly with the 

regionals, that’s gone. That is really not the case anymore. 

There are still compliance costs we have in terms of the reporting, the data requirements. I have four people at my institution 

that do nothing but collect data to fill out forms to report information that doesn’t get used very well. 

My colleague here talked about the IPEDS stuff, they exclude my 

whole student body, the reporting requirements and financial aid, 

we have to notify the Department every time a student drops a 

course. We start a semester every month. We don’t operate on the 

traditional calendar. 

The complexity of just trying to keep up with the reporting requirements is very costly and expensive. I understand why the Department wants to know about student engagement behavior, because they want to know if you change your eligibility, they want 

the financial aid cut off, so I get why it is coming, but the burden 

of complying with it is enormous. 

The overhead costs of managing Federal programs in some cases 

is not worth having the programs. 

I could give you a lot of details on that, but that’s— 

Mr. GROTHMAN. Maybe one more quick thing. I think there is to 

a certain extent a trend towards MOOCs, these big huge courses. 

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I think a lot of time those courses, at least common sense would 

tell you, are superior to the courses being offered in the traditional 

fashion, better professors, way better professors. 

Could you comment on if you feel there are any unfair barriers 

to students using MOOCs more, and just in general, do you feel 

they are to become a bigger, bigger share of our education? 

Ms. PETRISKO. I’d like to answer that. I’m going to try to tie two 

things together here, and that is what is restricting in regard to 

innovation and these other kinds of things. 

One of the things that is currently a requirement for accreditors 

is that if anything is considered to be a substantive change at an 

institution, something really different than what they’ve done before, it must go through accreditor’s review and approval to be able 

to be eligible for Federal financial aid. 

There is not a lot of flexibility. There are some very clear and 

defined things that we must review, although education has gone 

beyond these things as being actually substantive changes in the 

institutions. 

That costs institutions time and money. For some things like the 

MOOCs, for example, some other things that might be new that 

are very innovative and effective, we still have to approve them. 

We would like to have the flexibility as accreditors to determine 

what really does count as something that is substantive that we 

need to review, and where knowing the institution inside and out 

as we often do, where the flexibility can be granted to the institutions to go ahead and do that without that cost and burden. 

Mr. GROTHMAN. Thank you very much. 

Chairwoman FOXX. Thank you, Mr. Grothman. Mr. Mitchell, you 

are recognized for 5 minutes. 

Mr. MITCHELL. Thank you, Madam Chair, and thank you to all 

of you, and for your dedication to addressing this issue. 

I spent 35 years in postsecondary education with a private career 

school group, in fact, sat on an accrediting commission, not one of 

those discussed today, let’s put it that way. 

Dr. Pruitt, I absolutely agree- your comment about accrediting 

agencies existed long before it got tied into Title IV. I think it reflects the need to address the world of accreditation. As we talk 

about the Higher Education Act, we need to start with what should 

the role of the accrediting agencies be. They have evolved into 

being a regulatory agency, a gatekeeper, which makes it a tremendously distorted approach. I saw it in my career, I saw it on the 

accrediting commission. 

We have to recognize that the failures that we see in accreditation simply reflect the failures in postsecondary education and in 

all sectors, not just the for-profit sector, but in fact in the non-profit and public sector. 

There is a direct link between—at least an indicated link between graduation rates and default rates, yet some groups argue 

that we cannot measure graduation rates or we should not measure 

graduation rates, but only 55 percent of freshmen in 2010 now possess a degree or certificate as of 2016. We know what the likelihood 

is, they are more likely to default. 

Rather than set up another oversight—I have forgotten what Mr. 

Miller called it, the quality assurance group, another regulatory 

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burden, why is it we do not create a mechanism to provide consumers information, valid information, so they can assess the value 

of education to their future career. What is so hard about doing 

that and putting out that information so that families, citizens, and 

taxpayers can see what they are getting for their money. Yet, we 

seem to struggle with that. 

Dr. Petrisko, enlighten me what we do to get there, because I 

think consumers desperately need that to understand the burdens 

they are taking on. Maybe Dr. Pruitt, you may want to weigh in, 

too. Please. 

Ms. PETRISKO. So, one of the things that we do requires that all 

of our institutions make public on their website what their student 

learning outcomes are. Then you go to our website, and there is a 

page for every institution that we accredit and outcomes, and there 

is a link where you can go directly from our site— 

Mr. MITCHELL. Let me stop you, you know and I know from my 

experience with Michigan State University, there is a significant 

difference between the outcome of the nursing program and the architecture program. It has a fundamental impact on if people knew 

that, whether or not they would choose to invest in it. 

Let’s be honest, investment in any institution here is based on 

what is the likely outcome, whether they are going to be successful. 

What is so hard about drilling down on that data, provide that 

to consumers and families? 

Ms. PETRISKO. Well, what we do as an accreditor, and perhaps 

you can comment on whether you think this would be a good thing 

to put out to the public, what we require as an accreditor is that 

every institution provide us at the time of reaffirmation, at a midcycle review, getting us updated, what their learning goals are, evidence those goals have been achieved, who is measuring them, 

what they’re doing about it, and when their program reviews are. 

We do that at the institutional level, we do that for general education, we do that for every single program. 

One of our large campuses at the University of California has 

580 programs, so we do ask that for 580 programs. That can be 

drilled down even further. I think it’s a question about how to 

present that kind of information at that level in that much detail 

to the public. 

Mr. MITCHELL. You may not want to go with 580 programs, do 

it by college. You did not indicate employment rates in terms of the 

metrics you’re talking about. Maybe they are in there and I do not 

know. 

Ultimately, most of the students that go through your institutions went through ours. They came there to theoretically get the 

skills to go to work. Ultimately, to pay their loan back hopefully. 

Why are we not reporting that in most institutions other than 

private and for-profit? Why do we not gather that information and 

report it by program? Dr. Pruitt, do you have a comment? 

Mr. PRUITT. I think the key is with a lot of the data is what is 

the reasonable expectation of the program. If you’re coming to a 

program, if you want to be an architect, if you want to be a nurse, 

if you want to be a teacher, it’s reasonable to say what is the performance of our graduates in these areas? 

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If you’re coming in a program where there is no expected definable employment outcome, you are just coming there to be educated 

to increase your own capacity, it’s harder to do. 

I do think we should and many of us do, if you look at our 

websites, you will see that kind of information, and most of us like 

to put it up there because we like to brag about it. The stuff I told 

you this morning about us, because we wanted to brag about it. If 

it wasn’t good, I probably wouldn’t have told you about it. We want 

to do that. 

The issue is the system is very complex, so the challenge is how 

do you come up with useful data that reinforces and gives you incredible information on which to make an informed judgment in 

the programs where you need that information to decide, and that 

varies by program by program, by institution by institution. 

Mr. MITCHELL. One of the things I would like to talk to you further about is the comment you made about the intended outcome. 

I guess one of the questions is ultimately it is taxpayer money 

being invested in the education of adults, helping them vocationally. Is it wise to use taxpayer money for general education from 

Federal financial aid. I think it is a question we need to address 

and goes to some of your concerns. What are we investing in both 

as taxpayers, through Pell grants, Title IV, and through State 

agencies. It is a huge amount of money. 

Mr. PRUITT. I’d love to finish that conversation with you. That’s 

a long one. 

Mr. MITCHELL. We are out of time and the chair has been patient 

with me, so thank you for your feedback. Thank you. 

Chairwoman FOXX. You have been very patient, too, today. I 

want to thank our witnesses again for taking the time to testify before the committee today. 

I think from the comments you have heard from all the members, they have benefitted a great deal from your testimony and 

from this event. 

I do not think people’s comments were just perfunctory. I think 

they really mean that, and I certainly mean it from my perspective. 

I would like to now recognize Ranking Member Scott for his closing comments. 

Mr. SCOTT. Thank you, Madam Chair. This has been a great 

hearing. We got a lot of good information, and it appears 

accreditors can identify those institutions of higher learning that 

should be eligible or ineligible to participate in the Federal student 

financial aid programs, as well as providing important information 

that students should have when deciding how to assess the right 

postsecondary education program. 

The fact that some institutions maintain accreditation right up 

to the day they collapse is evidence that more needs to be done. 

The Federal Government has $150 billion a year interest in getting 

this right. 

So either the accrediting agencies, who should be in the best position to judge the quality of education, must credibly make the assessments, or the Federal Government will have to figure something out that is both fair and workable. 

Hopefully, the progress we have recently made will continue so 

we can rely on the accrediting agencies to assess the quality of our 

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institutions of higher learning, and I thank the witnesses for providing us with good information, and I yield back the balance of my 

time. 

Chairwoman FOXX. Thank you, Mr. Scott. I have found this to be 

a very interesting discussion today, too. It raises a lot more questions for me. I am a little sorry I asked my questions first. I would 

like to come back and ask more, but we do not have time for that. 

I think one of the major questions raised, particularly by Mr. 

Mitchell, right at the end, is a big discussion going on in our culture, and that is what is the purpose of ‘‘higher education.’’ 

I often say that education in our country is basically the only institution that has not changed for 150 years. We’re still operating 

on an Agrarian Model. Nine months out of the year, it started out 

a long time ago three months out of the year. It really has not 

changed, although we have a lot of alternatives, and I think that 

is wonderful. 

I asked Ranking Member Scott when the question came up about 

only 22 percent in jobs related to their degrees. I was an undergraduate English major. I often point that out. That should have 

prepared me for a lot of different jobs, I believe. 

I am a firm believer in liberal arts education, but I saw an article 

this week that said we have to go more into skills development and 

away from liberal arts education, but I think what we are blessed 

with in this country, and I want it to stay that way, is we have 

a diversity of institutions who are there to meet the needs of many 

different people, and the needs of our culture. 

I think we should celebrate that as much as we possibly can. I 

thought, Dr. Petrisko, of your comment about one of the objectives 

of some schools is to teach critical thinking skills. Yet, I read reports all the time that say 34 percent of employers say their employees have no critical thinking skills. How are we getting at 

measuring those kinds of things? 

It is true, I completely agree with Ranking Member Scott, we are 

investing—this is a case where we are spending a lot of hardearned taxpayer dollars in these institutions, and we need to know 

and the public wants to know if it is getting something for its 

money. 

I am happy for the issues to have been brought up about some 

for-profit institutions being closed precipitously, but what troubles 

me is the total lack of concern that the previous Administration 

had with the students in those institutions. It seems to me it was 

so unkind for the Department to simply pull the plug, and I cannot 

blame the accreditors for the students having the problem because 

it was the Department who said we are cutting you off from your 

money and then they closed, without the ability to teach out, without the ability to help those students make a transition. 

That was not the fault of the accreditors, I do not think. The 

accreditors may have had a responsibility. That was the fault of 

very uncaring people in the Department of Education in my opinion, who did not give one thought to what was going to happen to 

the students. 

I want for every student in this country, and I believe Ranking 

Member Scott does, to have the best possible educational experience wherever that occurs. 

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We have to decide as a people are we going to subsidize that educational experience. Again, with taxpayer dollars. 

There is a huge range of issues here to deal with. We cannot take 

care of all of them in a hearing on accreditation. I think this has 

helped us. 

I think one of the things we did not touch on at all that I have 

to bring up and that is are the accreditors looking at the caliber 

of the students being admitted, and what is the responsibility of 

the institutions for admitting students who cannot graduate, who 

do not have the skills, and that is a topic I think for another day. 

Lots and lots of issues. I asked the staff while we were talking 

because I remembered looking at Kiplinger’s Best College Values, 

there are institutions in here who after four years have a 19 percent graduation rate. Lots of issues, not many answers, but lots of 

issues to deal with. 

I thank you for helping us look at some of those issues. There 

being no further business, the committee stands adjourned. 

[Additional submissions by Ms. Petrisko follow:] 

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ABOUT US: 

The WASC Senior College and University Commission (WSCUC) is a regional accrediting agency 

serving a diverse membership of more than 200 public and private four-year higher education 

institutions throughout California, Hawaii, and the Pacific, as well as a limited number of 

institutions outside the U.S. 

WSCUC is recognized by the U.S. Department of Education as certifying institutional eligibility 

for federal funding in a number of programs, including student access to federal financial aid. 

OUR WORK: 

WSCUC helps assure postsecondary quality by requiring compliance with accreditation 

standards and related federal regulations and encouraging continuous improvement among its 

member institutions. 

Leveraging a diverse network of higher education experts from within and outside the region, 

WSCUC conducts ongoing oversight of colleges and universities based on standards spanning a 

variety of factors, from student outcomes and strategic planning to academic programming and 

fiscal stability. These and other metrics are used to determine whether an institution may be 

accredited and therefore eligible to participate in federal financial aid programs for its students. 

