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THE DEPARTMENT OF EDUCATION 

INSPECTOR GENERAL’S REVIEW OF STANDARDS 

FOR PROGRAM LENGTH IN HIGHER EDUCATION 

HEARING 

BEFORE THE

COMMITTEE ON 

EDUCATION AND LABOR 

U.S. HOUSE OF REPRESENTATIVES

ONE HUNDRED ELEVENTH CONGRESS 

SECOND SESSION 

HEARING HELD IN WASHINGTON, DC, JUNE 17, 2010 

Serial No. 111–67 

Printed for the use of the Committee on Education and Labor 

( 

Available on the Internet: 

http://www.gpoaccess.gov/congress/house/education/index.html 
(II) 

COMMITTEE ON EDUCATION AND LABOR 

GEORGE MILLER, California, Chairman 

Dale E. Kildee, Michigan, Vice Chairman 

Donald M. Payne, New Jersey 

Robert E. Andrews, New Jersey 

Robert C. ‘‘Bobby’’ Scott, Virginia 

Lynn C. Woolsey, California 

Rube ́n Hinojosa, Texas 

Carolyn McCarthy, New York 

John F. Tierney, Massachusetts 

Dennis J. Kucinich, Ohio 

David Wu, Oregon 

Rush D. Holt, New Jersey 

Susan A. Davis, California 

Rau ́l M. Grijalva, Arizona 

Timothy H. Bishop, New York 

Joe Sestak, Pennsylvania 

David Loebsack, Iowa 

Mazie Hirono, Hawaii 

Jason Altmire, Pennsylvania 

Phil Hare, Illinois 

Yvette D. Clarke, New York 

Joe Courtney, Connecticut 

Carol Shea-Porter, New Hampshire 

Marcia L. Fudge, Ohio 

Jared Polis, Colorado 

Paul Tonko, New York 

Pedro R. Pierluisi, Puerto Rico 

Gregorio Kilili Camacho Sablan, 

Northern Mariana Islands 

Dina Titus, Nevada 

Judy Chu, California 

John Kline, Minnesota, 

Senior Republican Member 

Thomas E. Petri, Wisconsin 

Howard P. ‘‘Buck’’ McKeon, California 

Peter Hoekstra, Michigan 

Michael N. Castle, Delaware 

Vernon J. Ehlers, Michigan 

Judy Biggert, Illinois 

Todd Russell Platts, Pennsylvania 

Joe Wilson, South Carolina 

Cathy McMorris Rodgers, Washington 

Tom Price, Georgia 

Rob Bishop, Utah 

Brett Guthrie, Kentucky 

Bill Cassidy, Louisiana 

Tom McClintock, California 

Duncan Hunter, California 

David P. Roe, Tennessee 

Glenn Thompson, Pennsylvania 

[Vacant] 

Mark Zuckerman, Staff Director 

Barrett Karr, Minority Staff Director 
(III) 

C O N T E N T S 

Page 

Hearing held on June 17, 2010 ............................................................................... 1 

Statement of Members: 

Guthrie, Hon. Brett, a Representative in Congress from the State of 

Kentucky ........................................................................................................ 4 

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

Miller, Hon. George, Chairman, Committee on Education and Labor ......... 1 

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

Statement of Witnesses: 

Manning, Sylvia, president, the Higher Learning Commission of the 

North Central Association ............................................................................ 12 

Prepared statement of ............................................................................... 14 

McComis, Dr. Michale S., executive director, Accrediting Commission of 

Career Schools and Colleges ........................................................................ 18 

Prepared statement of ............................................................................... 20 

Tighe, Kathleen S., Inspector General, U.S. Department of Education ...... 7 

Prepared statement of ............................................................................... 8 

(1) 

THE DEPARTMENT OF EDUCATION 

INSPECTOR GENERAL’S REVIEW OF 

STANDARDS FOR PROGRAM LENGTH 

IN HIGHER EDUCATION 

Thursday, June 17, 2010 

U.S. House of Representatives 

Committee on Education and Labor 

Washington, DC 

The committee met, pursuant to call, at 10:07 a.m., in room 

2175, Rayburn House Office Building, Hon. George Miller [chairman of the committee] presiding. 

Present: Representatives Miller, Kildee, Andrews, Woolsey, Hinojosa, McCarthy, Tierney, Kucinich, Holt, Bishop of New York, 

Hirono, Altmire, Hare, Shea-Porter, Fudge, Polis, Titus, Petri, 

Guthrie, and Roe. 

Staff present: Jeff Appel, Senior Education Policy Advisor/Investigator; Jody Calemine, General Counsel; Denise Forte, Director of 

Education Policy; Jose Garza, Deputy General Counsel; David 

Hartzler, Systems Administrator; Ryan Holden, Senior Investigator; Sadie Marshall, Chief Clerk; Ricardo Martinez, Policy Advisor, Subcommittee on Higher Education, Lifelong Learning and 

Competitiveness; Bryce McKibbon, Staff Assistant, Education; Alex 

Nock, Deputy Staff Director; Lillian Pace, Policy Advisor, Subcommittee on Early Childhood, Elementary and Secondary Education; Julie Peller, Senior Education Policy Advisor; Alexandria 

Ruiz, Administrative Assistant to Director of Education Policy; Melissa Salmanowitz, Press Secretary; Ajita Talwalker, Education Policy Advisor; Mark Zuckerman, Staff Director; Stephanie Arras, Minority Legislative Assistant; Kirk Boyle, Minority General Counsel; 

Amy Raaf Jones, Minority Higher Education Counsel and Senior 

Advisor; Alexa Marrero, Minority Communications Director; Brian 

Newell, Minority Press Secretary; Susan Ross, Minority Director of 

Education and Human Services Policy; and Linda Stevens, Minority Chief Clerk/Assistant to the General Counsel. 

Chairman MILLER [presiding]. The committee will come to order. 

My apologies to the members and the witnesses; just some last 

minute details that we had to take care of in preparation. So then 

a quorum being present, the committee will come to order, I am reminded by my staff. So a quorum is present, we are in order. Here 

we go. 
2 

The Education and Labor Committee meets this morning to examine reports from the Department of Education inspector general 

looking at higher education accrediting agencies. The inspector 

general’s review focused on institution policies on credit hours and 

program length. 

As the cost of higher education and, subsequently, the federal investment in student aid rise and more students go into debt to finance their education it is critical that we ask what students and 

taxpayers, as federal investors, are paying for. This has been a priority of this committee for many years, certainly intensely, I think, 

over the last 6 or 8 years as we have seen dramatic increases in 

the cost of education, dramatic increases in the rise of indebtedness 

of students who participate in higher education. 

And Mr. McKeon, on the Republican side of the aisle, has been 

a hawk on this issue. Mr. Kline has taken up that call also, Mr. 

Tierney and Mr. Hinojosa. 

With the last reauthorization of the Higher Education Act we 

tried to deal with issues like maintenance of effort to make sure 

that we weren’t putting federal money in at the top and people 

were taking it out the bottom, although I think the states are probably still doing that in a number of instances. 

It is not bound by whether an institution is for-profit or nonprofit, private or public; those haven’t been the issues. It has been 

a concern across the board and it has been echoed across the country as commentators and others have worried about the increased 

cost and the indebtedness of our students. 

The I.G.’s report found that some accrediting agencies do not 

have any established definitions of a credit hour, which could result 

in inflated credit hours and misappropriation of student aid. These 

are my conclusions, so I don’t ask you to—but I think the accrediting agency is sort of about the way it should be, and we discover 

these problems and we fix them, and we go back and forth on that. 

I hope to be able to use this report and the responses back and 

forth because I think they are representative of the concerns and 

I think they are representative of what has been the historical defense of the system that has worked, in many instances, reasonably 

well, it appears. 

But I must say that I am constantly inundated now from members of Congress on both houses, on both sides of the aisle, with 

the substantial increase in student aid that has been appropriated 

and authorized over the last several years—about how this aid is 

being used. I just want to impress upon people that this is a concern that goes across the Congress at this point. 

And again, I think there is the tendency that people say, ‘‘Well, 

you don’t like for-profits,’’ or, ‘‘You like the old, traditional way; you 

don’t understand the future; you don’t understand inputs versus 

outcomes, seat time versus this.’’ I think this committee does. 

But I think at the end of the day what we know is that the system has to resolve itself in how we allocate federal taxpayer dollars. And when students and families are borrowing money, the 

system has to resolve itself in favor of accountability and integrity, 

and that is our concern, and that is why this is really an oversight 

hearing. 
3 

This isn’t about a ‘‘gotcha.’’ This isn’t about who is right and who 

is wrong. I think that this particular episode—when I read the report essentially by chance, it said to me, ‘‘Here is a chance to look 

at this system and pull it apart a little bit to make sure that we 

have some understanding of how this is done.’’ 

You know, we have worked to try to bring down the cost of education for families by increasing the Pell Grant; we have lowered 

the interest rates on student loans; we made it easier for students 

and families to manage their debt with the income based repayment system; we have allowed, under certain circumstances, people 

to discharge their debt after 10 years, or after 25 years, so that 

they can make career choices. But at the end of the day we are still 

adding additional taxpayer dollars to the system to provide that opportunity. 

We see a system where certainly at the community college level 

1.5 million people showed up last year who hadn’t been in the system before because the economy dictated that they go and try to 

acquire additional skills and talents and update their skill sets. We 

see explosive growth in the for-profit system that is meeting the demands and the requirements of many, many students as they try 

to manage their obligations to work and their ability to acquire additional skills and knowledge. 

Much of this is new—relatively new, so to speak—and yet we 

continue to have an accreditation system that appears to be sort 

of the same as it was before, saying that we acknowledge the newness and we are accommodating that. That is just my impression; 

it is not a conclusion or to say that that is how it is so. 

And so I hope that we will be able to pull some of this apart, or 

I hope that we will be able to continue this inquiry, because I think 

we have to provide answers to taxpayers, to families, to students, 

and to the institutions of what are the rules. ‘‘How do you do this?’’ 

So this will continue. 

Because of the kind of unusual nature of this—of laying out this 

issue—I have asked and the minority has agreed that I would have 

15 minutes in my opening questions and that the minority would 

have 15 minutes, and then we will open it up for questions by the 

members. 

And with that, I would like to recognize Congressman Guthrie, 

the senior Republican this morning. 

[The statement of Mr. Miller follows:] 

Prepared Statement of Hon. George Miller, Chairman, 

Committee on Education and Labor 

Good morning. 

The Education and Labor Committee meets this morning to examine reports from 

the Department of Education Inspector General looking at higher education accrediting agencies. 

The Inspector General’s reviews focus on institutions’ policies on credit hours and 

program length. 

As the cost of higher education and, subsequently, the Federal investment in student aid rise, and more students go into debt to finance their educations, it is critical that we ask what students and the taxpayers—as Federal investors- are paying 

for. 

The IG’s report found that some accrediting agencies do not have any established 

definitions of a credit hour, which could result in inflated credit hours and misappropriated student aid. 
4 

This is alarming and could result in serious implications both for students and 

the future of this country. 

Now more than ever, the strength of our economy rests on our ability to produce 

a highly educated workforce. 

A study this week by the Center on Education and the Workforce at Georgetown 

University projected that in 2018, there will be more than three million jobs that 

require at least an associate’s degree and not enough people available who are 

qualified to fill them. 

The system we have today provides aid to students based on the number of credit 

hours they take at an accredited institution. Each institution sets those credit 

hours, and we rely on independent accreditors to see to it that institutions do so 

properly. 

However, the recent IG reports highlight a lack of clear standards and policies 

on this issue, as well as a questionable decision by one agency to accredit an institution which peer reviewers observed had ‘‘egregious’’ credit hour policies. 

I am particularly concerned about institutions inflating credit hours in order to 

garner more student aid than is justified. 

This is increased revenue to the institution, but raises the cost of higher education 

for their students, and for the taxpayer. 

Students could be paying more money than they should be without getting the 

product they had hoped for—a coursework or degree that is worth something in the 

workforce. 

This Committee and this Congress have worked diligently and in a bipartisan way 

to help ensure students have access to the resources they need to obtain a college 

degree. 

We’ve helped bring down the cost of college for families by increasing the Pell 

Grant. We’ve lowered the interest rates on need based student loans and made it 

easier for the students and the families to manage their debt. 

We’ve created income based repayment programs that ensures a borrower will 

only have to pay back fifteen percent of their discretionary income and after 25 

years, the debt will be completely forgiven. 

This is why we have a responsibility to ensure the students who are eligible to 

receive federal student aid are receiving it and that the institutions which serve 

these students are upholding the integrity of the programs. 

Accrediting agencies, in their role of overseeing educational quality, are important 

gatekeepers to student financial aid. 

Just like our federal student aid programs, they have to work in the best interest 

of students. 

The significant investments in Federal student aid this Committee has made in 

recent years makes it all the more critical and timely that we be assured accrediting 

agencies are providing the checks and balances needed to keep institutions of higher 

education accountable. 

I want to thank our witnesses for being here today. I look forward to hearing your 

testimony. 

Mr. GUTHRIE. Thank you, Mr. Chairman, and good morning. 

The topic of today’s hearing, broadly speaking, is accreditation. 

It is a system of peer review and program approval that has a long 

history in American higher education. 

Accreditation is widely viewed as a seal of approval, a sign of 

program quality. In our higher education system accrediting agencies are entrusted with a great deal of authority, determining 

which institutions are eligible to participate in the multibillion-dollar federal aid student programs. 

It is not Congress or the Department of Education that sets the 

standards or visits the colleges to measure and verify their program quality. Instead, independent accrediting agencies bear this 

vital responsibility. 

This is not a fluke. Our nation has always tried to maintain an 

appropriate balance between accountability to its students and taxpayers, and the independence of our higher education systems. 

One of the benefits of this framework is that it allows greater 

flexibility for maintaining program quality while fostering constant 
5 

innovation. For instance, if accreditation were defined by Congress 

and measured in terms of, for example, the number of books in the 

library, an institution that gives its students access to electronic 

course materials could be unfairly excluded from financial aid programs. 

Understanding the basic purpose and process of accreditation is 

necessary as we delve into the specific topic of our hearing. Today 

we will look at a report from the U.S. Department of Education’s 

inspector general regarding one specific accrediting agency and the 

process it used to grant accreditation to a particular institution of 

higher education. This is one of a series of reviews done by the I.G. 

examining how accrediting bodies are operating within the parameters of the law. 

I will leave it to the inspector general to spell out the details of 

her report. Let me simply say I appreciate the work that has been 

done to ensure the intent of Congress that accrediting bodies use 

the necessary tools to ensure the program quality is being met. 

As we examine the I.G.’s findings and the broader issues of how 

accrediting bodies measure program quality, let me close by urging 

a note of caution. American students and taxpayers must have confidence in our accrediting system. On that we all agree. 

We need transparency and accountability to ensure these independent bodies are fulfilling their mission. However, we must be 

careful not to stray from the fundamental principle that government does not—and indeed, it cannot—dictate what constitutes a 

quality institution of higher education. 

This is a point worth emphasizing, particularly in light of the notice of proposed rulemaking released by the U.S. Department of 

Education just last week. Efforts to create a federal definition for 

a credit hour or to establish strict federal parameters for program 

length have the potential to place us on a slippery slope—one that 

will limit creativity and innovation in the delivery of postsecondary 

education. 

Americans take unique pride in our colleges and universities— 

their independence, their quality, and their potential for innovation. These virtues are rooted in our unique system of peer-reviewed accountability. 

I welcome the efforts to shine light on the accrediting system and 

continue efforts to ensure accreditors are using the right tools and 

measurements to hold institutions to high standards. I believe we 

can maintain accountability without relinquishing the flexibility 

and independence of academia. 

Thank you, and I yield back. 

[The statement of Mr. Guthrie follows:] 

Prepared Statement of Hon. Brett Guthrie, a Representative in Congress 

From the State of Kentucky 

Thank you Mr. Chairman, and good morning. The topic of today’s hearing, broadly 

speaking, is accreditation. It is a system of peer review and program approval that 

has a long history in American higher education. 

Accreditation is widely viewed as a seal of approval—a sign of program quality. 

In our higher education system, accrediting agencies are entrusted with a great deal 

of authority, determining which institutions are eligible to participate in the multibillion dollar federal student aid programs. 
6 

It is not Congress or the U.S. Department of Education that sets the standards 

or visits the colleges to measure and verify their program quality. Instead, independent accrediting agencies bear this vital responsibility. 

This is not a fluke. Our nation has always tried to maintain an appropriate balance between accountability to students and taxpayers and the independence of our 

higher education system. 

One of the benefits of this framework is that it allows greater flexibility for maintaining program quality while fostering constant innovation. For instance, if accreditation were defined by Congress and measured in terms of—for example—the number of books in a library, an institution that gives its students access to electronic 

course materials could be unfairly excluded from the financial aid programs. 

Understanding the basic purpose and process of accreditation is necessary as we 

delve into the specific topic of our hearing. Today, we’ll look at a report from the 

U.S. Department of Education’s Inspector General regarding one specific accrediting 

agency and the process it used to grant accreditation to a particular institution of 

higher education. This is one of a series of reviews done by the IG examining how 

accrediting bodies are operating within the parameters of the law. 

I will leave it to the Inspector General to spell out the details of her report. Let 

me simply say I appreciate the work that has been done to ensure the intent of Congress—that accrediting bodies use the necessary tools to ensure program quality— 

is being met. 

As we examine the IG’s findings and the broader issues of how accrediting bodies 

measure program quality, let me close by urging a note of caution. 

American students and taxpayers must have confidence in our accreditation system—on that, we all agree. We need transparency and accountability to ensure 

these independent bodies are fulfilling their mission. However, we must be careful 

not to stray from the fundamental principle that government does not, indeed it 

cannot, dictate what constitutes a quality institution of higher education. 

This is a point worth emphasizing, particularly in light of the Notice of Proposed 

Rulemaking released by the U.S. Department of Education just this week. Efforts 

to create a federal definition for a ‘‘credit hour’’ or to establish strict federal parameters for program length have the potential to place us on a slippery slope—one that 

will limit creativity and innovation in the delivery of postsecondary education. 

Americans take pride in our colleges and universities—their independence, their 

quality, and their potential for innovation. These virtues are rooted in our unique 

system of peer-reviewed accountability. 

I welcome efforts to shine a light on the accreditation system, and continued efforts to ensure accreditors are using the right tools and measurements to hold institutions to high standards. I believe we can maintain accountability without relinquishing the flexibility and independence of academia. Thank you, and I yield back. 