OUR PRIORITIES: 

As experts with significant experience in the field, accreditors are uniquely positioned to offer 

the constructive feedback and guidance necessary to help institutions meet high standards and 

improve over time. We encourage a collaborative atmosphere to boost student success, 

compile and highlight valuable data and research findings, and identify and circulate best 

practices among institutions. 

Our priorities include: 

I. PROMOTING INSTITUTIONAL IMPROVEMENT: WSCUC supports efforts to increase 

student achievement through the measurement and evaluation of student outcomes, 

improved stakeholder partnerships, research, and the sharing of resources and best 

practices. 

As part of this effort, we have secured a Lumina grant to increase our institutions' ability 

to provide publicly-available evidence of student learning, as is required by our 
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standards. Additionally, we are cataloging institutional successes, thus encouraging a 

productive and collaborative environment to better serve students in our region. 

II. IMPROVING POSTSECONDARY DATA QUALITY: Recognizing the need to collect and 

provide more comprehensive data on student completion than is currently available 

through I PEDS, WSCUC has developed the Graduation Rate Dashboard. The Graduation 

Rate Dashboard captures data that consider all students, regardless of transfer, 

enrollment status or time to degree, and provides institutions with more actionable 

information. 

WSCUC is also working on predictive modeling to better anticipate graduation rates 

based on student population and institutional type. Continuing to highlight enrollment, 

retention, and graduation patterns across student demographics remains a top WSCUC 

priority. 

Ill. STRENGTHENING TRANSPARENCY AND PEER EVALUATION: WSCUC is dedicated to 

continuous improvement of the accreditation review process, transparency regarding its 

findings and recommendations, and the thorough training and preparation of its peer 

reviewers to conduct effective evaluations. 

We continue to enhance training opportunities, materials and resources provided to 

evaluators to ensure that they are well prepared to fairly and objectively review 

member institutions. Furthermore, since July 1, 2012, we have publicly shared all team 

reports and Commission action letters on the WSCUC website, helping to shed light on 

the challenges and opportunities facing institutions in our region. 

To learn more about WSCUC, visit www. wascsenior.orq. 
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FREQUENTLY ASKED QUESTIONS 

What is regional accreditation? 

Regional accreditation is a robust, low-cost, peer-review system to assure and improve quality 

in higher education. It relies on a diverse network of higher education experts to evaluate 

colleges and universities based on a variety of factors, such as academic programming, student 

outcomes and educational effectiveness. These and other metrics are used to determine 

whether an institution is accredited and therefore eligible to participate in federal financial aid 

programs for its students. There are seven regional accrediting commissions in the United 

States responsible for different assignments of states and institutions. The WASC Senior College 

and University Commission {WSCUC) is the western accrediting agency, responsible for fouryear institutions in California, Hawaii and the Pacific. 

Why does accreditation matter? 

Voluntary, non-governmental, institutional accreditation as practiced by the WSCUC and the 

other regional accrediting commissions is a unique characteristic of American education. In 

many other countries the maintenance of educational standards is a governmental function. No 

institution in the United States is required to seek accreditation; however, because of the 

recognized benefits, most of the eligible institutions in this and other regions have sought to 

become accredited. 

Why is the peer review process important? 

As experts with significant experience in the field, accreditors are uniquely positioned to offer 

the constructive feedback and guidance necessary to help institutions improve over time. We 

encourage a collaborative atmosphere to boost student success, compile and highlight valuable 

data and research findings, and identify and circulate best practices among institutions. 

What are the goals of accreditation? 

The central goal of accreditation is to assure the educational community, the general public, 

and other organizations and agencies that an accredited institution is effectively serving 

students and the public good. Additionally, accreditation is used to help protect taxpayers, 

providing an important layer of oversight in the distribution of federal financial aid. 

How does accreditation help institutions improve? 

To be accredited, institutions must meet standards that represent best practice in higher 

education. The accreditation system also provides an avenue for institutions to collaborate and 

share best practices around assessing and enhancing the teaching and learning process, 

conduct research on improving educational quality and institutional performance, and collect 

valuable data to inform institutional decision-making, planning and improvement. Promoting 

the active interchange of ideas among public and independent institutions furthers the 

principles of improved institutional performance, enhanced educational effectiveness, and 

strengthens the process of peer review. 
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A Better Dashboard 

By Mary Ellen Petrisko and John Etchemendy 

June 30, 2016 

Everyone complains about not getting reliable data on student success, but no one does 

anything about it. Until now, write Mary Ellen Petrisko and John Etchemendy. 

A national outcry regarding the cost of education and the poor performance of institutions in 

graduating their students has raised questions about the extent to which accreditors are 

fulfilling their mission of quality assurance. Politicians have expressed outrage, for instance, at 

the fact that accreditors are not shutting down institutions with graduation rates in the single 

digits. 

At the same time, accreditors and others have noted that the graduation data available from 

the National Center for Education Statistics' Integrated Postsecondary Education Data System, 

familiarly known as I PEDS, include only first-time, full-time student cohorts and, as such, are 

too limited to be the measure by which institutional success is measured-- or by which 

accreditation is judged. But simply noting this problem does nothing to solve it. The imperative 

and challenge of getting reliable data on student success must be more broadly acknowledged 

and acted upon. The WASC Senior College and University Commission (WSCUC) has taken 

important steps to do just that. 

As is well known, I PEDS graduation rates include only those students who enrolled as first-time, 

full-time students at an institution. Of the approximately 900,000 undergraduate students 

enrolled at institutions accredited by WSCUC, about 40 percent, or 360,000, fit this category. 

That means approximately S40,000 students in this region, including all transfer and part-time 

students, are unaccounted for by I PEDS graduation rate data. 

The National Student Clearinghouse provides more helpful data regarding student success: 

while including full-time student cohorts, part-time students are also considered, as well as 

students who combine the two modes, and data include information on students who are still 

enrolled, have transferred and are continuing their studies elsewhere or have graduated 

elsewhere. Six-year student outcomes, however, are still the norm. 

Since 2013, WSCUC has worked with a tool developed by one of us-- John Etchemendy, provost 

at Stanford University and a WSCUC commissioner that allows an institution and our 

commission to get a fuller and more inclusive picture of student completion. That tool, the 

graduation rate dashboard, takes into account all students who receive an undergraduate 
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degree from an institution, regardless of how they matriculate (first time or transfer) or enroll 

(full time or part time). It is a rich source of information, enabling institutions to identify 

enrollment, retention and graduation patterns of all undergraduate students and to see how 

those patterns are interrelated --potentially leading to identifying and resolving issues that may 

be impeding student success. 

Here's how it works. 

WSCUC collects six data points from institutions via our annual report, the baseline data 

tracked for all accredited, candidate and eligible institutions and referenced by WSCUC staff, 

peer evaluators and the commission during every accreditation review. On the basis of those 

data points, we calculate two completion measures: the unit redemption rate and the absolute 

graduation rate. The unit redemption rate is the proportion of units granted by an institution 

that are eventually "redeemed" for a degree from that institution. The absolute graduation rate 

is the proportion of students entering an institution who eventually-- a key word-- graduate 

from that institution. 

The idea of the unit redemption rate is easy to understand. Ideally, every unit granted by an 

institution ultimately results in a degree (or certificate). Of course, no institution ilCtually 

achieves this ideal, since students who drop out never "redeem" the units they take while 

enrolled, resulting in a URR below 100 percent. So the URR is an alternative way to measure 

completion, somewhat different from the graduation rate, since it counts units rather than 

students. But most important, it counts units that all students-- full time and part time, first 

time and transfer-- take and redeem. 

Interestingly, using one additional data point (the average number of units taken by students 

who drop out), we can convert the URR into a graduation measure, the absolute graduation 

rate, which estimates the proportion of students entering a college or university (whether first 

time or transfer) who eventually graduate. Given the relationship between annual enrollment, 

numbers of units taken in a given year and the length of time it takes students to complete 

their degrees-- all of which vary-- the absolute graduation rate is presented as an average over 

eight years. While not an exact measure, it can be a useful one, especially when used alongside 

I PEDS data to get a more nuanced and complete picture of student success at an institution. 

What is the advantage to using this tool? For an institution like Stanford-- where enrollments 

are relatively steady and the overwhelming majority of students enter as first-time, full-time 

students and then graduate in four years-- there is little advantage. In fact, I PEDS data and 

dashboard data look very similar for that type of institution: students enter, take roughly 180 

quarter credits for an undergraduate degree and redeem all or nearly all of them for a degree in 

four years. For an institution serving a large transfer and/or part-time population, however, the 

dashboard can provide a fuller picture than ever before of student success. One of our region's 

large public universities has a 2015 !PEDS six-year graduation rate of 30 percent, for example, 

while its absolute graduation rate for the year was 61 percent. 
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What accounts for such large discrepancies? For many WSCUC institutions, the I PEDS 

graduation rate takes into account fewer than 20 percent of the students who actually 

graduate. The California State University system, for example, enrolls large numbers of students 

who transfer from community colleges and other institutions. Those students are counted in 

the absolute graduation rate, but not in the I PEDS six-year rate. 

As the dashboard includes I PEDS graduation rate data as well as the percentage of students 

included in the first-time, full-time cohort, it makes it possible to get a better picture of an 

institution's student population as well as the extent to which I PEDS data are more or less 

reliable as indicators of student success at that institution. 

Here's an example: over the years between 2006 and 2013, at California State University 

Dominguez Hills, the I PEDS six-year graduation rate ranged between 24 percent and 35 percent. 

Those numbers, however, reflect only a small percentage of the university's student 

population. The low of 24 percent in 2011 reflected only 7 percent of its students; the high of 

35 percent in 2009 reflected just 14 percent. The eight-year I PEDS total over those years, 

reflecting 10 percent of the student population, was 30 percent. 

In contrast, looking at undergraduate student completion using the dashboard, we see an 

absolute graduation rate of 61 percent-- double the I PEDS calculation. Clearly, the dashboard 

gives us a significantly different picture of student completion at that institution. 

And there's more. To complement our work with the dashboard, WSCUC staff members have 

begun work on triangulating dashboard data with data from the National Student 

Clearinghouse and I PEDS to look at student success from various angles. We recognize that all 

three of these tools have limitations and drawbacks as well as advantages: we've already noted 

the limitations of the I PEDS and National Student Clearinghouse data, as well as the benefit of 

the inclusion in the latter's data of transfer students and students still enrolled after the sixyear period. In addition, the data from both I PEDS and the clearinghouse can be disaggregated 

by student subpopulations of gender and ethnicity, as well as by institution type, which can be 

very beneficial in evaluating institutional effectiveness in supporting student success. 

Pilot work has been done to plot an institution's IPEDS and dashboard data in relation to the 

clearinghouse data, displayed as a box-and-whisker graph that provides the distribution of 

graduation rates regionally by quartile in order to give an indication of an institution's success 

in graduating its students relative to peer institutions within the region. While care must be 

taken to understand and interpret the information provided through these data, we do believe 

that bringing them together in this way can be a powerful source of self-analysis, which can 

lead to institutional initiatives to improve student completion. 

As noted, WSCUC has been working with the dashboard since 2013. While we are excited and 

encouraged regarding the benefits of the tool in providing a more complete and nuanced 

picture of student success, we also recognize that we have a great deal of work ahead of us to 

make the tool as useful as we believe it can be. After two pilot projects including a limited 
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number of WSCUC-accredited institutions, the required collection of data by all WSCUC colleges 

and universities in 2015 revealed a number of challenges to institutions in submitting the 

correct data. The dashboard can be somewhat difficult to understand, especially for institutions 

with large shifts in enrollment patterns. And unlike National Student Clearinghouse data, 

dashboard data, at least at this point, cannot be disaggregated to reveal patterns of completion 

for various student subpopulations. 

Such issues notwithstanding, we are encouraged by the value of the dashboard that we have 

seen to date and are committed to continuing to refine this tool. WSCUC staff members have 

given presentations both regionally and nationally on the dashboard, including one to I PEDS 

trainers to show them the possibilities of this tool to extend the data available nationally 

regarding student completion. 

We are hopeful that other accreditors and possibly the NCES will find the dashboard a useful 

tool and, if so, adopt it as an additional completion measure for institutions across the country. 

In any case, we will continue to do this work regionally so as to not just complain about the 

available data but to also contribute to their improvement and usefulness. 

Mary Ellen Petrisko is president of the WASC Senior College and University Commission. John 

Etchemendy is provost of Stanford University. 

https:;jwww.insidehighered.com/views/2016/06/30/new-way-imprave-avai/able-data-studentsuccess-essav 
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WSCUC'S GRADUATION RATE DASHBOARD 

Providing more actionable and inclusive information on student success 

In 2011, the WASC Senior College and University Commission (WSCUC) launched an effort to 

collect and provide more comprehensive data on student success, an effort that led to the 

development of the Graduation Rate Dashboard. The Graduation Rate Dashboard goes beyond 

federally available data reported by the Integrated Postsecondary Education Data System 

(I PEDS) to ensure that all graduates "count" toward an institution's completion rate. 

Currently, federal graduation rate data only cover approximately 40 percent of the nearly one 

million undergraduates in the WSCUC region. WSCUC's Graduation Rate Dashboard, on the 

other hand, captures data on all students, regardless of transfer, full-time or part-time 

enrollment status or time to degree. 

As a result, the Graduation Rate Dashboard provides institutions with more complete and 

inclusive information regarding student success; helps shine a light on enrollment, retention 

and graduation patterns; and allows WSCUC and institutions to better identify and address 

issues that affect student success. 

How the Graduation Rate Dashboard Works: 

As part of the annual reporting required of all institutions, WSCUC collects the following six 

data points: 

1. The unduplicated headcount of all students enrolled in undergraduate degree programs 

during the academic year; 

2. The total institutional units completed during the academic year by students enrolled in 

undergraduate degree programs; 

3. The unduplicated headcount of students who graduated with an undergraduate degree 

or credential during the academic year; 

4. The total, cumulative institutional units completed by those considered "graduated"-

i.e., those counted in item (3)-during their time enrolled in the degree program at the 

institution; 

5. Number of dropouts in the academic year (all enrolled in year 1 but not in year 2 and 

who did not graduate); and 

6. The number of units taken by dropouts in the academic year (all institutional units 

completed by dropouts). 

WSCUC uses this additional data to calculate two completion measures: the Unit Redemption 

Rate and the Absolute Graduation Rate: 
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• The Unit Redemption Rate is the proportion of credits granted by an institution that are 

eventually 'redeemed' for a degree from that institution. The URR is a completion 

measure that can be applied to institutions serving any population of students (full-time 

or part-time, first-time, transfer or swirling), as well as institutions offering different 

degree programs or mixes of degree programs. 

• The Absolute Graduation Rate is the proportion of students entering an institution that 

eventually graduate from that institution. Unlike I PEDS, which only tracks first-time, fulltime students, the Absolute Graduation Rate is inclusive of all students who receive a 

degree from an institution. 

Why the Graduation Rate Dashboard Matters: 

The Graduation Rate Dashboard provides a more inclusive method to identify the enrollment, 

retention and graduation patterns of all undergraduates- regardless of how they matriculate, 

enroll, or the programs they pursue. Given this fact, the Graduation Rate Dashboard often 

shows an institution to have a greater success rate than indicated by I PEDS data. It enables 

institutions to base its decisions and actions on data reflecting the success of all of its students, 

not only a subset. 

To learn more about the Graduation Rate Dashboard, visit 

https://www.wascsenior.org/resources/about-the-graduation-rate-dashboard 
91 

[Additional submission by Dr. Pruitt follows:] 

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23 four-year schools with low costs that lead to high incomes- ED.gov Blog Page I oft! 

HOMEROOM 

THE OFFICIAl BlOG OF THE 

U.S. DEPARTMENT OF EDUCATION 

(https://blog.ed.gov/) 

Home (https://blog.ed.gov/) 

Comments Policy (https://blog.ed.gov/comments-policy/) 

23 four -year schools with low costs that lead to high 

incomes (https://blog.ed.gov/2015/09/schools-with-lowcosts-and-high-incomes/) 

One of the biggest concerns about college that students and families have is the costs 

of attending-and the possible opportunities it could create for their careers. Check 

out 23 four-year institutions of higher education that have demonstrated both high 

earnings, as well as low costs for their lowest-income students. 

Institution 

Amherst College 

fhttps://collegescorecard.ed.goy/schooi/?164465-

Amherst-Collegel 

Bowdoin College 

lhttps://collegescorecard.ed.gov/school/?161 004-

Bowdoin-Collegel 

Median Earnings of Average Net 

Students 10 Years Price for lowAfter Entering the Income 

School Students 

$56,800 $3,739 

$54,800 $6,731 

Brown University $59,700 $6,104 

Chttps://collegescorecard.ed.goy/schooi0217156-

Brown-Unjversityl 

Columbia University in the Cjty of New York $72,900 

{https://collegescorecard.ed,gov/schooi1?19015QColumbia-University-in-the-Cit;y-of-New-Yorkl 

https:l/blog.ed.gov/2015109/schools-with-low-costs-and-high-incomes/ 

$5,497 

211412017 
93 

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23 four-year schools with low costs that lead to high incomes- ED.gov Blog 

Dartmouth College $67,100 

lhttps://col!egescorecard.ed.gov/school/?1 82670-

Dartmouth-Collegel 

Duke University $76,700 

Chttps://www.collegescorecard.ed.gov/school/? 

198419-Duke-U njversit;yl 

Georgia Institute ofTechnology-Main Campus $74,000 

Chttps:!/www.collegescorecard.ed.govtschool/? 

139755-Georgia-lnstjtute-of-Technology-MainCampus> 

Hamilton College $57,300 

!https:/ /collegescorecard.ed.gov/school/?1 91 515-

Hamilton-Collegel 

Harvard University $87,200 

lhttps://collegescorecard.ed.gov/schooi/?166027-

Harvard-Universit;yl 

Haverford College $55,600 

Chttps://collegescorecard.ed.gov/schooi/?212911-

Hayerford-Collegel 

Massachusetts Institute ofiechnology $91,600 

!https://coliegescorecard.ed.gov/school/?1 66683-

Massachusetts-lnstitute-of-Technology\ 

Massachusetts Maritime Academy $79,500 

lhttps:/ /collegescorecard.ed.gov/schooi/?166692-

Massachusetts-Maritime-Academyl 

Princeton University $75,100 

lhttps://collegescorecard.ed.gov/schooi/?186131-

Prjnceton-Unjversityl 

Rice University $59,900 

Chttps://www.collegescorecard.ed.gov/school/? 

227757-Rice-Unjversityl 

Stanford University $80,900 

(https://collegescorecard.ed.gov/schooi/7243744-

Stanford-U njyersityl 

Trinity College $56,100 

Chttps://collegescorecard.ed.gov/schooi/?130590-

Irinity-Coliegel 

https:/lblog.ed.gov !20 15109 /schools-with-low-costs-and-high-incomes/ 

Page 2 of II 

$7,648 

$6,280 

$7,875 

$7,245 

$3,386 

$5,648 

$6,733 

$7,519 

$5,720 

$7,960 

$3,895 

$7,874 

211412017 
94 

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23 four-year schools with low costs that lead to high incomes- ED.gov B!og Page 3 of II 

University of Michigan-Ann Arbor $57,900 

!https://www.collegescorecard.ed.gov/school/? 

170976-University-of-Michigan-Ann-Arborl 

University of Pennsylvania $78,200 

Chttps://collegescorecard.ed.gov/school/?21 5062-

University-of-Pennsylvanial 

University of Virginia-Main Campus $58,600 

Chttps://collegescorecard.ed.gov/schooi/?234076-

University-of-Virginia-Main-Campusl 

Vanderbilt University $60,900 

!https://collegescoreca rd.ed.gov/schooi/?221999-

Vanderbi!t-Universityl 

Washington and Lee University $77,600 

!https://collegescorecard.ed.govlschooi/?234207-

Washjngton-and-Lee-Universityl 

Williams College $58,100 

Chttps:/lcollegescorecard.ed,gov/schooi/?168342-

Williams-Collegel 

Yale University $66,000 

Chttps://collegescorecard,ed.gov/school/?130794· 

Yale-U niversityl 

$7,156 

$6,614 

$7,007 

$7,147 

$7,663 

$8,202 

$7,637 

This list includes schools in the top 10 percent of predominantly four-year-degreegranting schools for 1) median positive earnings 10 years after beginning at the school 

and 2)1ow net price for students receiving federal grants or loans with a family Income 

of $0-$48,000. Net price refers to the net price for in-state students in public 

institutions. Percentiles were calculated excluding cell sizes less than 30, schools with 

zero undergraduate degree-seeking students, schools not currently operating, and 

schools in territories. 

Posts you may also like 

• LGBT Students Work to Ensure Safe and Supportive Schools for all Students 

(https://bl og.ed .gov/20 17/0 1/lgbt -students-work-ensure-safe-supportive-schoolsstudents!) 

• Creating an Educational System that Supports Democracy Through Student Activism 

( https://b log.ed.gov/2017/0 1/creating-educational-system-supports-democracy-studentactivism/) 

• A New Principal- Again (https://blog.ed.gov/2017/01/a-new-principal-again/) 

https :1/blog.ed.gov 120 15/09/sc hoo!s-with-!ow-costs-and-high-incomes/ 2/14/2017 
95 

[Questions submitted for the record and their responses follow:] 

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July 6, 2017 

The Honorable Virginia Foxx 

c/o Caitlin Burke- Legislative Assistant 

Chairwoman, Committee on Education and the Workforce 

U.S. House of Representatives 

2176 Rayburn House Office Building 

Washington, DC 20515-6100 

Dear Chairwoman Foxx: 

2101 W1ls.on Boulevard, Suite 302 

Arlington, Virgm1a 22201 

703 247.4212 

703 247.4533 fax 

www.accsc.org 

Thank you for the opportunity to provide testimony at the Committee on Education and Workforce's 

hearing, ''Strengthening Accreditation to Better Protect Students and Taxpayers" and for the 

opportunity to address the additional questions posed by Committee members. It goes without saying 

that ACCSC embraces the important role that accreditation plays in helping to ensure the quality of 

education provided by its member institutions for students and the continued integrity of the Title IV 

federal student financial aid program. On behalf of ACCSC, I want to express my genuine 

appreciation for the opportunity to continue the dialogue on ways to support Congressional efforts to 

strengthen accreditation. 

As it relates to the Committee's June 9, 2017 letter, ACCSC's response is organized in the order of 

the questions provided by Committee members. 

Chairwoman Vh-ginia Foxx (R-NC) 

Can you desct·ibe your admissions standards? 

The foundation of ACCSC's admissions standards is a belief that admissions criteria are a key and 

front-line indicator of potential students' abilities to be successful in and to benefit from their chosen 

programs. Given this fundamental belief, ACCSC requires institutions to establish admissions criteria 

that are designed to admit only those students who are reasonably capable of successfully completing 

and benefiting from the training offered (e.g., gaining employment). ACCSC does not define those 

criteria, but does expect a school to admit only those applicants who can demonstrate that they 

possess the qualifications that have been formally established by the school via its admissions 

process. 

Moreover, ACCSC requires institutions to secure documentation demonstrating that applicants meet 

the school's admissions criteria prior to those students starting class. In the past, ACCSC found 

instances where institutions were allowing students to "self-certifY" that they had completed high 

school or possessed some other credential without the student having to produce supporting 

documentation. Given ACCSC's belief that admissions criteria are an essential front-line indicator of 

student retention and completion, in 2012 ACCSC issued clarifying guidance on this long-standing 

requirement. As a result, institutions have reported improvement in student preparedness. 

Appendix A provides a copy of ACCSC's admission standards. 
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ACCSC Response to Questions from tlte Committee on Education and the Workforce 

July 6, 2017 

Page 2of8 

Do accrcditors place a responsibility on colleges and universities to only admit those students 

whom they have a reason to believe will successfully complete their t•ducational programs'? 

In ACCSC's case, yes, absolutely. In fact, Section V(A)(l) of ACCSC's Standards of Accreditation 

states that schools are required to develop "admissions criteria that are designed to admit only those 

students who are reasonably capable of successfully completing and benefiting from the training 

offered." Fundamentally, ACCSC's accreditation standards require that admissions decisions be 

based on fair, effective, and consistently applied criteria that enable the school to make an informed 

judgment as to an applicant's ability to achieve the program's objectives. 

This is an area, in our opinion and experience, where the Higher Education Act can be improved. 

Specifically, while 34 CFR §602.16 (a)(l)(vii) requires accreditors to have standards that "effectively 

address the quality of the institution" in the area of admissions, there is too much ambiguity in that 

phrase. Revising the phrase in §602.16 (a)(1) to something along the lines of "[t]he agency's 

standards effectively address the quality of the institution and support student achievement and 

program completion in the following areas ... " would give the U.S. Department of Education, 

accreditors, and institutions more context within which to develop standards and define success. 

Effective admissions standards are those that set both institutions and students up for success. 

Institutions that have high rates of program completion can point to well defined admissions 

standards as contributing factors. 

It is also important to note here that we do not advocate for highly selective or restrictive admissions 

standards. Instead, ACCSC supports finely tuned criteria that are used to identifY areas in which 

students may need additional assistance in order to be successful and that highlight for prospective 

students whether they are adequately prepared for the program. Too many students have taken on 

sizeable debt only to drop out of school without completing. Institutions and accreditors should be 

making every effort to help students make good decisions about enrolling in college. The admissions 

process is a pivotal point in that paradigm. 

How do admission standards diller liJr institutions with open access missions'! 