Chairman MILLER. Thank you, gentleman, for your statement. 

And I would like now to welcome our panel to the committee. 

Thank you for giving us your time and your expertise. 

We will begin with Ms. Kathleen Tighe, who serves as inspector 

general for the Department of Education, conducting independent, 

objective audits, investigations, and inspections to weed out fraud, 

waste, and abuse within the department. During her distinguished 

career in public service Ms. Tighe has served as deputy inspector 

general of the U.S. Department of Agriculture, counsel to the inspector general of the General Services Administration, and as assistant counsel to the Office of Inspector General. 

Dr. Sylvia Manning is the president of the Higher Learning Commission of the North Central Association, a position she has held 

since 2008. As president she is responsible for overseeing the accreditation of degree-granting postsecondary educational institutions in the north central region of the United States. Previously 

Ms. Manning served as chancellor of the University of Illinois at 

Chicago, elevating the university to its current position as one of 

the top 50 universities in the country for federal research funding. 

Dr. Michale McComis currently serves as the executive director 

of the Accrediting Commission of Career Schools and Colleges, 
7 

overseeing the accreditation process for over 100—excuse me—for 

over 810 applicant institutions throughout the United States. Specializing in measuring and evaluation of student achievement outcomes, Dr. McComis has authored several publications and conducted several research projects for the commission in addition to 

participating in the International Accreditation Activities in Saudi 

Arabia, Malaysia, Brazil, Canada, and the Caribbean. Before joining ACCSC Mr. McComis worked in trade work by serving as an 

electrician’s apprentice and HVAC technician throughout his service to the United States Marine Corps. 

Welcome to all of you. Our lighting system you may be familiar 

with, but when you begin a green light will go on in those small 

boxes in front of you; that will give you 5 minutes. And at 4 minutes an orange light will go on and then you can start summing 

up your testimony. Your statement will be placed in the record in 

its entirety so you proceed in the manner in which you are most 

comfortable. 

And I will begin with you. 

STATEMENT OF KATHLEEN TIGHE, INSPECTOR GENERAL, 

U.S. DEPARTMENT OF EDUCATION 

Ms. TIGHE. Chairman Miller, Representative Guthrie, and members of the committee, thank you for inviting me here today to discuss the Office of Inspector General’s reviews of accrediting agencies’ standards for program length in higher education. This is my 

first opportunity to testify before Congress since my March confirmation as inspector general and I look forward to working with 

this committee to help ensure that federal education programs and 

operations meet the needs of America’s students and families. 

As requested, I will discuss OIG work involving standards for 

program length and the definition of a credit hour—critically important issues in the federal student loan program as the amount 

of federal aid a student can receive is based on the number of credit hours that a student is enrolled in. 

This issue has become even more significant as online education 

has exploded in recent years, making credit hour assignment difficult, its comparison to traditional classroom delivery difficult and 

a challenge, and its value increasingly important to ensure that 

students and taxpayers get what they are paying for. 

The OIG has conducted extensive work involving accrediting 

agencies for over 2 decades because the role of these—these agencies play is vital. Accreditation is one of the primary requirements 

for an institution’s participation in the federal student aid programs and determines whether academic programs merit taxpayer 

support. 

The department is dependent on accrediting agencies to ensure 

that institutions provide quality content and academic rigor at the 

postsecondary level as it is prohibited from determining the quality 

of education funded by federal education dollars. All the department can do with regard to evaluating the quality of postsecondary 

education is recognize accrediting agencies as reliable authorities 

for the quality of education funded by federal dollars. Thus, the 

recognition of accrediting agencies by the secretary of education is 

the primary tool available to the department for ensuring that stu-
8 

dents receive value for the taxpayer investment of postsecondary 

education. 

We conducted our most recent work on accrediting agencies last 

year in order to provide the department and Congress with information regarding the definition of a credit hour for recent negotiated rulemaking sessions. We examined three of the seven regional accrediting agencies to determine what guidance regarding 

program length and credit hours they provided to those institutions—to institutions and peer reviewers. The three accrediting 

agencies we reviewed represent one-third of the institutions participating in federal student aid programs—over 2,200 postsecondary 

institutions receiving more than $60 billion in federal student aid 

funding. 

We found varying levels of guidance related to the issues we 

looked at. For example, the Southern Association of Colleges and 

Schools provides guidance regarding program length and the required number of credit hours; however, the other two agencies did 

not set minimum requirements related to program length. 

Most significantly, we found that none of the agencies established a definition of a credit hour. Their failure to do so could result in inflated credit hours, the improper designation of full-time 

student status, the over-awarding of federal student aid funds, and 

excessive borrowing by students, especially with distance, accelerated, and other programs not delivered through the traditional 

classroom format. 

At two of the accrediting agencies we were told that student 

learning outcomes were more important than the assignment of 

credit hours. However, these two accrediting agencies provided no 

guidance to institutions or peer reviewers on acceptable minimum 

student learning outcomes at the postsecondary level. 

Currently the student aid programs are primarily dependent on 

the credit hour for making funding decisions, as are other forms of 

aid including state student aid programs and certain programs administered through the Department of Veterans Affairs. To help 

address this issue the department just released a proposed rule 

that contains the definition of a credit hour. Once a final rule is 

adopted by the department we will be closely watching its implementation and evaluating whether the definition of a credit hour 

is effective in protecting students. 

This concludes my statement, and I am happy to answer any 

questions. 

[The statement of Ms. Tighe follows:] 

Prepared Statement of Kathleen S. Tighe, Inspector General, 

U.S. Department of Education 

CHAIRMAN MILLER, RANKING MEMBER KLINE, AND MEMBERS OF THE COMMITTEE: 

Thank you for inviting me here today to discuss the U.S. Department of Education 

(Department) Office of Inspector General’s (OIG) reviews of accrediting agencies’ 

standards for program length in higher education. This is my first opportunity to 

testify before Congress since my March confirmation as the Inspector General. It is 

an honor to lead this organization with its long history of accomplishment and to 

have the opportunity to work with this Committee, which has led the way in improving Federal education programs and operations so they meet the needs of America’s students and families. 

As requested, I will provide information on our work involving standards for program length and the definition of a credit hour—critically important issues in the 
9 

Federal student aid programs, as the amount of Federal student aid a student can 

receive is based on the number of credit hours for which a student is enrolled. 

This issue has become even more significant as on-line education has exploded in 

recent years, making credit hour assignment difficult, its comparison to traditional 

classroom delivery a challenge, and its value increasingly important in order to ensure that students and taxpayers get what they are paying for. 

Background on the OIG and Accrediting Agencies 

For 30 years, the OIG has worked to promote the efficiency, effectiveness, and integrity of Federal education programs and operations. We conduct independent audits, inspections, investigations, and other reviews, and based on our findings, make 

recommendations to the Department to address systemic weaknesses and recommend to both the Department and Congress needed changes in Federal laws. 

As members of this Committee know, the Federal student aid programs have long 

been a major focus of our audit, inspection, and investigative work, as they have 

been considered the most susceptible to fraud and abuse. The programs are large, 

complex, and inherently risky due to their design, reliance on numerous entities, 

and the nature of the student population. OIG has produced volumes of significant 

work involving the Federal student aid programs, leading to statutory changes to 

the Higher Education Act of 1965, as amended (HEA), as well as regulatory and Departmental operational changes. This includes extensive work involving accrediting 

agencies. Accrediting agencies are private educational associations that develop 

evaluation criteria and conduct peer reviews of institutions of higher education to 

ensure that the instruction provided by those institutions meets acceptable levels 

of quality. The role they play is vital, as accreditation is one of the primary requirements for an institution’s participation in the Federal student aid programs and determines whether academic programs merit taxpayer support. 

Under the HEA, the Department is dependent on the accrediting agencies recognized by the Secretary of Education (Secretary) to ensure that institutions provide 

quality, content, and academic rigor at the postsecondary level. The Higher Education Opportunity Act of 2008 included a provision that prohibits the Department 

from developing minimum regulatory criteria for an accrediting agency’s standards 

for accreditation. The Department of Education Organization Act of 1980 prohibits 

the Department from making determinations on curriculum and educational quality. 

Thus, the Department is prohibited from determining the quality of education funded by Federal education dollars. All it can do with regard to evaluating the quality 

of postsecondary education is recognize accrediting agencies as reliable authorities 

for the quality of education funded by Federal dollars. In 1992, Congress established 

the National Advisory Committee on Institutional Quality and Integrity—an independent body charged with doing what the Department cannot: evaluating the adequacy of accrediting agencies’ standards for accreditation and making recommendations to the Secretary as to those agencies that should be recognized. That input 

is vital, as the recognition of accrediting agencies by the Secretary is the primary 

tool available to the Department for ensuring that students receive value for the 

taxpayer investment in postsecondary education. 