Given the diversity of institutional missions across higher education, it logically follows that different 

institutions accredited by different types of accrediting agencies would have different standards and 

different expectations regarding student learning and student outcomes. This is both appropriate and 

necessary. 

Having said that, for those institutions with open access missions, understanding what the students' 

needs are, as well as their level of preparedness, is still a necessary measure. What can be said with 

certainty is that an institution with an open access mission is no different than an institution with a 

more selective admissions criteria in that all institutions have an absolute responsibility to ensure 

that each and every student has the necessary skills, as well as access to student services, to be 

successful in the program of study. This explicit expectation, captured under 34 §602.16 (a)(l)(vi 

&vii), underscores why accreditors must ensure that institutions not only have robust admissions 

standards, but also have designed, developed, and consistently deployed a comprehensive student 

service program to help all students navigate their educational experience towards a successful 

outcome. 
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ACCSC Response to Questions from the Committee on Education and the Workforce 

July 6,1017 

Page3 of8 

As an accrediting agency that serves institutions with open access missions, ACCSC is by no means 

limited in establishing an accountability-based model that combines rigorous input standards with 

performance outcomes in categories such as student learning, student assessment, and student 

achievement as measured by student graduation rates, graduate employment rates, and 

certification/licensure pass rates. In ACCSC's 50 years of experience as a recognized agency, 

outcomes measurements work best when complemented with rigorous input standards. While 

institutions with open access missions face their own challenges, those challenges are not 

insurmountable and the Congress, the U.S. Department of Education, and accreditors should not 

lower expectations based solely on that mission. Instead, challenges must be met by those institutions 

that have taken on the open access mission and accreditors should expect those institutions to have a 

tailored student services program designed to meet the breadth and depth of the needs that 

accompany students that may come to them with less academic preparation. 

Rep. Phil Roe (R-TN) 

What an~ the regulations that are preventing accrcdito•·s from focusing on student outcomes'! 

ACCSC does not believe there are any regulations that necessarily prevent accreditors from focusing 

on student achievement. In fact, given the career, vocational, and technical emphasis of the ACCSC 

membership, ACCSC has adopted graduation, employment, and certification/licensure benchmarks 

as an assessment tool to help students, parents, as well as the institutions and the accrediting 

commission itself to make informed decisions about program performance and to better assess 

student outcomes. From ACCSC's vantage point as a recognized accrediting agency, there is nothing 

from a regulatory perspective that is preventing any recognized accreditor, regional or national, from 

focusing on student outcomes. 

Having said that, there has not been an even application of the federal regulation that does exist in 

this regard. 34 CFR §602.16(a)(l)((i) applies to all recognized accrediting agencies and requires 

agencies to demonstrate that its standards address success with respect to student achievement in 

relation to the institution's mission, which may include different standards for different institutions or 

programs, as established by the institution, including, as appropriate, consideration of course 

completion, state licensing examination, and job placement rates. This requirement has been in place 

for over two decades and while national accrediting agencies such as ACCSC that accredits 

institutions with a vocational or career orientation have been held to task to show standards in the 

areas of graduation rates and employment rates, the regional accreditors have not. Even within the 

national accreditation community that accredits institutions with a vocational or career orientation, 

the application of this federal regulation has been uneven and agencies that have "retention" 

requirements and not "completion" requirements have been found to be in compliance in the past. 

Thus, a more definitive statement from the Congress that graduation rates and rates of employment 

or employability! are a requirement for all accreditors and all institutions would be an improvement. 

There are simply too many institutions that accreditors and the public know too little about when it 

comes to assessing rates of graduation- particularly in the realm of online distance education. 

1 My testimony before the Committee on April 27'h underscored the notion that Congress should expect accreditors 

to have rigorous outcomes measures and that it is up to the accreditor to find and define the right set of measures and 

metrics to evaluate institutional and student success. 
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ACCSC Response to Questions from the Committee on Education and the ff'orkforce 

July 6, 2017 

Page4 of8 

Arc there duplicative data collection •·cquireml•nts the Department of Education makes on 

accredito•·s and schools'? 

ACCSC cannot speak to the full array of data collection requirements that the U.S. Department of 

Education makes on institutions. With regard to accreditation, the U.S. Department of Education has 

increased the amount of data and information being requested from accreditors; but because it has 

been requested in the spirit of information sharing between triad partners, ACCSC has had no 

objections with complying with the Department's requests. 

If on the other hand you are speaking of undue regulatory burden on accreditors and institutions, then 

the federal definition of a credit hour (34 §CFR 600.2) is a prime example. By creating the federal 

definition of a credit hour, the U.S. Department of Education federalized a basic academic concept 

and developed a complex and confusing system and then required accreditors to enforce this 

regulation. This serves as an example where accreditation has been co-opted to enforce federal 

overreach and blurs the lines between accreditation's self-defined quality assurance and institutional 

improvement role, and the quasi-surrogacy federal enforcement role that the U.S. Department of 

Education has at times foisted upon accrediting agencies. ACCSC believes that the better approach is 

to eliminate the federal definition of a credit hour and focus more on competency-based 

measurements and the expectations that all recognized accreditors should have rigorous student 

achievement outcomes standards. 

Fundamentally, ACCSC believes that on matters of academic quality assessment, federal intervention 

into the relationship between accreditors and institutions should be minimal. The federal government 

recognizes accreditors as valid and reliable agents of educational quality assessment and as such 

should not also use the federal recognition process to insert the federal government into the peerreview process of accreditation. Doing so accomplishes little more than distracting accreditors from 

focusing their attention on the core aspects of their mission to ensure educational quality at the 

institutions they accredit. 

How l'an innovation in acc•·cditation be encouraged'! 

ACCSC recognizes that for the sake of higher education's advancement, the higher education 

community including accrediting agencies - must be allowed to adapt and innovate in order to 

accommodate the diversity of students served, student preferences, and differentiated learning styles. 

While it is true that many new entrants to higher education generally do not fit the mold of traditional 

accreditation, this is not the prime barrier to allowing entry for innovative approaches. Instead, it has 

been ACCSC's experience that it is the lack of federal funding available for any innovative 

educational approach that falls outside the outdated definition of "seat-time" that is the great 

impediment to innovation. It was reported in 2017 that hundreds of colleges have worked on 

introducing competency-based credentials in recent years, but also that "federal roadblocks" 

including mixed signals on competency based education and audits by the Office of Inspector 

General that have had a "chilling effect on colleges and accreditors." 

Although "direct assessment" is a step in the right direction, it co-exists in federal regulation with the 

federal definition of a credit hour which causes uncertainty on how to move forward with more 

innovative models. As higher education takes a more diverse shape, accrediting agencies and the peer 

review process must foster avenues for institutions to develop and deploy innovative approaches that 

both increase access to higher education and fundamentally change the manner in which education is 
100 

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ACCSC Response to Question.v from the Committee on Education and the Workforce 

July 6, 2017 

Page5 of8 

delivered. Removing the current seat-time requirements and moving toward more competency-based 

assessment models would open pathways for new types of 'programs" that focus on what a student 

knows and can do as opposed to how long the student has been in school. This would encourage 

stair-step programs, "badges," and life-long learning opportunities for more students and would 

produce a far better qualified workforce. 

In addition to allowing for more innovative program design, ACCSC bylieves that allowing for 

differentiation in accreditation and Title IV eligibility would be a significant innovation. By this 

ACCSC means that allowing accreditors and U.S. Department of Education to accredit/recognize 

institutions at different levels that could change the level of federal eligibility or which would allow 

new entrants to "ease" into federal student financial aid programs (e.g., limed access or loans only 

until student achievement outcomes can be demonstrated). Right now accreditation is a binary on-off 

process and access to federal funding goes from zero to infinite. ACCSC believes there are several 

ways to think about this differently. 

Rep. Luke Messer (R-IN) 

Dr. McComis, in your testimony you mention how n•gulatory uncntainty bas been a hindrance 

to institutions who are interested in implementing innovative education models, like 

competency based education. How can Congress provide more flexibility to accreditors to 

promote these types of models? 

Innovative Education Models 

The greatest single impediment to exploring innovative education models like competency-based 

education is that it shares space with the federal definition of a credit hour under 34 CFR §668.8 and 

institutions have been reticent to experiment with an innovative education model for fear that they 

would be out of compliance with Title IV regulations surrounding "seat-time" and the awarding of 

credit hour. Few institutions have been willing to offer competency-based education on a large scale 

outside of the experimental projects because of the inherent risk to an institution's overall eligibility 

for Title IV funding and its "seat-time" based education model. For example, in February 2017, 

American Public University which is accredited by the Higher Learning Commission, announced a 

new competency-based education program, Momentum, designed to further enhance and affordability 

of delivering innovative, career-relevant offerings for working adults, and is doing so, out of 

regulatory necessity, without access to Title IV funding. 

While ACCSC's standards contemplate the suspension of certain accrediting standards for the 

purpose of innovative pilot projects in career-orientated education and training, without federal 

funding, the practical reality is that these programs never see the light of day. This is unfortunate on 

many levels, one of which is the lost opportunity to adjust and improve accrediting standards and 

practices based on innovations in education design and delivery. For ACCSC, the opportunity to 

nurture these programs, particularly those focused on competency assessment, without undue 

regulatory burden is of paramount importance. 
101 

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ACCSC Res{HJnse to Questions from the Committee 011 Education and the Workforce 

July 6, 2017 

Page 6 of8 

Differentiated Accreditation 

ACCSC believes that Congress should consider allowing for differentiated levels of accreditation 

which could place schools in different "categories." The primary purpose of differentiated 

accreditation is to allow accreditors to continue to fulfill their traditional role of working with schools 

toward continuous improvement goals and meeting established standards while also serving as 

gatekeepers to various federal funding programs. Differentiated accreditation could allow for an 

institution to move in and out of eligibility for funding programs, which may be a better option than 

the "all or nothing" binary system that the Higher Education Act acknowledges and that the ensuing 

regulations currently employ. In this new model, an accreditor could make a determination that a 

school can maintain its accreditation while working toward improvement, but at a "different-level" of 

approval than another accredited school approved at a higher level. This different level of approval 

could alter, limit, or suspend the federal financial aid available to new students to use at that 

institution. This approach could also preserve a school's ability to regain full eligibility for federal 

financial aid while also not putting more students and tax dollars at risk at underperforming 

institutions. 

Differentiated accreditation could also be used to allow new entrants to "ease" into federal student 

financial aid programs (e.g., loans only until student achievement outcomes can be demonstrated). 

Right now accreditation is a binary on-off process and access to federal funding goes from zero to 

infinite but there are several ways to think about this differently. 

ACCSC currently uses differentiated accreditation to recognize high-performing institutions that 

demonstrate high levels of success in the accreditation process and student achievement (e.g., 

Schools of Excellence earn an additional year of accreditation based on above-average graduation 

and employment rates). ACCSC is also exploring a diverse array of enhancements that are intended 

to streamline the accreditation process such as establishing an expedited review for institutions with 

established compliance track records, streamlining approval processes for institutions who have 

consistently demonstrated program viability and student performance in program offerings, offering 

more gradations in accreditation decisions, and incentivizing accreditation and a focus on student 

achievement outcomes. 

Rep. Francis Rooney (R-FL) 

Student loan debt is now exceeding $1.3 trillion and another $1.2 trillion in new federal student 

loans are expected to be originate in the next 10 years (CBO). Taxp:tyers have much to gain 

from accreditation reforms that increase learning options and lower educational t•osts. 

How can Congress appmach accreditation rcfonn to implement much needed innovation in 

higher education and link student learning to skills needed in the market place'? 

First, seat-time requirements for funding programs do not preserve academic integrity nor promote 

competency assessment and as such the federal definition of a credit hour and the complex clockhour conversion formulas should be removed from the federal regulations. If accreditors are going to 

be the purveyors of educational quality assessment, then accredilors should be given the discretion 

necessary to define the elements that go into the assessment paradigm. 
102 

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ACCSC Response to Questions from the Committee on Education and the Workforce 

July 6, 2017 

Page 7 of8 

The greatest single impediment to exploring innovative education models like competency-based 

education is that it shares space with the federal definition of a credit hour under 34 CFR §668.8 and 

institutions have been reticent to experiment with an innovative education model for fear that they 

would be out of compliance with Title IV regulations surrounding "seat-time" and the awarding of 

credit hour. Few institutions have been willing to offer competency-based education on a large scale 

outside of the experimental projects because of the inherent risk to an institution's overall eligibility 

for Title IV funding and its "seat-time" based education model. For example, in February 2017, 

American Public University which is accredited by the Higher Learning Commission, announced a 

new competency-based education program, Momentum, designed to further enhance and affordability 

of delivering innovative, career-relevant offerings for working adults, and is doing so, out of 

regulatory necessity, without Title IV funding. 

ACCSC recognizes that for the sake of higher education's advancement, the higher education 

community - including accrediting agencies must be allowed to adapt and innovate in order to 

accommodate the diversity of students served, student preferences, and differentiated learning styles. 

While it is true that many new entrants to higher education generally do not fit the mold of traditional 

accreditation, this is not the prime barrier to allowing entry for innovative approaches. Instead, it has 

been ACCSC's experience that it is the lack of federal funding available for any innovative 

educational approach that falls outside the outdated definition of "seat-time" that is the great 

impediment to innovation. It was reported in 2017 that hundreds of colleges have worked on 

introducing competency-based credentials in recent years, but also that ''federal roadblocks" 

including mixed signals on competency based education and audits by the Office of Inspector 

General that have had a "chilling effect on colleges and accreditors." 

Although "direct assessment" is a step in the right direction, it co-exists in federal regulation with the 

federal definition of a credit hour which causes uncertainty on how to move forward with more 

innovative models. As higher education takes a more diverse shape, accrediting agencies and the peer 

review process must foster avenues for institutions to develop and deploy innovative approaches that 

both increase access to higher education and fundamentally change the manner in which education is 

delivered. Removing the current seat-time requirements and moving toward more competency-based 

assessment models would open pathways for new types of 'programs" that focus on what a student 

knows and can do as opposed to how long the student has been in school. This would encourage 

stair-step programs, "badges," and life-long learning opportunities for more students and would 

produce a far better qualified workforce. 

In addition to allowing for more innovative program design, ACCSC believes that allowing for 

diflerentiation in accreditation and Title IV eligibility would be a significant innovation. By this 

ACCSC means that allowing accreditors and U.S. Department of Education to accredit/recognize 

institutions at different levels that could change the level of federal eligibility or which would allow 

new entrants to "ease" into federal student financial aid programs (e.g., limed access or loans only 

until student achievement outcomes can be demonstrated). Right now accreditation is a binary on-off 

process and access to federal funding goes from zero to infinite. 

Do you think states should be allowed to accredit colleges and courses of study while still 

having access to fedct'al student aid? Could this help local indust.-ies partner with student 

leaming to teach student skills needed in the local market place? 
103 

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ACCSC Response to Questions from the Committee on Education and the Workforce 

July 6, 2017 

Page 8 of8 

While any state certainly could pursue recognition from the U.S. Department of Education, from a 

practical standpoint, this would not seem to be an effective use of state resources (resources that are 

already stretched thin) given that the regulatory framework that already exists, and in consideration 

of the expertise and nuance that the peer-review system of accreditation provides. Currently, each 

member of the regulatory triad - state government, accreditor, and federal government - has an 

essential role to play in the oversight of institutions. From ACCSC's perspective, it would be more 

effective to clarity and to articulate common understandings about the responsibilities of each 

member of the triad, and foster increased communication among triad actors to achieve greater 

commonality across the quality assurance/eligibility enterprise. By continuing to work together in 

partnership with the various organizations within the regulatory triad, ACCSC believes we can 

strengthen the existing oversight system while retaining the positive qualities of the peer-review 

system of accreditation. 

With respect to partnering with local industries, there is nothing in the accreditation system today 

that would prevent an institution from establishing these partnership. In fact, ACCSC requires that its 

accredited institutions utilize Program Advisory Committees made up of representatives from the 

local employment community (among others) in order to provide a formal opportunity for feedback 

to be shared regarding program curriculum, equipment, facilities, as well as student performance 

outcomes. In ACCSC's experience, these types of campus-based initiatives with the local 

employment community is of paramount importance to the sustained success of the institution in that 

community and could be established as a requirement for all recognized accrediting bodies. 

2017 marks ACCSC's SO'h year of recognition from the U.S. Department of Education for ACCSC, 

including earning in 20 II & 2016 consecutive five-year unencumbered recognition grants. Today, 

ACCSC remains committed to helping enhance the student educational experience and student 

achievement outcomes through quality assurance, supporting workforce development, and bridging 

the growing skills gap in the United States. ACCSC believes that accreditors, as the most 

experienced source of information on academic quality, must be given ample trust to establish and 

enforce the standards and practices that best align with the institutions they serve. ACCSC, along 

with other recognized accrediting agencies, continue to demonstrate that the enterprise of 

accreditation is evolving and improving. ACCSC sincerely believes that accreditation can be 

strengthened while retaining the positive qualities and the expertise that peer-review captures without 

undue federally mandated intervention into accreditation affairs. Once again, ACCSC appreciates the 

opportunity to work with Congress on strengthening accreditation and looks forward to continuing 

dialog in this regard. 

Sincerely, 

~u'f.r1,~ Michale S. McComis, Ed. D. 

Executive Director 

ACCSC 
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2101 Wdson Boulevard, Suite 302 

Arlington, Vrrg1n1a 22201 

703 247.4212 

703 247.4533 fax 

www.accsc.,org 

APPENDIX A- ACCSC ADMISSIONS POLICIES AND PRACTICES 

SECTION V- STATEMENT OF PURPOSE 

The purpose of this section is to ensure that schools only admit those students who are capable of 

successfully completing the training offered. Admission decisions must be based on fair, effective, and 

consistently applied criteria that enable the school to make an informed judgment as to an applicant's 

ability to achieve the program's objectives. 

A. General Requirements 

I. A school develops admissions criteria that are designed to admit only those students who are 

reasonably capable of successfully completing and benefiting from the training offered. 

2. A school publishes in its catalog and informs, prior to admission, each applicant for enrollment of 

the program's admission requirements, process, and procedures; the nature of the training and 

education provided; and the program's responsibilities and demands. (See also Section IV (C), 

Substantive Standards, Standards of Accreditation.) 

3. A school consistently and fairly applies its admission requirements. 

4. Prior to enrollment a school: 

a. Determines that an applicant meets the school's admissions requirements; 

b. Secures documentation to demonstrate that each applicant meets all admission requirements;, 

c. Documents that applicants rejected did not meet admissions requirements; 

5. A school maintains documentation covering the last five years that demonstrates that admission 

requirements have been met or that explains the basis for any denial of admission. 

6. A school neither denies admission nor discriminates against students enrolled at the school on the 

basis of race, religion, color, gender, sexual orientation, genetic information, age, disability, or 

national origin. Schools must reasonably accommodate applicants and students with disabilities to 

the extent required by applicable law. 

7. A school may not enroll or admit any person of compulsory school age or any person attending a 

school at the secondary level, unless the school has established through contact with properly 

responsible parties that pursuit of the training will not be detrimental to the student's regular 

school work. 

8. The Commission, at its discretion, may require a school to conduct a study to document the 

effectiveness of its admission requirements for all students. 

B. Non-Degree Programs 

If the school enrolls a person who does not possess a high school diploma or recognized equivalency 

certificate (non-degree programs only): 

!. The determination of the applicant's ability to benefit from the training offered must be confirmed 

by documentation of the applicant's achievement of an approved score on a test or tests that have 

1 See also Appendix V, Substantive Standards, Standards of Accreditation. 
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ACCSC Response to Questions from the Committee on Education and the Workforce 

Appendix A 

July 6, 2017 

Pagel of3 

been reviewed by a qualified, independent third party for appropriateness of the instrument and 

specific score levels required for admission. 

2. The acceptable score ensures that students will benefit from the training provided and that a 

substantial number of students will complete the training and be employed in the field for which 

training was provided. 

C. Degree Programs-Undergraduate 

The school must use appropriate techniques to assess whether applicants have the skills and 

competencies to benefit from the training provided at the undergraduate level. Students admitted to 

associate or baccalaureate degree programs must have earned at least a high school diploma or 

recognized equivalency certificate prior to starting class. 

D. Degree Programs-Graduate 

I. The school must use appropriate techniques to assess whether applicants have the skills and 

competencies to benefit from the training provided at the graduate level. A student admitted to a 

master's degree program must possess an earned baccalaureate degree from a recognized highereducation institution (e.g., accredited by an agency recognized by the U.S. Department of 

Education or the equivalent). All admission criteria, to include evidence of an earned 

baccalaureate degree, must be met prior to matriculation. 

2. For graduate level courses or master's degree programs, standardized or national examinations 

may be required (e.g., GRE or GMAT). The school may utilize other entrance tests that have been 

reviewed by a qualified, independent third party for appropriateness of the instrument and 

specific score levels required for admission. In any case, the school must disclose the type and 

nature of examination and the acceptable score and/or range of scores applicants must receive to 

be admitted. 

E. ESL Courses 

I. Students enrolled in ESL courses must meet all other admission requirements applicable to 

students enrolled in the school's career or occupational programs, which may be established 

through testing in the student's native language. During the enrollment process, adequate 

translation resources must be available to assist students in their comprehension of the process 

and all program requirements. 

2. The school must demonstrate that, with appropriate teaching, the students enrolled in front-loaded 

and integrated ESL courses can qualify for specialized training or continue their occupational 

education. 

ADMISSIONS DOCUMENTATION 

Section V (A){4){b), Substantive Standards, Standards of Accreditation requires that a school "secures 

documentation to demonstrate that each applicant meets all admission requirements" prior to enrollment. 

Because of the importance of admissions requirements and the role those requirements play in allowing 

schools to make infonned admissions decisions, the Commission believes that a school's diligence in 

requiring documentation is a key component to institutional success. Therefore, the Commission does not 

consider a self-certification by a student that he or she has a high school diploma or equivalent to be 
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ACCSC Response to Questions from the Committee 011 Education and the Workforce 

Appendix A 

July 6, 2017 

Page3of3 

"documentation" that the student has met this admissions requirement. The standard contemplates that a 

school will support its admissions decisions with independent documentation such as transcripts and 

copies of diplomas or other documentation of equivalency. Admissions documentation for students from 

foreign countries is to be translated and certified to be at least equivalent to the credential required by the 

school in its admissions criteria (e.g., a U.S. high school diploma). In all cases, it is the responsibility of 

the school to determine whether the credential is appropriate and meets the school's admissions criteria. 

Moreover, the Commission believes that it is the responsibility of each school to make a determination 

that a student meets the school's admissions criteria prior to that student beginning a program of study as 

a means to ensure that the student can perform the level of work required by the program curricula. The 

fundamental rationale is that admissions criteria are a key and front-line indicator of a potential student's 

ability to be successful in a program and as such a school should not admit students to a program of study 

until the potential students can show that those qualifications have been met. The Commission also 

concluded that requiring admissions documentation prior to enrollment aligns with Section V, Statement 

of Purpose, Substantive Standards, Standards of Accreditation which states: 

The purpose of this section is to ensure that schools only admit those students who are capable 

of successfully completing the training offered. Admission decisions must be based on fair, 

~ffective, and consistently applied criteria that enable the school to make an informed judgment 

as to an applicant's ability to achieve the program's objectives. 

As such, the Commission has interpreted that "prior to enrollment" in the context of Section V (A)(4)(a-b) 

means prior to the acceptance of the student through the full execution of the enrollment agreement (e.g., 

signed by the accepting school official) and before allowing a student to start classes. As a practical 

matter, the Commission concluded that a student may sign an enrollment agreement and a school may 

communicate conditional or provisional acceptance of a student prior to receipt of documentation that 

admissions criteria have been met. However, a school may not consider a student fully enrolled and may 

not allow a student to start classes without the requisite documentation. Thus, each school must have a 

policy and procedure for ensuring that admission documentation is secured prior to fully executing the 

enrollment agreement and allowing the student to start class. The Commission also concluded that this 

interpretation applies equally to "conditional" or "trial" periods of enrollment. 

For those ACCSC-accredited institutions that require that an applicant must possess a high school 

diploma or its equivalent for admission, the Commission recognizes that in rare instances students may 

not be able to provide documentation required by a school's admissions criteria due to issues beyond their 

control (e.g., loss of records due to fire or flood, inability to obtain records, home schooled students, etc.). 

In these rare cases, a school may use an admissions test in lieu of documentation of a high school diploma 

or its equivalent. Under these circumstances, the student must sign a statement attesting that he or she in 

fact obtained a high school diploma or its equivalent and state the reason(s) why documentation of the 

earned credential cannot be provided. The admissions test used under these circumstances must be 

reviewed by a qualified, independent, third party and certified as to the appropriateness of the instrument 

and required score levels (i.e., equivalent to a high school diploma). If a school chooses to use such a test 

for these unusual circumstances, this should be stated in the school's admissions policies. 

The Commission understands that other regulatory agencies may have different requirements. Please be 

advised that in instances where these differences exist, the more stringent requirements shall apply 

(Section I (B)(J)(e)(iii), Rules of Process and Procedure. Standards of Accreditation). 
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Education and the Workforce Committee Hearing, Strengthening Accreditation to Better Protect 

Students and Taxpayers, April 27, 2017 

Response of Ben Miller, Senior Director, Postsecondary Education, Center for American Progress to 

Questions for the Record 

June 30, 2017 

What are the regulations preventing accreditors from focusing on outcomes? 