OIG Work Involving Accrediting Agencies 

In the late 1980s and early 1990s, OIG identified significant problems with some 

accrediting agencies’ oversight of program length at some institutions. Our work 

contributed to significantly strengthening the requirements accrediting agencies 

needed to meet for recognition by the Secretary in the Higher Education Act 

Amendments of 1992. The Amendments also mandated that an academic year, for 

undergraduate programs, must be a minimum of 30 weeks of instructional time in 

which a full-time student is expected to complete at least 24 credit hours. The Department faced difficulty in applying this requirement to programs measuring student progress in credit hours but not using a semester, trimester, or quarter system, 

including non-traditional educational delivery methods. Therefore, the Department 

established the regulatory 12-Hour Rule. The 12-Hour Rule served as a surrogate 

for the Carnegie formula, which provided the standard unit of measuring credit in 

higher education, whereby one credit hour generally consisted of one hour of classroom work and two hours of outside preparation over the course of the academic 

year. ‘‘One hour of classroom work’’ is defined as 50 to 60 minutes. Under this method, a full-time student in an education program using a semester, trimester, or 

quarter system would have a workload of 36 hours per week through the academic 

year (12 hours of classroom work and 24 hours of outside preparation per week). 

At the time, there was an assumption that the traditional semester, trimester, and 

quarter system provided a minimum level of instruction and that these programs 

closely followed the Carnegie formula. 
10 

The 12-Hour Rule provided a tool for the Department to help ensure that students 

received a given quantity of instruction. The Department relied on accrediting agencies to ensure that the quantity and quality of instruction was at the postsecondary 

level. The assumption was that a full-time student attempting 12 credit hours in 

a semester would have 12 hours of scheduled instruction per week. In 2000, we performed an audit where we found that an institution’s programs offered much less 

classroom education than programs provided by traditional term-based institutions 

and that the institution was in violation of the 12-Hour Rule. A series of audits over 

the next two years identified other institutions that were in violation of the 12-Hour 

Rule. 

In 2002, the Department eliminated the 12-Hour Rule in favor of the One-Day 

Rule. Under this regulation, an institution is required to provide one day of regularly scheduled instruction during each week in an academic year. However, neither 

the HEA nor the implementing regulations define what constitutes instruction or 

the minimum amount of instruction that needs to be provided during the required 

one day of instruction. At the time of the change, much like today, there were many 

different delivery methods for instruction: the traditional residential term-based 

programs; residential programs not offered on a semester, trimester, or quarter system; correspondence courses; telecommunications programs; and independent study. 

There was no specificity in what could be included as instruction for determining 

an institution’s academic year and credit hours for the awarding of Federal student 

aid funds. 

We informed the Department about our concern with the elimination of the 12- 

Hour Rule, as well as the need to address the definition of instruction, the appropriate amount of Federal student aid to be awarded in non-traditional programs, 

and accrediting agency oversight of non-traditional programs. As a result of this 

concern, in 2002-2003, we took another look at this issue and examined two regional 

accrediting agencies and two national accrediting agencies, evaluating their standards for program length and student achievement. The scope of recognition for regional accrediting agencies is limited to specific states for each accrediting agency, 

while the scope of national accrediting agencies is not limited to specific states. We 

found: 

Program Length 

• Neither regional agency had a definition of a credit hour that it required its institutions to follow. The standards these regional agencies applied to program 

length were vague and without definition, effectively allowing institutions to establish their own standards; and • The two national agencies both had a definition of a credit hour in terms of the 

required hours of instruction needed to equate to a credit hour. 

Student Achievement 

• The regional agencies had not established minimum graduation, placement, and 

licensure rates for any of their institutions providing vocational education programs. 

For all education programs, these regional agencies permitted institutions to establish their own standards for student achievement, without any specified minimum 

standard; and • The national agencies had established minimum graduation, placement, and 

state licensure rates for the institutions they accredited. However, at both agencies 

we identified problems in the methodology by which the rates were calculated that 

caused the rates to be overstated. 

As a result of these findings and in anticipation of the scheduled 2004 reauthorization of the HEA, we made a recommendation that Congress establish a statutory 

definition of a credit hour stating: ‘‘For programs that are not offered in clock-hours, 

credit hours are the basis for determining the amount of aid students are eligible 

for. Absent a definition of a credit hour, there are no measures in the [Higher Education Act] or regulations to ensure comparable funding across different types of 

educational programs.’’ The recommendation was not included in the reauthorization. 

Recent OIG Reviews 

As a follow-up to this work and in anticipation of the 2009-2010 higher education 

negotiated rulemaking sessions in which the definition of a credit hour was to be 

discussed, OIG once again examined the issue in order to provide the Department 

with facts on program length and the definition of a credit hour in negotiated rulemaking and to provide information to Congress on the state of the definition of a 

credit hour at regional accrediting agencies. As regional accreditation has long been 

considered the ‘‘gold standard’’ in accreditation and information on what the regional accrediting agencies were doing with regard to credit hours could greatly in-
11 

form the regulatory process, we determined that we would do reviews at the three 

largest of the seven regional accrediting agencies. The three accrediting agencies 

were: the Southern Association of Colleges and Schools Commission on Colleges 

(SACS); the Middle States Association of Colleges and Schools (Middle States); and 

the Higher Learning Commission of the North Central Association of Colleges and 

Schools (HLC). These three accrediting agencies represent one-third of the institutions participating in Federal student aid programs: 2,222 postsecondary institutions with more than $60 billion in Federal student aid funding. 

Our objectives were to determine: (1) what guidance the accrediting agencies provide to institutions regarding program length and credit hours; (2) what guidance 

the accrediting agencies provide to peer reviewers to assess program length and 

credit hours when evaluating institutions; and (3) what documentation the accrediting agencies maintain to demonstrate how they evaluate institutions’ program 

length and credit hours. We found that none of the accrediting agencies defined a 

credit hour and none of the accrediting agencies provided guidance on the minimum 

requirements for the assignment of credit hours. At two of the accrediting agencies 

(HLC and Middle States), we were told that student learning outcomes were more 

important than the assignment of credit hours; however, these two accrediting agencies provided no guidance to institutions or peer reviewers on acceptable minimum 

student learning outcomes at the postsecondary level. The following is a summary 

of our results at each accrediting agency: 

Southern Association of Colleges and Schools Commission on Colleges 

• SACS provides guidance to institutions regarding program length and the required number of credit hours; however, it does not provide guidance on the minimum requirements for the assignment of credit hours or the definition of a credit 

hour; • SACS provides guidance to reviewers regarding the assessment of program 

length, but does not provide reviewers guidance regarding the assessment of credit 

hours; and • SACS maintains documentation to demonstrate that it evaluates institutions’ 

program length and credit hours. 

Middle States Association of Colleges and Schools 

• Middle States does not have minimum requirements specific to program length 

and does not have minimum requirements for the assignment of credit hours; and • Middle States senior staff stated that their main focus was on student learning 

outcomes; however, we did not find that Middle States provided any guidance to institutions and peer reviewers on minimum outcome measures to ensure that courses 

and programs are sufficient in content and rigor. 

Higher Learning Commission of the North Central Association of Colleges and 

Schools 

• HLC’s standards for accreditation do not establish the definition of a credit hour 

or set minimum requirements for program length and the assignment of credit 

hours; • HLC does not provide specific guidance to peer reviewers on how to evaluate 

the appropriateness of an institution’s processes for determining program length 

and assigning credit hours or on the minimum level of acceptability for accreditation 

when evaluating these processes; • HLC maintains self-studies and team reports as documentation of its evaluation 

of institutions’ program lengths and credit hours, but the amount of information related to program length and credit hours that institutions and peer reviewers included in these respective documents varied; and • HLC determines whether institutions assess student learning outcomes; however, it does not define a minimum threshold for when the measures of achievement 

for student learning outcomes indicate poor educational or programmatic quality. 

While conducting our inspection at HLC, we identified a serious issue that we 

brought to the Department’s attention through an Alert Memorandum, HLC evaluated American InterContinental University (AIU)—a for-profit institution owned by 

Career Education Corporation (CEC)—for initial accreditation and identified issues 

related to the school’s assignment of credit hours to certain undergraduate and 

graduate programs. HLC found the school to have an ‘‘egregious’’ credit policy that 

was not in the best interest of students, but nonetheless accredited AIU. HLC’s accreditation of AIU calls into question whether it is a reliable authority regarding 

the quality of education or training provided by the institution. Since HLC determined that the practices at AIU meet its standards for quality, without limitation, 

we believe that the Department should be concerned about the quality of education 

or training at other institutions accredited by HLC. Based on this finding, our Alert 
12 

Memorandum recommended that the Department determine whether HLC is in 

compliance with the regulatory requirements for accrediting agencies and, if not, 

take appropriate action under the regulations to limit, suspend, or terminate HLC’s 

recognition by the Secretary. The Department initiated a review of HLC and determined that the issue identified was not an isolated incident. As a result, the Department gave HLC two options for coming into compliance: (1) to accept a set of corrective actions determined by the Department; or (2) the Department would initiate a 

limitation, suspension, or termination action. In May 2010, HLC accepted the Department’s corrective action plan. 

Current Status 

With the explosion of on-line postsecondary education and accelerated programs, 

the value of a credit hour becomes increasingly important to ensure that students 

and taxpayers get what they are paying for. Currently, the Federal student aid programs are primarily dependent on the credit hour for making funding decisions, as 

are other forms of aid, including state student aid programs and certain programs 

administered through the U.S. Department of Veterans Affairs. To help address 

this, the Department will soon be issuing a definition of a credit hour through a 

notice of proposed rulemaking that we understand will be issued on June 18. Once 

a final rule is adopted by the Department, we will be closely watching its implementation and evaluating whether the definition of a credit hour is effective in protecting students and taxpayers. 

Closing Remarks 

We view the recognition of accrediting agencies by the Secretary as the primary 

tool available to the Department for ensuring that students receive value for the 

taxpayer investment in postsecondary education. As the Department is prohibited 

from developing minimum regulatory criteria for an accrediting agency’s standards 

for accreditation or making determinations on curriculum and educational quality, 

it is not unreasonable for the Department to expect an accrediting agency to have 

developed its own minimum standards. 

On behalf of the OIG, I want to thank you for the support Congress has given 

to this office over the years. We look forward to working with the 111th Congress 

in furthering our mutual goal of protecting students and serving the taxpayers. 

This concludes my written statement. I am happy to answer any of your questions. 

Chairman MILLER. Thank you. 

Ma’am? 

STATEMENT OF SYLVIA MANNING, PH.D., PRESIDENT, THE 

HIGHER LEARNING COMMISSION OF THE NORTH CENTRAL 

ASSOCIATION 

Ms. MANNING. There we go. Okay, thank you very much. 

And good morning, Chairman Miller, Representative Guthrie. 

Thank you very much for giving me this opportunity to speak with 

you today on matters of great mutual concern. 

You spoke about accountability and integrity; they are very high 

on our list. And we are also very much concerned about the issues 

of student debt and taxpayer costs. 

I do want to make one brief point with regard to the case that 

was the center point of the inspector general’s review of our work 

last summer and then move on to the body of my testimony. The 

point I want to make is simply to remind people that this was not 

a dispute about the value of the courses for which we determined 

that there was too much credit being ascribed. We found that fault 

and we found that based on our own standards. 

The disagreement with the Inspector General’s Office was a disagreement about having made that finding, what should we do 

next? We took an approach that they did not agree with. Subsequent events and further examination of the institution have indi-
13 

cated that our approached worked. And of course, I would be willing to answer more questions about this institution in the question 

period. 

I want to make two simple points about how we conduct accreditation. Accreditation, for us, is an action that does indeed rely more 

upon judgment than upon statements of minimum thresholds. And 

secondly, I want to say—and I want to assert—that this is a rigorous process and that it is rigorous not in spite of the fact that 

it relies upon informed judgment but, frankly, because of that fact. 

Why do we use a process that relies so much upon judgment and 

so much less upon minimum thresholds? Because we are charged 

with assuring and advancing quality and we want real quality, we 

don’t want minimum quality; because the areas in which our evaluators are judging are messy and complex; and because we want 

to be in a posture of continuously requiring that our institutions 

improve. 

We don’t believe quality stands still. An institution that isn’t assessing itself and constantly engaging in improvement is losing 

quality, and that is what we are fighting against. 

How do we achieve the rigor? We achieve the rigor by using experienced professionals, people how have been in the field for 

many, many years. We use a wide range of them. 

But we don’t simply rely on that expertise. We require our evaluators to be trained, and in fact, we do refresher training when policy changes. And the training they receive and the work they do 

is within a framework of stated criteria. This varies from accrediting agency to accrediting agency. 

In our case we have five criteria and 21 core components, and 

our institutions are required to demonstrate that they meet every 

one of these core components, and our evaluators are required to 

make a finding that they meet them. But the finding must be 

based, as is the demonstration, on evidence. 

This is an evidence-based process. The findings are rendered in 

evidentiary statements, and that is a primary consideration. 

Let me turn for a minute more to the question of program length 

and definition. The definition, so to speak, of a credit hour is actually deeply understood in the higher education community. 

The fact that our standards don’t happen to cite precisely the socalled Carnegie Hour does not mean that our evaluators are not capable of assessing whether a course is worth the amount of credit 

that is being given to the course. And in fact, in the particular case 

that came up in the course of our review our assessors exactly 

looked at the courses and without benefit of a written definition 

and a written standard determined that in their view the courses 

carried too much credit. 

But what has happened over the many decades in which the 

credit hour concept is used is that it has come to be understood by 

the working professionals in the area not as a function of a clock 

but as a body or a quantity of knowledge and skill that is imparted. 

And that is why accreditors have come to look so much at student 

outcomes, because the fact of the matter is that the credit hour 

may be good for lots of things but it won’t tell you what a student 

learns—it won’t even tell you whether a student learned anything 
14 

in the 3 hours a week the student sat in the classroom or whether 

the student even did the homework. 

What we are looking for is assessment of outcomes as a very important factor in accreditation because we want to be sure that the 

students learned things and that the institutions assessed that and 

paid attention to it. 

If the regulations as proposed are promulgated can we work with 

them? Yes, we can work with them. There may be some challenges 

for the institutions. There will be costs to demonstrate compliance, 

and there may be some deterrence to innovation. We can work with 

it. 

But I can assure you of this much: I don’t believe that a definition of a credit hour will solve our challenges with regard to consistency, and I don’t believe that that will lead us to the kind of 

high quality and ever increasing quality this nation needs in higher 

education. 

Thank you. I will be happy to answer questions. 

[The statement of Ms. Manning follows:] 

Prepared Statement of Sylvia Manning, President, the Higher Learning 

Commission of the North Central Association 

I thank Chairman Miller, Ranking Member Kline, and members of the Committee 

for this invitation to testify on standards for program length in higher education. 

I have served as President of the Higher Learning Commission of the North Central Association since July 1, 2008. Prior to that I served as Chancellor of the University of Illinois at Chicago; I have worked in higher education my entire adult life. 

The Higher Learning Commission is the regional accreditor for 19 states defined 

as North Central. Specialized and professional accrediting agencies accredit specific 

programs, such as law, engineering, or nursing. Regional accreditors accredit entire 

degree-granting institutions of higher education; they are membership organizations 

composed of the accredited colleges and universities, committed to uphold shared 

standards and improve practices and outcomes. The Higher Learning Commission 

has just over 1,000 members representing the full spectrum of American higher education: public, private and for-profit; community colleges, four-year schools, professional schools, comprehensive universities, research universities, faith-based colleges, tribal colleges; colleges with a few hundred students and universities with 

tens of thousands of students. 

This diversity of colleges and the spirit of freedom and enterprise that enabled 

its development are widely believed to constitute one of the pillars that have made 

U.S. higher education still the strongest in the world, despite continuing concerns 

about American global competitiveness. In fact, those continuing concerns are part 

of an unceasing drive to innovation that sustains quality. 

It is my understanding that this hearing was prompted by the recently reported 

review by the U.S. Department of Education Inspector General of standards for 

credit hours and program length at three of the regional accrediting agencies. The 

report on the Higher Learning Commission was the last to be released and the most 

critical of the three, culminating in a recommendation that the Department undertake a review of the Commission’s qualification as a recognized accreditor. The report and in particular that recommendation focused intensively on the case of a single institution and the Commission’s decision to grant it accreditation. 

In preparing this testimony I have proceeded on the understanding that the Committee’s interest is not in a single institution or a single decision, but in the general 

issue of credit hours and program length and the broader issue of quality. I will 

refer briefly to the specific case at the end of my testimony and am entirely willing 

to discuss it further in oral questioning. 

My testimony is in three parts: (1) The nature of accreditation and how it addresses quality; (2) The strengths and limitations of the credit hour as a measure to determine academic attainment; and (3) The relationship of the credit hour and program length to the assurance of quality. 

Accreditation and Quality 

Higher education institutions are regulated by state and local governments and, 

to the extent that they accept federal monies, the federal government. These regula-
15 

tions touch upon accounting standards, probity in the use of public funds, fire and 

building codes, discrimination in employment, athletics opportunities for students, 

research with human or animal subjects, eligibility for Title IV federal aid to students, and a variety of other matters. 

Regional accreditation assesses the quality of a college or university to ensure 

that its academic offerings are appropriate and rigorous, that its practices have integrity, and that its business operations are robust. It looks at the entirety of the 

institution, necessarily taking a broad view. The issues it engages are complex and 

messy and often don’t lend themselves to strict rules, to questions with yes-or-no 

answers and scores at the end. 

Accreditation is an act of judgment based upon articulated standards or criteria 

that expressly allow for, even require, judgment. Because of that, it preserves the 

ability to adapt to varying circumstances, contexts and environments, to deal with 

diversity, to tolerate—even to encourage—innovation, and to apply constant pressure for improvement. Accreditation, in other words, seeks to support the innovative 

and adaptive spirit that has created the richness and range of American higher education, the range that in turn enabled the United States to democratize higher education long before other political democracies attempted to do so. 

Accreditation pursues a dual purpose of quality assurance and quality improvement and must accomplish both rigorously. There are standards of quality that 

must be met, and there is the need for continuous quality improvement. Improvement is critical because quality is not immutable and it does not stand still: an organization is either improving its quality or losing it. 

In regulations under Title IV of the Higher Education Act, minimum thresholds 

are often key and must be clear, although even in Title IV regulation there is a 

place for judgment by the staff of the U.S. Department of Education where appropriate. Accreditation typically shies away from defining minimum thresholds, and 

the Higher Learning Commission in particular has tended to less specific language, 

with phrases such as ‘‘commonly accepted.’’ But there is no basis for any assumption 

that the absence of precise or quantified minimum thresholds indicates or creates 

a lack of rigor. 