While it is fair to debate the question of improving accreditor regulations, current rules do not 

inherently prevent these agencies from focusing on outcomes. For instance, essentially every national 

accreditation agency has benchmarks for certain outcomes institutions are required to meet. These 

include measures of completion, retention, placement, licensure, and student satisfaction. 

Instead, the problem with the regulations related to outcomes is that they are too vague. Because 

Congress prohibits the Department of Education from looking at the actual content of the measures of 

student achievement accreditors use, there is no mechanism besides internal agency will to ensure they 

set any bars for outcomes, or that the bars they set are sufficiently ambitious. As a result, regional 

agencies do not have any clear standards when it comes to outcomes. This limitation also allows many 

national agencies to set standards in a rudimentary manner, where required thresholds are often set 

just one standard deviation below the median. This approach presumes that the median performance 

level is acceptable. 

Restoring a middle ground between federal oversight and institutional flexibility would help here. At the 

very least, federal reviews of accreditors should consider the student achievement standards set in 

relation to other accreditors. National accreditation provides a perfect example of this. At one point, the 

Accrediting Commission for Career Schools and Colleges (ACCSC) and the Accrediting Council for 

Independent Colleges and Schools (ACICS) oversaw functionally identical branches of colleges owned by 

Corinthian Colleges. The campuses under ACCSC had to demonstrate completion rates of between 36 

percent and 84 percent depending on the program length, and all programs had to have a placement 

rate of 68 percent. The ACICS campuses, meanwhile had to show a retention rate of 60 percent and a 

placement rate of 60 percent.' A very reasonable review would have asked why it is acceptable for one 

accreditor to set weaker student achievement standards versus another. 

The interaction between accreditors and institutions allowed by regulation also complicates the use of 

outcomes. Regional accreditors generally defer to the institutions they oversee to self-define acceptable 

rates of student achievement. The benefit of operating without a standard on student outcomes is that 

it allows one agency to oversee a diverse range of institutional types. But allowing an institution to set 

its own bars for performance can arguably go too far. Some rebalancing, where accreditors could define 

acceptable outcomes for different types of institutions, would help with consistency. 

Are there duplicative data collection requirements the Department of Education makes on accreditors 

and schools? 

The problem is not that the Department requires duplicative data from accreditors and schools, ·it's that 

too often data are decentralized and some of the measures collected are not very useful. For example, 

some accreditors require colleges to submit program-level data on completion. Accreditors cannot rely 

on Department of Education data for program-level data because it only produces graduation rates at 

the institutional level. Even worse, the federal graduation rate measure is useless for schools with large 

numbers of part-time or transfer students. 
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The second issue is that accreditors may not always get access to the wealth of data held by the 

Department of Education. For instance, the department began producing a great deal more information 

about the outcomes for students receiving federal financial aid through the College Scorecard, such as 

earnings and loan repayment. Sharing these new data and at a more granular level (such as by program) 

with accreditors would make their use of outcomes a lot easier. 

Creating a student-level data system at the federal level would streamline the accreditation data 

collection process. If accreditors could get access to comprehensive, centralized federal data on 

completion, loan repayment, and other outcome indicators then it would not have to go to individual 

schools for this information. 

Accreditors recognize the need for these data. Several are already working with the National Student 

Clearinghouse-a private provider that generates better completion data than the federal government 

because they have student-level data that includes individuals who did not receive federal financial aid, 

part-time students, and transfer students. However, using Clearinghouse data comes with other 

limitations. First, it may require a fee from accreditors. Second, the Clearinghouse can only provide data 

for individual institutions if the institution itself grants the Clearinghouse permission to share its data. As 

a result, the accrediting agency must get permission from each of the hundreds of institutions it 

oversees before it can use the data in any meaningful way. The Western Association of Schools and 

Colleges Senior College and University Commission, or WASC, is in the process of getting permission 

from its institutions now. 2 Third, the Clearinghouse can only generate a completion measure for an 

institution after it has collected years of data. While many institutions now share their data with the 

Clearinghouse, it will take some time before a valid completion measure can be generated for some of 

them. Lastly, the Clearinghouse has suboptimal coverage for many for-profit colleges, making this data 

system not as useful as it could be for many of the national agencies. 

Admittedly, finances are one place where there is some duplication of collection. But this generally 

means that accreditors also demand an institution's annual financial audit and financial measures 

collected through collected through the Integrated Postsecondary Education Data System, or I PEDS. 

Though this information is also sent to the department, sharing an audit with multiple parties essentially 

means just forwarding a PDF to a few separate locations. 

How can innovation in accreditation be encouraged? 

We should be clear about what we mean by "innovation" because it can take different forms. There is 

innovation in the sense of having new entities with higher standards act as quality assurance 

gatekeeping agencies. There is innovation in the sense that we can have existing accreditors pursue new 

ways of assuring quality. And there is innovation in the sense of allowing new types of educational 

providers. Each has merit, though the policy solutions are different. 

New quality assurance agencies 

Regulations allow new agencies to petition the Department of Education to serve as gatekeepers of 

federal financial aid. It is unclear why many of the organizations that complain about the existing system 

have not chosen to support the creation of new quality assurance agencies. 

The best way to solve this problem, however, would be to authorize a new system that could operate as 

an alternative to the current accreditation model. This would be a voluntary effort that educational 

providers and traditional institutions could choose to use. It would require new quality assurance 
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entities to put forth standards that hold providers to a high bar for student performance and to 

demonstrate robust financial health.3 

Fortunately, there are some efforts already underway to test out new forms of quality assurance. The 

Educational Quality Through Innovative Partnerships (EQUIP) program created by the Department of 

Education in 2016 is providing a way for new organizations to serve as quality assurance entities. 

Congress should support this effort and ensure that the program continues. 

Improve the existing system 

The current system should be made more flexibile. Accreditors should be given authority to authorize 

differential levels of access to federal financial aid (e.g., approve access to grants but not loans), as well 

set greater restrictions on newly approved colleges. This can mean limiting growth at first, or enforcing 

tougher requirements on colleges trying to expand program types. This will remove the risk of approving 

a new provider that scales up too quickly before it proves it can be successful. In addition, accreditors 

should be encouraged to create different review systems that vary how they approach quality assurance 

based upon the school's outcomes. 

More flexibility should, however, come with oversight. Reviews of accreditation agencies should 

consider the outcomes of schools that are given a differential process and lighter touch to ensure that 

the agencies are not using this authority to lessen requirements on problematic actors. Similarly, 

accreditors where overall results are lacking should not be granted this authority. 

Approve innovative new providers 

As described above, an alternative system would help with this problem. So would changes to the 

current system that take a more thoughtful and cautious approach to new actors. One of the problems 

with the current system is that once an institution secures approval for federal financial aid, it becomes 

eligible for an unlimited amount of federal student aid funds, and removing them from the system is 

difficult. This can create problematic incentives where a model that was designed for one type of 

population and one enrollment size can easily change who it is serving and the scale at which it 

operates. As a result, the accreditation system must anticipate not only whether a new provider will 

high-quality, but also whether some unknown future permutation of the new provider can maintain the 

same level of performance. Getting this initial call wrong can be devastating-a school may get way too 

large, do a terrible job serving students, and continue to do so with few consequences. 

A system that has more processes for easing institutions into the federal financial aid system would 

help. For example, new providers should first have to operate on a reimbursement basis with strict 

limits on growth and enrollment. This would allow accreditors to do more around experimenting with 

new actors because they would not have to worry that an incorrect approval call would metastasize into 

a massive problem. Similarly, it would allow a new provider to work out whether its model still operates 

well as it grows to serve new populations. The Higher Education Innovation Act introduced by Senators 

Marco Rubio (R-Fia.) and Michael Bennet (D-Colo.) provides a good model for how this could work4 

1 Ben Miller, "ACICS Must Go," (Washington: Center for American Progress, 2016), available at 

https://www.american.r:>I.2ilress,grg/issues/education/reports/2016/06/0_§LJ,1~?1_~acics-must-go/ 

1 WASC Senior College and University Commission, "Triangulating Student Success: WSCUC seeks permission for 

data use," available at https://www.wscuc.org/annoucements/wscuc-seeks-permission-data-use 
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3 Ben Miller, David Bergeron, and Carmel Martin, 1

'A Quality Alternative: A New Vision for Higher Education 

Accreditation," (Washington: Center for American Progress, 2016), available at 

https://www.americanprogress.org/issues/education/reports/2016/10/06/145152/a-guality-alternative-a-newvision-for-highe r-ed ucatio n-accred itatio n/ 4 5.2111 Higher Education Innovation Act, available at https:/iwww.congress.gov/bill/114th-congress/senatebill/2111 
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June 30, 2017 

Dr. Virginia Foxx 

Chairwoman 

Committee on Education and the Workforce 

U.S. House of Representatives 

2176 Rayburn House Office Building 

Washington, DC 20515-6100 

Dear Chairwoman Foxx: 

Thank you for your letter of June 9, 2017 providing additional questions as a follow-up to the April 

27, 2017 hearing, "Strengthening Accreditation to Better Protect Students and Taxpayers." I am 

pleased to receive these additional questions and have provided my responses in the enclosure. 

would be happy to provide additional information as it may be helpful. 

Thank you for the opportunity to assist the House of Representatives Committee on Education 

and the Workforce in its important work. 

Sincerely, 

Mary Ellen Petrisko 

President 

WASC Senior College and University Commission 

YHS At.l;wtic Avt>nLH~, Suitt.• !00, AlamNh, CA 94:!()1 • phon v~ S10.74H.9001 • P-fax: •WI'I'W.wsqworg 
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Committee on Education and the Workforce 

U.S. House of Representatives Information Request 

June 30, 2017 

Chairwoman Virginia Foxx (R-NC) 

Can you describe your admissions standards? Do accreditors place a responsibility on colleges and 

universities to only admit those students whom they have reason to believe will successfully complete 

their educational programs? How do admissions standards differ for institutions with an open access 

mission? 

At the WASC Senior College and University Commission (WSCUC), admissions are addressed primarily at 

the time of application for eligibility for accreditation, to ensure that all institutions eventually admitted 

to Candidacy or granted Initial Accreditation have appropriate admissions policies and procedures. 

There is also a stress on institutions' providing sufficient information to the public so that a prospective 

student can determine whether a particular institution is one at which he or she has a good chance of 

success. There is not a different requirement for institutions with an open access mission. As noted 

below, every institution must have admissions policies "consistent with its purposes" that specify 

prospective student qualifications Institutions must also provide clear and honest information about 

themselves to aid prospective students in deciding whether to apply. 

The WSCUC manual How to Become Accredited (https://www.wscuc.org/content/How-to-Become) 

includes Eligibility Criterion 15. Admissions: 

The institution has adopted and adheres to admission policies consistent with its purposes that 

specify the qualifications of students that are appropriate to the degree levels offered. 

[emphasis added] 

This Criterion specifies that an institution applying for eligibility must provide: 

a copy of its admissions policy from a published statement, including criteria for 

admission; 

a copy of its enrollment application; 

any articulation agreements with other institutions; and 

marketing or outreach plans and materials. 

A responsibility is placed on colleges is to be clear and honest with regard to other information about 

the institution as well. Eligibility Criteria 3. Public Information is also relevant to this question: 

The institution publishes in its catalog, or in other appropriate places, accurate and current 

information that describes its purposes and objectives, admission requirements and procedures, 

financial aid policies and procedures, rules and regulations directly affecting students, programs 

and courses, degrees offered and the degree requirements, costs and refund policies, formal 

and informal grievance procedures, academic credentials of faculty and administrators, and 

other items relevant to students' attending the institution or withdrawing from it. 

This Criterion specifies that an institution applying for eligibility must provide general information that 

must include at least the following: 

official name, address, telephone, website 

• educational mission 

• course, program, degree offerings 

• academic calendar and program length 
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available student financial aid 

available learning resources 

names and degrees of administrators and faculty 

names of governing board members 

• admissions criteria and processes 

• student fees and other financial obligations 

• all degrees, diplomas, and certificates currently offered 

graduation and transfer policies 

Criterion 3 also requires that an institution applying for eligibility provide major policies affecting 

students: 

academic regulations including academic honesty 

nondiscrimination policies and procedures 

acceptance of transfer credits 

grievance and complaint procedures 

sexual harassment policies and procedures 

refund of tuition and fees 

location of publications where other policies may be found 

Rep. Phil Roe (R-TN) 

What are the regulations that are preventing accreditors from focusing on student outcomes? Are 

there duplicative data collection requirements the Department of Education makes on accreditors and 

schools? How can innovation in accreditation be encouraged? 

The Council of Regional Accrediting Commissions (C-RAC) has compiled a list of recommendations 

regarding current regulations that we hope will be taken into account with a next reauthorization of the 

Higher Education Act. I have attached those recommendations here (Attachment A). They have also 

been shared with the Senate HELP Committee. 