The Higher Learning Commission, for example, has five Criteria under which it 

arrays 21 Core Components. The Core Components are findings that institutions 

must demonstrate and review teams must make, such as ‘‘The organization’s learning resources support student learning and effective teaching.’’ To support this finding, multiple forms of evidence will be required and the evidence will be concrete, 

but that is different from a ‘‘minimum threshold’’ that might say something like 

‘‘The organization must provide at least 1 public computer station for every 20 students enrolled.’’ In addition to the Criteria and Core Components, the Commission 

has 12 specified requirements for eligibility and supplements its Criteria with Statements such as ‘‘Principles of Good Practice in Adult Degree Completion Programs.’’ 

The importance of evidence is paramount. The Commission’s guidance documents 

provide about a half-dozen ‘‘Examples of Evidence’’ for each of the 21 Core Components and reviewers are required to ground every judgment in substantial evidence. 

The Commission relies upon expert or professional judgment to determine when 

standards are simply not met and to apply continuous pressure, even upon the best, 

to improve. Because it has not depended upon extensive definitions of minimum 

thresholds, there is no such thing as a ‘‘perfect score’’ in an accreditation review. 

In its commitment to quality improvement, the Commission eschews a pure regime 

of minimum thresholds under which an institution seeking only to earn its stamp 

of approval—its ticket, as it were, to Title IV funds—would be able to meet those 

minima and no more. 

Key to accreditation is the use of peer evaluation by professionals who are qualified and trained to bring judgment to bear on questions of quality. The American 

judicial system requires juries of peers to assure a communal role in the execution 

of the law. Accreditation seeks juries of peers for the purpose of expertise, the expertise that is necessary where mission and outcomes are complex, rules cannot be 

framed with mathematical precision, and judgment is essential. 

Countering the risk of excessive subjectivity in judgment, the Commission complements its extensive documented discussions with required training for its peer 

reviewers and multiple levels of review for critical decisions. Even a relatively small 

change for an institution, such as a venture into establishing an off-campus location, 

is reviewed for approval by more than one person. And, as noted above, judgments 

need to be based on evidence. 

Voluntary accreditation has been in place in the United States for over a hundred 

years and has handled issues related to the evaluation of quality for most of that 

time. Accreditation works well because it ensures that institutions not only meet appropriate standards but are continually working to exceed those standards, all the 
16 

while recognizing that institutions across the broad spectrum of American higher 

education are not all the same: they have considerable differences in how they approach the task of educating students. This diversity of institutions that provides 

opportunities for students across the United Status to participate in higher education is a key strength of this country. I believe that voluntary accreditation is an 

important factor in keeping this system strong. 

At the same time the Higher Learning Commission believes that its processes, 

like those of the institutions it accredits, can always benefit from review and improvement. In fact, we have agreed, in follow-up to the Inspector General’s report, 

to address further guidance for our review teams on the application of our standards. But the principles remain: Minimum thresholds may be useful, but they do 

not guarantee rigor and their absence does not create an absence of rigor. Alone 

they cannot produce high quality, especially the quality needed in a rapidly changing, competitive environment. 

Credit Hours and Program Length 

The concept of the credit hour was originally developed for K-12 education. It was 

adopted by higher education as a way to create a unit smaller than the course, to 

define differences among types of courses. Later it came to be used in a variety of 

other ways, such as to define the workload of a faculty member or assess tuition 

charges. It is now deeply embedded in so many facets of higher education practice 

that efforts to dislodge it would be highly disruptive. Only very recently in the last 

century did federal monies become attached to it for the distribution of financial assistance to students. 

The credit hour is based upon what is often referred to (usually pejoratively) as 

seat-time, because it starts from the amount of time a student spends in a classroom. One semester credit hour consists of 15 hours in a classroom plus an assumed 

two hours of homework for every hour in the classroom, so that it represents a total 

of 45 hours. A three-credit course at a college on a semester calendar therefore normally meets three hours a week for 15 weeks and assumes that students are doing 

6 hours a week of homework. (Except that an ‘‘hour’’ in the classroom is usually 50 

minutes, an understanding developed to accommodate the need for students to have 

10 minutes to get from one class to another on a college campus.) In theory the definition still makes sense. In practice it has always been mushy. 

Anyone who has ever taught or taken a class knows the concept of credit hours 

is mushy. No one can be sure how much time students spend on homework, but we 

do know that in any given class there will be huge variation. What’s more, the seattime and homework time, that is the credit hour, has nothing to tell us about what 

a student learned. But we do know that some students get A’s and some students 

get D’s and that the students who got A’s learned more than the students who got 

D’s—or at any rate knew more by the end of the course—even though they all met 

the same credit-hour requirement. Furthermore, we know but don’t like to say that 

a student who earned an A in a course of a given description with a given number 

of credits using the standard credit-hour definition might take the same course with 

the same description and the same number of credits using the same standard credit-hour definition at another college and earn a C—because there are differences in 

what is taught under the description and in the performance expected of students. 

So the credit hour by itself is not very good for telling us what a student learned. 

It may be very good for other things, but not for that. And that is why Undersecretary for Higher Education Martha Kanter has chided accreditors for using input 

measures like seat-time to assess quality. And that is why for the past 20 years 

higher education has been developing ways to measure student learning outcomes. 

That is still a developing art, because it is very difficult to do once you get beyond 

factual knowledge and basic skills. But that is why some accrediting agencies, like 

the Higher Learning Commission, have put less emphasis on credit hours as minimum standards and more emphasis on assuring that colleges figure out what their 

students actually learn and use those assessments to improve their curriculum and 

teaching. 

Program length is almost uniformly defined in American higher education by a 

number of credit hours, usually referred to simply as credits or units. It is a practical description, and just as the concept of credit hours serves in a mushy way to 

define a quantity of learning, or at least a quantity of teaching, program length in 

terms of credit hours defines a degree level. For example, bachelor’s degrees are 

generally 120 or 124 credits, though in some fields, especially technical and certain 

practice fields, they creep up to as much as 136; associate’s degrees are generally 

60 credits. 

Credit hours and program lengths as developed in this way have come under 

question not only for their mushiness but also out of the need to adapt to a world 
17 

in which a declining percentage of students are traditional students who go away 

to college or commute to college on a full-time basis. Alternative modes of delivery, 

most notably internet-based distance delivery that permits a student to participate 

in classroom activities at any time from anywhere, make nonsense of the idea of 

seat-time. Furthermore, research in adult learning and the effectiveness of compressed course formats suggests that equivalence should not be measured by time. 

Does this mean that higher education should do away with the concept of credit 

hours? No; but we need to be thoughtful in how we apply it. Over the decades during which the concept of the credit hour has been used, it has come to be understood 

not as a multiple of hours but as a unit for describing a quantity of information 

or skill provided in a specific course. Professors of English share widespread understanding of what a three-unit survey course in American literature comprises, and 

professors of Chemistry know what they should cover in a three-unit course in introductory Chemistry. Those two things are enormously different, and there is no 

equating the three credits. They began as two of five courses that a typical freshman or sophomore would be expected to carry in one semester in a traditional, fulltime college, and that body of effort, for each of those courses, has come to be well 

understood by the professionals who prepare and teach the courses. 

That is how those professionals were then able to transfer the concept of credits 

to compressed or asynchronous formats where hours can’t be counted. What they 

transferred was not the hours, but the body of work, the body of information and 

skill. It is symptomatic that the phrase ‘‘credit hour’’ isn’t used much: people speak 

of credits, or units, or sometimes hours, though in that case they would likely be 

surprised to be taken literally, as though ‘‘hours’’ had something to do with a clock. 

That is why they accept the notion of giving degree credit for work experience or 

military training. 

If program length is measured in credits and credits are mushy, then program 

length is necessarily a mushy standard too. But it has come to be workable, just 

as the concept of credit hours has. That is why we do not support the notion of creating three-year bachelor’s degrees. We support the notion of students’ completing 

what has been understood as a four-year program in three years, through advanced 

placement, year-round course-taking and suchlike, but we believe that it is useful 

that a bachelor’s degree is generally understood to be four years of work and an associate’s two, and that calling a three-year program by either of those names would 

just create confusion. We can have a three-year degree, but let’s call it something 

else. 

Credit Hours and Assurance of Quality 

The Inspector General’s review of the Higher Learning Commission and two other 

regional accrediting agencies took place in the context of an upcoming session of negotiated rule-making called by the Department of Education, for which one of the 

issues on the table was the matter of definition of credit hours and program length. 

The argument put forward as to why a definition was necessary was that the Department of Education needs to assure that federal funds are going towards quality 

education. That goal is incontrovertible. Ideally, such assurance would be based not 

on the input of credit hours, but on the outcome of learning. But in reality, federal 

funds need to be disbursed to students at the beginning of a term, not at the end 

when it would be at least theoretically possible to measure what they had learned. 

So the Department needs an input measure. 

Will defining that input measure, the credit hour, with more specificity contribute 

to the assurance or improvement of quality in American higher education? I do not 

think so. The apparent precision of the credit hour as originally defined, based on 

the fact that it has numbers, is an illusion: underneath the numbers lies the mush. 

Will the Department’s requirement of that input measure harm American higher 

education? I do not think that either. But resources will be spent in demonstrating 

compliance with the regulation, resources spent by colleges and universities, not 

accreditors, and diverted from helping students. And it is possible that the risk of 

citation by an accreditor will deter some institutions from innovation in developing 

programs for adults and other student populations. 

What strikes us as curious is that the call for minimum thresholds in matters 

such as the credit hour and program length runs counter to the country’s expressed 

interest in increasing, significantly and rapidly, our nation’s attainment in higher 

education. To meet our national goals for educational attainment and a workforce 

for the 21st-century economy, higher education is asked—by policy makers, legislators, foundations, opinion leaders—to break out of old molds, seek efficiencies, open 

doors, reach new populations. Strict accreditation requirements based in 19th-century models don’t seem likely to get us there. 
18 

Can rigor in quality assurance be achieved without defining a credit hour, or requiring institutions to define it or accreditors to approve the definition? Yes. This 

point may be best demonstrated by referring to the specific case at the center of 

the Inspector General’s report on the Higher Learning Commission. The core of that 

issue was the fact that a visiting review team to a campus had identified some 

courses which the team determined were being awarded about double the amount 

of credit they were worth. Because the Commission nonetheless granted accreditation to the institution, the Inspector General asserted that the Commission either 

does not have standards or is unwilling to enforce its standards. 

But here is the record: (1) the Higher Learning Commission, not the Office of the 

Inspector General, identified the issue of credits during its review of the institution; 

(2) consistent with the recommendation of two teams of experienced peer reviewers 

and based on their academic judgment, we determined that the issue—given the 

general strength of the institution under our standards—did not warrant denial of 

accreditation and that a requirement to remedy the problem would be the most effective approach; and (3) further review and a site visit to the institution have since 

provided evidence that the approach worked. Our standards and procedures identified the problem and corrected it, benefitting students and the public in a way that 

denial of accreditation could not (especially since the institution was already accredited by another agency and its students were already receiving Title IV monies). 

The visiting team of expert reviewers identified the problem, without benefit of 

a precise definition of the credit hour from either the institution or the Commission. 

The members of that team, based on years of professional experience, applied professional judgment, pronounced the credit ascription out of line and recommended 

that the Commission require this fault to be cured (which the Commission did). 

When the team declared the credit values to be out of line, it did not do so based 

on how many hours the students spent working on the course, in a classroom or 

elsewhere. It did so based on the syllabus, on the curriculum, on what and how the 

students were being taught. 

Conclusions 

We offer the following conclusions: 

• It is appropriate for the Department of Education to assure that recognized accrediting agencies pay great attention to quality and rigor, including the award of 

appropriate academic credit. 

• Accreditation can and does achieve rigor because it relies on peer judgment 

based on clear evidence and demands improvement well beyond minimum standards. 

• The absence of a definition of the credit hour or other minimum thresholds has 

not impeded the Higher Learning Commission’s discernment of quality or making 

rigorous accreditation decisions. 

• A definition of the credit hour, if accompanied by sufficient leeway to adapt to 

contemporary modes of delivery and adult learning, is something higher education 

can work with, but it will not assure or improve the quality of higher education in 

America. 

• There is room for improvement in accrediting agencies’ assessment and assurance of quality. The Higher Learning Commission is committed to improving its 

practices and to demonstrating that commitment in action, just as it expects its institutions to be. 

Thank you again for the opportunity to testify before the Committee. I look forward to responding to any comments or questions you may have. 

Chairman MILLER. Thank you. 

Mr. McComis? 

STATEMENT OF MICHALE S. MCCOMIS, ED.D, EXECUTIVE DIRECTOR, ACCREDITING COMMISSION OF CAREER SCHOOLS 

AND COLLEGES 

Mr. MCCOMIS. Good morning, Chairman Miller, Representative 

Guthrie, Committee. Thank you for the opportunity to testify. 

My name is Michale McComis and I am the executive director of 

the Accrediting Commission of Career Schools and Colleges, or 

ACCSC. We currently accredit 789 career-oriented institutions with 

over 250,000 students throughout the country. 
19 

Today the number of nontraditional, working, adult students 

seeking higher education is steadily on the rise. While a traditional 

liberal arts education continues to be an important goal for many 

students, many other nontraditional students are enrolling in career-oriented programs, often part-time or online. 

Given the growing demographic of career-focused adult learners, 

the higher education community must continue to adapt and innovate in order to accommodate the diversity in its student body. Accordingly, there is not, nor should there be, a one-size-fits-all 

means by which to define or analyze program length or the credits 

provided by the institution. 

Having said that, evaluating the continued value provided by an 

institution program remains extremely important. As independent 

entities that establish standards and assess institutions on a peer 

review basis, accrediting agencies are the best resource for making 

determinations related to educational design, delivery, and quality. 

The Higher Education Act is written in a manner that relies on 

and respects an accrediting agency’s independence and the need for 

flexibility to shape standards and processes in a manner that accounts for the types of schools and programs that it accredits. It 

is important that the act’s accompanying regulations continue to 

also provide this flexibility in order to meet the increasing demand 

for innovation and diversity in higher education. 

As I pointed out during the recent negotiated rulemaking, flexibility and regulation regarding the issue of credit hour is important 

because regulatory definitions, particularly narrow ones, have the 

tendency to become entrenched rules that stifle innovation. 

The current flexibility in the act has enabled my agency to write 

standards and create processes that make the best sense for the 

types of institutions that the agency accredits. 

The current NPRM’s definition of a credit hour would relegate 

our rather rigorous requirements to an ‘‘other’’ category in the regulations, potentially exacerbating the difficulty that students attending our schools already have in the area of transfer of credit. 

ACCSC’s standards are focused on institutional operations and 

how those operations contribute to student achievement outcomes. 

Because our goal is to assess an entire institution we do not apply 

standards one in isolation from another. 

Our agency has more than 20 standards that address program 

length and objectives directly. Our primary standards in this area 

require institutions to demonstrate that the length of each program 

enables students to achieve the necessary skills, knowledge, and 

competencies. 

If the school’s program is not comparable to others our standards 

require an institution to justify that variant length. As a standard 

measure, ACCSC uses a straight clock hour to credit hour conversion which does not take into account outside preparation. Additional standards on program length require the use of independent 

program advisory committees, specific credit hour lengths for degree programs, and specific considerations for distance education. 

Our standards are only as good as the process by which we measure our institutions against them. To prepare for the accreditation 

process institutions are required to prepare a self-evaluation report, or SER. 
20 

ACCSC’s staff and on-site evaluators review the institutions SER 

and evaluate program length against our standards, such as the 

clock hour to credit hour conversion formula. If there is an issue 

presented on program length or on other outcomes measures, such 

as graduation or employment rates for example, we might require 

the institution to prepare a program viability study, which requires 

a showing that the program is appropriately designed to meet the 

needs of the employment market. If an institution is not able to 

make this showing ACCSC has several institutional and programmatic actions available to remediate or correct poor performance or to deny or revoke accreditation. 

ACCSC believes there is a direct link between the evaluation of 

program and length and student learning and achievement outcomes at an institution. We therefore tightly align our student 

achievement standards to the program objective standards. We 

view our graduation and employment rates benchmarks as tools to 

identify issues such as an appropriate program length and to then 

develop institutional improvement mechanisms as a means to enhance institutional and student success. 

In conclusion, ACCSC believes that its standards represent exemplary practices in the areas of program length, program objectives, and student achievement measures for the kinds of institutions it accredits. We do not intend to suggest that our standards 

could or should be applied to every institution of higher education. 

Our standards work because they have been developed in a peer 

review environment that is committed to institutional and student 

success. 

Accreditors should continue to be relied upon to establish these 

standards in conjunction with their institutions, keeping in mind 

the best interests of students. Thus, federal law and regulation 

should also continue to rely with confidence on professional 

accreditors and refrain from overly-prescriptive requirements that 

may, albeit unintentionally, stifle flexibility and innovation. 

Thank you. I will be happy to answer any questions. 

[The statement of Mr. McComis follows:] 

Prepared Statement of Dr. Michale S. McComis, Executive Director, 

Accrediting Commission of Career Schools and Colleges 

Thank you for the opportunity to testify. My name is Michale McComis and I am 

the Executive Director of the Accrediting Commission of Career Schools and Colleges (ACCSC). I am honored to appear before the Committee this morning to discuss the important issue of program length in higher education. I hope to provide 

the Committee information about ACCSC’s standards and accreditation process in 

this area, but also to provide you our perspective on the role of accreditation in 

higher education more generally. 

ACCSC is a private, non-profit independent accrediting agency recognized by the 

Secretary of Education continually since 1967. It is a national agency in scope that 

currently accredits 789 institutions with over 250,000 students throughout the country. These institutions are predominantly private sector, career-oriented institutions, 

offering programs at the non-degree, Associates Degree, Bachelors Degree, and Masters Degree levels. They prepare students for trade and technical careers in many 

areas including allied health, nursing, information technology, automotive technology, commercial art, and unique areas such as horology, luthiery, and yacht 

building and restoration. 

ACCSC’s primary mission is to serve as a reliable authority on educational quality 

and to promote enhanced opportunities for students. To meet its mission, the Commission has a values-based framework for accrediting focused on integrity, accountability, continuous improvement, open communication and teamwork. My tenure 
21 

with ACCSC began in 1994, becoming its Executive Director in 2008. I have recently 

served on two of the Department of Education’s negotiated rulemaking panels—the 

2009 Accreditation Panel and the 2010 Program Integrity Panel—to help establish 

regulations pursuant to the legislative provisions of the Higher Education Act 

(HEA). 