The data that are collected from accreditors are primarily those related to actions taken on accredited 

institutions. I do not believe that there is significant duplication compared to the data that are collected 

from institutions. 

Regional accreditors are unfairly accused of stifling innovation. We actually are supportive of 

innovation, as long as students' interests are protected and the quality and sustainability of the 

institution are maintained. That being said, one way in which innovation in accreditation could be 

encouraged would be to allow accreditors the flexibility to determine when certain requirements tied to 

federal regulation might be waived to allow for experimentation and innovation. Accreditors would be 

able to determine, given the particular situation of an individual institution, whether that institution 

could experiment with new types of programs and/or program delivery without having to go through 

normal channels of substantive change (see 34 CFR 602.22). 

Rep. francis Rooney (R-fl) 

Student loan debt is now exceeding $1.3 trillion and another $1.2 trillion in new federal student loans 

are expected to be originated in the next 10 years (CBO). Taxpayers have much to gain from 

accreditation reforms that increase learning options and lower educational costs. How can Congress 
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approach accreditation reform to implement much-needed innovation in higher education and link 

student learning to skills needed in the marketplace? Do you think states should be allowed to 

accredit colleges and courses of study while still having access to federal student aid? Could this help 

local industries partner with student learning to teach students skills needed in the local marketplace? 

As stated in my response to Rep. Roe, allowing accreditors the flexibility to waive requirements tied to 

federal regulations would be a helpful step in enabling institutions to experiment and implement 

innovative offerings. With regard to linking student learning to skills needed in the marketplace, WSCUC 

includes the following in its standards for accreditation under Standard 4: Creating an Organization 

Committed to Quality Assurance, Institutional learning, and Improvement, to help ensure that 

institutions are aware of and responding to marketplace and other societal needs with their offerings: 

Criterion for Review 4.5: Appropriate stakeholders, including alumni, employers, practitioners, 

students and others designated by the institution, are regularly involved in the assessment and 

alignment of educational programs. 

Criterion for Review 4.6: The institution periodically engages its multiple constituencies, 

including the board, faculty, staff, and others, in institutional reflection and planning processes 

that are based on the examination of data and evidence. These processes assess the 

institution's strategic position, articulate priorities, examine the alignment of its purposes, core 

functions, and resources, and define the future direction of the institution. 

Criterion for Review 4.7: Within the context of its mission and structural and financial realities, 

the institution considers changes that are currently taking place and are anticipated to take 

place within the institution and the higher education environment as part of its planning, new 

program development, and resource allocation. 

With regard to states, which have largely reduced their traditional responsibilities within the triad of 

quality assurance consisting of the federal government, states, and accreditors, I do not believe that it is 

reasonable or prudent to assume that there is sufficient capacity to conduct the kind of evaluation 

needed to assure the quality of colleges and universities. Accreditors' evaluations of the wide variety of 

institutions with access to federal student aid depend on qualified peer evaluators who understand the 

complexities of those diverse institutions. State organizations, to the extent that they exist, do not have 

the capacity to perform such evaluations. Additionally, the peer evaluators who conduct institutional 

reviews do so on a voluntary basis, keeping the costs of accreditation low. States would require greater 

financial resources to allow them to conduct these reviews, even if they had qualified staff to do so. The 

need for local industries to partner with institutions of higher education to ensure that workplace needs 

are taken into consideration in educational offerings can be met through accreditors' current 

requirements, as noted in the Criteria for Review cited above, as well as through direct collaboration 

between employers and colleges and universities. See, for example, the activities of the Business-Higher 

Education Forum (www.bhef.com), which brings together Fortune 500 CEOs and college and university 

presidents to address this issue. 
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Attachment A 

Recommendations for the Reauthorization of the Higher Education Act (HEA) 

Council of Regional Accrediting Commissions (C-RAC) 

1. Reduce burden and costs of accreditation by repealing language that forces accreditors to seek 

separate approval in their scope of recognition for reviewing distance education and 

correspondence education. 

Background: 

The Higher Education and Opportunity Act of 2008 (HEOA) added to HEA new requirements for 

accreditors evaluating the quality of institutions or programs offering distance education or 

correspondence education. These requirements (and their corresponding regulations) have added 

burden and costs to the accreditation process but have not provided any meaningful benefit to 

institutions or students. Thus, these additional requirements should be repealed, and the academic 

integrity of institutions and programs delivering education through these or any future modalities 

should be evaluated in the same manner as all other institutions and programs. 

Proposed Language: 

Strike section 496(a)(4)(B) as follows: 

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2. Reduce the institutional paperwork burden related to "substantive change" requirements, and 

allow accreditors greater flexibility in determining when approval is necessary. 

Background: 

Under current law, institutions must seek approval from their accreditor in cases where they 

establish a branch campus or have a change of ownership. These "substantive change" 

requirements are vastly expanded under HEA regulations, which dictate the specific conditions in 

which approval is necessary. This rigid system provides very little flexibility for accreditors to make 

case-by-case determinations of when separate approval is truly necessary and has led to accreditors 

reviewing thousands of substantive change requests each year, at huge cost to both accreditors and 

institutions. 

Proposed Language: 

Amend section 496(c), paragraphs (4) and (5), as follows: 

(c) OPERATING PROCEDURES REQUIRED.-No accrediting agency or association may be 

recognized by the Secretory as a reliable authority as to the quality of education or training 

offered by an institution seeking to participate in the programs authorized under this title, unless 

the agency or association- ... 

(4} requires that any institution of higher education subject to its jurisdiction which plans to 

establish a branch campus, submit a plan far approval to the accrediting agency or 

association in accordance with standards promulgated by such agency or association , 

sw9FI'Iit 11 9wsiRess p111R, iRslwdiRg pt'GjesteEI reveRwes llREI eNpeREiitwres, prier te epeRiRg 

the BF9R£R 61lTRpws; 

(5) agrees to conduct, 11s seeR llS pr~~sfi61l9Je, 9wt withY! 11 pe1#eEI fi{Ret R!9<e tllllR fi 

RI9Rths 9} upon the establishment of a new branch campus or a change of ownership of an 

institution of higher education, a review of such branch campus or institution.~ 

1•\!i't ef th11t 9,qm£il &llmpws er ef tile iRstitwti9R 11/Hr 11 shiiRge ef 91''Rersldp in accordance 

with standards promulgated by such agency or association; 
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Amend section 496(o) as follows: 

(o) REGULA T/ONS.- The Secretary shall by regulation provide procedures for the recognition af 

accrediting agencies or associations and for the appeal of the Secretary's decisions. 

Notwithstanding any other provision of law, the Secretary shall not promulgate any regulation 

with respect to the standards of an accreditation agency or association described in subsection 

{a){S), or with respect to the operating procedures implemented by an accreditation agency or 

association pursuant to subsection (c/(4/ or (c/(5/. 

3. Provide a path for accreditors to seek waivers of rules and regulation that block innovation. 

Background: 

The efforts of accreditors to enable innovation in higher education are at times made more difficult 

by statutory or regulatory limitations. Although these provisions may often serve an important role 

toward ensuring quality and integrity, the lack of flexibility in how they are applied can have the 

unintended consequence of forcing accreditors to reject innovative programs or institutional 

initiatives that accreditors would otherwise find have clear academic integrity. 

Although these barriers often extend beyond the purview of accreditors, C-RAC believes there 

should at least be a process through which accreditors have the ability to signal to the Department 

of Education that certain initiatives warrant consideration for having specific statutory or regulatory 

barriers waived. 

Proposed Language: 

Add a new section 498(r), as follows: 

(r} Waiver.-The Secretary shall establish a process through which an agency or association 

may seek to have a provision of law under this subpart {Subpart 2 -Accrediting Agency 

Recognition/ waived, if such agency or association demonstrates that such waiver is necessary 

to enable a program or institution of high integrity and quality to implement innovations and 

such agency or association describes the terms and conditions such agency or accreditor will 

place upon the program or institution to ensure academic integrity and quality. 

4. Ensure that students and the public have access to information on the quality and accreditation 

status of institutions. 

Background: 

Under current law, an accreditor is required to make certain information available to the public, 

including: 

Whenever an institution of higher education subject to its jurisdiction is being considered 
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for accreditation or reaccreditation; 

Summaries of agency or association actions (including award of accreditation, 

reaccreditation or adverse actions); and 

Upon request, a summary of any reviews resulting in a final accrediting decision involving 

denial, termination, or suspension of accreditation, together with the comments of the 

affected institution. 

The proposed language strikes "upon request" to ensure this information is more readily available 

without students and parents having to make a special request. In addition, this proposal expands 

the types of information made publica fly available and includes new language to ensure that 

institutions are disclosing consumer information to students as required under Section 132(i). 

Proposed language: 

Amend section 496(a)(8) as follows: 

(8) such agency ar association shall make available to the public, wp9R Felflle5t the Secretary, 

and the State licensing or authorizing agency a summary of any review resulting in a final 

accrediting decision involving denial, termination, or suspension of accreditation, together with 

the comments of the affected institution. 

Amend the following new paragraphs to section 496(c): 

(c) OPERATING PROCEDURES REQUIRED. -No accrediting agency or association may be 

recognized by the Secretary as a reliable authority as to the quality of education or training 

offered by an institution seeking to participate in the programs authorized under this title, unless 

the agency or association-

(7) makes available to the public and the State licensing or authorizing agency, and 

submits to the Secretary, a summary of agency or association actions, including-

(A) the award of accreditation or reaccreditation of an institution; 

(B) final denial, withdrawal, suspension, or termination of accreditation of an 

institution, and any findings made in connection with the action taken, together 

with the official comments of the affected institution; and 

(C) any other adverse action taken with respect to an institution or placement on 

probation of an institution; 

(8) discloses publicly whenever an institution of higher education subject to its 

jurisdiction is being considered for accreditation or reaccreditation; and 

(9) confirms, as a part of the agency's or association's review for accreditation or 

reaccreditation, that the institution has transfer of credit policies-

(A) that are publicly disclosed; and 
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(B) that include a statement of the criteria established by the institution 

regarding the transfer of credit earned at another institution of higher 

education. 

(10} makes publicly available, an the agency or association's website, a list of the 

institutions of higher education accredited by such agency or association, including -

(A} the year accreditation was granted; 

(8} the most recent date of a comprehensive evaluation of the institution; and 

(C} the anticipated date of the next such evaluation; and 

(11} confirms, as a part of the agency's or association's review for accreditation or 

reaccreditation, that the institution's website includes consumer information on 

students outcomes as described section 132(i}. 

5. Ensure continuous monitoring of institutional quality and effectiveness. 

Background: 

The Act currently requires the regular review of institutions by accreditors. Many accreditors do this 

through the annual review of data submitted by institutions. 

The proposed language would provide more flexibility to accreditors by striking requirements for onsite reviews and prohibiting the Secretary from regulating on how accreditors perform such reviews, 

while requiring agencies to have policies in place that include annual monitoring of indicators of 

quality and program effectiveness. 

Proposed Language: 

Amend section 496{c) as follows: 

(c) OPERATING PROCEDURES REQUIRED.-No accrediting agency or association may be 

recognized by the Secretary as a reliable authority as to the quality of education or training 

offered by an institution seeking to participate in the programs authorized under this title, unless 

the agency or association-

(1) performs_at regularly established intervals, eR site ;115f1BGti!IIIS !llld cevi~H..s ef 

!Rstitwtiells efll!.gller edwGeti!lll fwil!61! lllll'Y !IIGJwfle Wllll'llllll'WII&edsi*e •·!sits) ••\;f:ll 

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Fe5f19Rsibilifies1 i11slwdiRg tl:tese regE1rdi11g fl;stfiRGe efiwGflfi!lll for each institution at 

higher education that such agency or association accredits or pre-accredits, a review~ 

that includes monitoring against education quality and program effectiveness 

indicators in accordance with policies promulgated by the agency or association; 
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(21 ensures that accreditation team members are well-trained and knowledgeable 

with respect to their responsibilities, including those regarding distance education; 

(o) REGULA T/ONS.- The Secretary shall by regulation provide procedures for the recognition of 

accrediting agencies or associations and for the appeal of the Secretary's decisions. 

Notwithstanding any other provision of low, the Secretary shall not promulgate any regulation 

with respect to the standards of an accreditation agency or association described in subsection 

(a)(S), or with respect to the operating procedures of an accreditation agency or association 

described in (c/(1}. 

6. Restrict lawsuits against accreditors to federal court. 

Background: 

Under the Act, any civil suit brought by an institution that involves an adverse action must be 

brought to the appropriate United States district court. This has left open the ability for third parties 

to sue on behalf of such institutions in state courts. The proposed language would ensure ill! 

lawsuits of this nature be brought to federal court including those bought by third parties. 

Proposed Language: 

Amend section 496(f) as follows: 

(f) JURISDICTION. -Notwithstanding any other provision of law, any civil action bl'eii!Jht by EHI 

iRStitflti9R fJ/ Ri!JReF efli/G9ti91'1 5eekfi'I!J9GGI'eflitrlti9R f"9F», 9F riGGI'efliteEJ by; 9R riGGFeEJitii'I!J 

r~geRsy 9r 9559Gi&ti9R reG9!JRiJeEJ by the SesretBPf ,frH' the purp9se 9/thi& title &Rd involving the 

denial, withdrawal, or termination of accreditation, or the pre-accreditation of an #!e institution 

of higher education, shall be brought in the appropriate United States district court. I 

7. Ensure that accreditors are separately incorporated and jndependent. 

Background: 

Regional and specialized accreditors have increasingly moved toward becoming "separate and 

independent" entities. In nearly all cases, regional accrediting commissions are separately 

incorporated. And recent situations- especially in nursing (ACEN) and psychology (APA) --illustrate 

the problems that can occur when specialized accreditors are embedded within membership 

organizations and cannot, for example, ensure that their assets will be protected (ensuring their 

independence) or that they can sufficiently distance themselves from the conflict-of-interest 

problems inherent within a parent organization. Ensuring that accreditors are truly "separate and 

independent" can increase public confidence in accreditation. 
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Proposed Language: 

Amend section 496(a)(3) as follows: 

(3) if such agency or association is an agency or association described in-

(A) subparagraph (A)(i) af paragraph (2}, then such agency or association is separatelY_ 

incorporated and independent, both administratively, and financially af any related, 

associated, or affiliated trade association or membership organization. 

Amend section 496(b) as follows: 

(b) SEPARATELY INCORPORATED AND INDEPENDENT DEFINED. -For the purpose of 

subsection {a){3}, the term "separately incorporated and independent" means that-

(1) the members of the postsecondary education governing body of the 

accrediting agency or association are nat elected or selected by the board or 

chief executive officer of any related, associated, or affiliated trade association 

or membership organization; 

(2) among the membership of the board of the accrediting agency or association 

there shall be one public member (who is not a member of any related trade or 

membership organization) far each six members of the board, with a minimum 

of one such public member, and guidelines are established for such members to 

avoid conflicts of interest; 

(3) dues to the accrediting agency or association are paid separately from any 

dues paid to any related, associated, or affiliated trade association or 

membership organization; and 

(4) the budget of the accrediting agency or association is developed and 

determined by the accrediting agency or association without review or resort to 

consultation with any other entity or organization. 
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111 W. State St. 

Trenton, NJ 08608 

www.tesu.edu 

The Honorable Virginia Foxx 

c/o Ms. Caitlin Burke, Legislative Assistant 

Committee on Education & the Workforce 

2257 Rayburn House Off'JCe Building 

Dear Chairwoman F oxx: 

June 26, 2017 

Office of the President 

(609) 984-1105 

Fax: (609) 989-9321 

gpmitt@tesu.edu 

It was my honor to testify on April27'" before the Committee on Education and the Workforce at 

its hearing entitled "Strengthening Accreditation to Better Protect Students and Taxpayers." I have received 

your letter dated June 12''. and l am pleased to respond herewith to questions that were forwarded from 

members of the Committee. 

The following questions were posed by Representative Phil Roe: What are the regulations that are 

preventing accreditors from focusing on student outcomes? Are there duplicative data collection 

requirements the Department of Education makes on accreditors and schools? How can innovotion in 

accreditation be encouraged? 

Accreditors have focused on student outcomes for years, but the definition of what constitutes 

student outcomes has changed, especially recently. Under the regulations 34 CFR 602.16(a)(l )(i) -

accreditation standards must address student achievement in relation to an institution's mission. For years, 

regional accrediting agencies such as the Middle States Commission on Higher Education (MSCHE) 

addressed student achievement through emphasis on the outcomes of student learning. Under these 

standards, there has been a requirement that accredited institutions demonstrate that students accomplish 

educational goals consistent with their programs of study, degree level, the institution's mission, and 

expectations for higher education. This assessment of student learning outcomes emphasizes understanding 

and improving teaching and learning. 

More recently, the focus on student achievement has shifted toward measures/metrics of student 

success. The press, some higher education rese81Chers, and the National Advisory Committee on 

Institutional Quality and Integrity (NACIQI) all are pushing in this direction. While regional accreditors 

have been open to exploring the use of available data, the Commissions have done so with care and caution. 

That care and caution is warranted because the available data does not, as I indicated in my testimony, 

provide an accurate picture for all institutions. For example, l described the situation at Thomas Edison 

State University where a very small percentage of our students begin as first-time full-time students. 

Because of tha~ the vast majority of students are not counted in the cohorts that are the basis for federal 

graduation rate calculations, and the rates are then meaningless as a basis for making any judgment about 

the University. The limitations of the data are well known and have been reported as recently as this past 

week in a lengthy article that appeared in The Chronicle of Higher Education under the headline "Colleges 

Face More Pressure on Student Outcomes, but Success Isn't Always Easy to Measure." 
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2 

Even with data limitations in mind, the Council on Regional Accrediting Commissions (C-RAC) 

has collectively created a Graduation Rates Project that has focused on institutions with federal data 

showing graduation rates that are half or less of the national averages. That project is ongoing, however, 

some conclusions are already obvious. For example, the federal datahases and websites need to be 

consolidated to avoid the confusion created when there are differing statistics simultaneously available for 

a single institution. In addition, data improvements (e.g., expansion beyond first-time full-time cohorts, 

etc.) need to be made as quickly as possible so that the data is meaningful. Also, there needs to be more 

contextual information presented so that inquirers can better understand and make judgements about an 

institution. Today, the majority of students participating in higher education are over the age of 25, 

attending school part-time. If you are a part-time student taking four courses a year, it will take you 10 

years to earn a baccalaureate degree. Mixing persistence rates of full-time and part-time students as is the 

current practice yields graduation rates that are misleading and useless as a measure of institutional quality 

or effectiveness. 

With regard to the means by which innovation in accreditation can be encouraged, I believe that 

accreditors are already doing what they can to innovate and to encourage innovation by the institutions that 

they accredit. New accreditation standards, new accreditation processes, updated policies, and improved 

infrastructure including information technology systems all are being developed and implemented, and all 

modernize accreditation. One limitation, however, is the need to innovate within the context of regulations 

such as those pertaining to substantive change. Substantive change rules require prior approval of a very 

specific and long list of institutional changes ranging from contractual relationships with non-accredited 

entities to approval of additional locations and branch campuses. If, through law or regulation, accreditors 

could grant exceptions or exemptions to trusted institutions, innovation could be encouraged. Currently, 

this is done through the defined Experimental Sites programs of the Department of Education. These are 

programs that often require approvals from accrediting agencies as well as the Department. If such 

experimentation could be allowed directly through the accreditors, it is likely that the process could be 

faster and less cumbersome for institutions wishing to innovate. And, of course, it would still be done under 

the ultimate oversight of accreditation that is exercised by the Department of Education. 

The following questions were posed by Representative Lulre Messer: As a former member of the 

National Advisory Committee on Institutional Quality and Integrity (NACIQI), what do you think the 

ramifications will be far students and taxpayers if many of the 245 institutions currently accredited by 

Accrediting Cormc/1 for Independent Colleges and Schools (ACJCS) are not able to find a new accreditor? 

If those institulions lose Title W funding, what do you think should be done to help students transition to 

other schools? And what can be done to help encourage other schools to accept their credits? 

Representative Messer further states: You mention in your testimony why you don't think the 

Education Department's "scorecard" works well in providing useful information to students. Clearly, as 

legislators, we want to empower students to make good decisions about who/ school they attend and hold 

institutions accormtable. How do we strilre the right balance of reporting that will hold instiiUiions 

accormtable and also empower students? 

I believe that accreditors and the Department have been working together to provide as many 

opportunities as possible for transition of ACICS accredited institutions to other recognized accrediting 

agencies. Many of the affected institutions may be most interested in transitioning to another national 

accreditor of similar institutions. It is my understanding that the federal student aid division of tha 

Department has been overseeing the situation and has set a series of benchmark deadlines. 

A few of the affected institutions have expressed interest in regional accrediting agencies. 

However, one of the issues has been the relatively short period of time - 18 months I believe - that those 
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3 

institutions will have to find another accreditor. Applicants for regional accreditation must progress through 

applicant and candidacy statuses. In the case of the Middle States Commission on Higher Education, the 

candidate institution must be able to prove compliance with all Requirements of Affiliation and Standards 

before accreditation can be granted- a process that must be faithfully followed and can take up to five years 

to complete. The time frames just do not mesh well. 

There may be some institutions that will not be able to make a transition to meeting the 

requirements and standards of another accrediting agency within the allowed timeframe. Some institutions 

may close and then teachout agreements would assist students with placements at other institutions. In my 

experience, where possible and practical, other institutions do step up to assist students in situations like 

this, provided that the receiving institution can uphold usual academic quality standards and expectations. 

Moving to the topic of the "Scorecard,n you are correct that I indicated in my testimony that I do 

not believe that it works well in providing useful information to students as the basis for informed decisions 

about which schools to attend or as a means by which to hold institutions accountable. Further, you ask 

how best to balance the need to provide a reporting that holds institutions accountable and empowers 

students. I have reiterated some of my concerns about currently available data in my response to a question 

raised by Representative Roe (see separate section of this Jetter). 

Perhaps what is most important now is a need to hit the "pause button" while experienced and 

responsible people make decisions about what needs to be done regerding data, and changes are actually 

implemented. Right now, we have a situation where inadequate data sets are being used to form opinions 

and make decisions. I do not believe that this is good public policy. For example, NACIQI should not be 

making decisions about accreditor recognition, as increasingly seems to be the case, based on flawed and 

incomplete "Scorecard" data and a series of pilot questions. 

As I indicated in my testimony before the Committee, I served for many years as a member of 

NACIQI under administrations of both political parties. I was proud to represent the higher education 

community on this advisory committee. However, I believe that in recent years it has become politicized 

and has in some important ways deviated from its purpose. NACIQI should be engaged in making 

recommendations to the Secretary of Education concerning the ability of accrediting agencies to meet the 

stated criteria for recognition. It is appropriate for NACIQI to hold accrediting agencies accountable for 

meeting the criteria. NACIQ! should not be engaged in attempts to set new policy that is more appropriate 

to the legislative process. It is not appropriate for NACIQI to rely on flawed data or to otherwise make 

recognition recommendations based on the personal beliefs or preferences of members or on anything other 

than the stated criteria. 

I am not suggesting that we should give up on the use of measures/metrics, for example, pass rates 

on state licensure exams are a both relevant and effective measure of institutional quality but if we are going 

to make meaningful use of data, we should bring together members of the higher education community to 

make decisions about what data should be collected and how it should be used. Further, while there may 

be a temptation to leave this in the hands of the data "experts," I think that more is required. It is simply 

too easy for researchers to collect data because it is possible to do so without considering whether that data 

should be collected or used. There needs to be higher education representatives involved in data decisions 

who can consider what should be done in order to address student empowerment as well as accountability. 

The following questions were posed by Representative Francis Rooney: Forty years ago, US. 

colleges employed more faculty than administrators. Buttaday, teachers make up less than half of college 

employees. In this time period the number of foil-time professors increased slightly more than 50 percent. 

while the number of administrators and administrative staffers increased 85 percent (Forbes). Are the 

rules and regulations set forth by Congress forcing postsecondary institutions to hire high amounts of 
125 

[Whereupon, at 12:21 p.m., the committee was adjourned.] 

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4 

administrators instead of hiring more full-time professors and allowing for career predatory programs? 

What is the important day-to-day functions that force postsecondary institutions to hire all these 

administrators? 

There are increased accountability measures as well as reporting that adds to the regulatory burden 

faced by all colleges and universities. Perhaps the most siguificant increases have been related to research 

programs, but these requirements apply unevenly across institutions. On the other hand, increased data 

collection (!PEDS) is required of all, and increased reporting has been required from most institutions in 

topic areas as varied as campus security/crime and international students. To carry out these functions, 

staff have been added to research and student life offices, and institutional research functions and offices 

have grown proportionately. 

Perhaps more importantly, forty years ago in 1977, the environment of U.S. higher education was 

much different than it is today. Compared to 1977, today there are new instructional delivery systems 

including online learning, new educational provider partners, new information technology, new online 

learning resources, and new or enhanced student support systems from advising to career services. All of 

these developments have resulted in colleges and universities becoming much more complex institutions. 

That increasing complexity has demanded the addition of administrative personnel. 

I do hope that the Committee and its members will find these brief comments useful. Please contact 

me again should you require additional information or clarification. 

~ George A. Prmtt 

President 

GAP/mam