Summary of Testimony 

My testimony is divided into two primary parts. First, I will spend a few minutes 

placing the issue of program length in the broader context of our higher education 

system and regulatory structure. It is important to provide a bit of background regarding the need for continued reliance on the regulatory ‘‘triad’’ that provides the 

student funding and quality-assurance mechanisms for our institutions of higher 

education. I will speak briefly on how the flexibility of this regulatory structure has 

helped to support and encourage innovation and diversity in our institutions and 

their programs and teaching methods. In the context of program length specifically, 

I will discuss the relationship between the importance of determining the appropriate length of a program, the value of credits provided, and the assessment of student achievement. 

The second and most important part of my testimony will provide the Committee 

with a summary of ACCSC’s standards on program length and its process for reviewing institutions generally, and with regard to program length in particular. 

ACCSC takes pride in the manner by which it has adapted its standards and process to account for the types of institutions and programs that it accredits. I also 

would like to discuss with the Committee how our standards on program length and 

credit hour directly relate to our assessments of student achievement at our institutions. 

The Broader Context of Higher Education Policy, Accreditation and the Evaluation 

of Program Length 

It is important to take a minute to put the narrow issue of accreditation standards on program length into the broader context of today’s higher education system. 

Today, the number of ‘‘non-traditional’’ students seeking higher education is steadily 

on the rise, the majority of whom are working adults. While a traditional liberal 

arts education at an on-ground institution continues to be an important goal for 

many students graduating from high school, many other non-traditional students 

are enrolling in career-oriented programs. Moreover, students are increasingly enrolling on a part-time basis or online to accommodate their work schedules or other 

family commitments. 

Given the growing demographic of career-focused, adult learners, the higher education community must continue to adapt and innovate in order to accommodate the 

diversity represented in its student body. The higher education community itself is 

also diverse and is defined by a broad selection of institutions and programs that 

range from short-term, non-degree programs to four-year liberal arts programs, to 

graduate level programs in hundreds of different academic areas, taught at institutions both on-ground and on-line. With this rich variety, there is not, and should 

not be, a one-size, fits all means by which to define or analyze program length or 

the credits provided by an institution; however, evaluating the continued value provided by an institution’s programs remains extremely important. 

As higher education takes a more diverse shape, ensuring the quality and integrity of these institutions and their programs continues to be a paramount concern 

and historically the primary responsibility of accrediting agencies and the schools 

they accredit. Unlike federal and state governments, accrediting agencies are private, independent entities, focused on establishing standards and assessing their 

member institutions in relation to those standards on a peer-review basis and as 

such are the best resource for making determinations related to educational quality. 

Despite the independent, private nature of accreditation, accrediting agencies 

have been linked to the federal government since the Congress established the 

Higher Education Act 45 years ago. In this regard, accreditation has played an essential role in institutional and programmatic quality assurance and has served as 

an essential component of the regulatory ‘‘triad’’ in partnership with federal and 

state governments for the regulatory oversight of higher education institutions. Institutions eligible for Title IV funds must be accredited by an accrediting agency recognized by the U.S. Secretary of Education and the Higher Education Act created 

a structure for this recognition process. Included in the Act and regulations are criteria which all accrediting agencies must include in their accreditation standards. 

One of these criteria requires standards that assess an institution’s measures of program length and the objectives of the degrees or credentials offered. 
22 

The Act is written in a manner that respects an accrediting agency’s independence and the need for flexibility to shape standards and processes in a manner that 

accounts for the types of schools and programs that it accredits. Concordantly, it is 

important that the Act’s accompanying regulations continue to also provide this 

flexibility. With regard to the issue of program length in particular, the above overview of the diversity of the higher education community demonstrates the importance of avoiding prescriptive federal regulations that might prevent institutions 

from meeting the increasing demand for innovation and diversity in the academic 

programs offered. Moreover, as I pointed out during the Program Integrity Negotiated Rulemaking session, the need for flexibility in regulatory language regarding 

the definition of a credit hour is important because regulatory definitions, particularly narrow definitions, have the tendency to become entrenched rules such that 

creative yet equally effective approaches or even more rigorous approaches are not 

considered or are seen as suspect. As I demonstrate in the next section of my testimony, the current flexibility in the Higher Education Act has enabled my agency, 

ACCSC, to write standards and create processes that measure program length and 

credit hours, and that seek to define program objectives in a manner that makes 

the best sense for the types of programs and institutions that the agency accredits. 

The current NPRM regarding the definition of a credit hour would relegate our 

rather rigorous requirements to an ‘‘other’’ category in the regulations potentially 

exacerbating the difficulty that students attending our schools already have in the 

area of transfer of credit. 

ACCSC’s Standards and Processes to Evaluate Program Length and Credit Hour 

The ACCSC Standards of Accreditation and accreditation process emphasize educational quality by focusing on outcomes. What actually happens as a consequence 

of the teaching-learning processes in a school and what is the evidence of these results? Given the stated purposes of the school and its documented outcomes, can the 

school be judged as meeting standards of quality compared with similar institutions? Does the accreditation process help the school to evaluate and improve its 

student achievement outcomes and hence its quality? Such questions are the primary focus of ACCSC as the Commission conducts its work. 

Our Standards 

In addition to having standards and processes to examine institutional inputs, 

ACCSC has outcomes-based standards, including graduation and employment rates, 

which the agency uses in its assessment process. In short, the Commission is concerned about institutional operations and how those contribute to student achievement outcomes related to the attainment and application in the workplace of skills, 

knowledge, and competencies. 

Our standards on program length are necessarily linked to our standards on student achievement; none of our standards is utilized in isolation. ACCSC strives for 

a ‘‘whole school’’ assessment process whereby the appropriateness of an institution’s 

operational and education inputs can be evaluated in the context of student achievement outcomes. Each component of the school (e.g., admissions requirement and recruiting, program design and curriculum, student services, the quality of the administration and faculty, the inclusion of the employment community in curriculum development and assessment, etc.) has a role to play and an impact on the overall success of an institution and the success of students. In the area of program length 

and objectives, ACCSC has more than 20 standards that address these areas directly (see Appendices I and II) and several more that do so tangentially. 

Our primary standards in this area require our institutions to demonstrate that 

the length of each of their programs enable students to achieve their learning objectives. In the event a school has programs that vary from comparable programs, our 

standards require an institution to justify that variant length. As a standard measure for program length, ACCSC uses a straight clock hour to credit our conversion 

shown below: 

Semester Credit Hours: 

• One semester credit hour for at least 15 hours of classroom contact; or 

• One semester credit hour for at least 30 hours of supervised laboratory/shop instruction; or 

• One semester credit hour for at least 30 hours of documented independent 

study activities; or 

• One semester credit hour for not fewer than 45 hours of externship/internship 

or work-related experience. 

• Quarter Credit Hours: 

• One quarter credit hour for at least ten hours of classroom contact; or 
23 

• One quarter credit hour for at least 20 hours of supervised laboratory/shop instruction; or 

• One quarter credit hour for at least 20 hours of documented independent study 

activities; or 

• One quarter credit hour for not fewer than 30 hours of externship/internship 

or work-related experience. 

Outside preparation is not considered in the conversion of clock hours to credit 

hours. In addition to ACCSC’s formula for conversion, institutions are required to 

comply with applicable state and federal regulations related to clock-to-credit hour 

conversions. 

In addition to these standards, additional standards on program length require: 

• Institutions to have an independent program advisory committee review and 

comment on program length; 

• Minimum and maximum credit hour length for degree programs; 

• Comparability of distance education to residential programs; and 

• A justification and validation for any deviation from established clock-to-credit 

hour conversions in distance education programs. 

Our Processes 

Our standards are only as good as the process by which we measure our institutions against them. We, therefore, have a multistep process by which we look at an 

institution’s program length. To prepare for the re-accreditation process, institutions 

are required to prepare a Self-Evaluation Report (SER). ACCSC’s SER instructions 

requires institutions to demonstrate how their programs meet our standards, i.e., 

we require an explanation of how the school has determined that the length of each 

program offered is appropriate to enable students to achieve the program objectives. 

Institutions that do not meet our standards, i.e., their program length is not comparable to similar programs, are required to justify their program’s length. 

Even before our evaluators visit an institution for re-accreditation, ACCSC staff 

will review the institution’s SER and evaluate program lengths against our standards, such as the clock to credit hour conversion formula. When our evaluators visit 

an institution, they review the institution’s response to the SER and make assessments regarding a school’s compliance with those standards. Each on-site evaluation 

team is comprised of an education specialist and occupation specialist who work together to make assessments regarding the appropriateness of a program taking into 

account the institution’s assertions, the review by an independent Program Advisory 

Committee, student feedback, and student achievement outcomes. If there is an 

issue presented on program length or on other outcomes measures, such as graduation or employment rates, for example, ACCSC might require the institution to prepare a Program Validation Study, which would require an institution to show that 

the program is appropriately designed (e.g., program length) to meet the needs of 

the employment market. If an institution is not able to make this showing, ACCSC 

has several institutional and programmatic actions available to remediate or correct 

poor performance. 

For institutions seeking initial accreditation, we likewise require them to complete 

a detailed SER, provide a demonstration of compliance with our program length 

standards, and undergo an on-site evaluation. If a school is unable to demonstrate 

programmatic success via student achievement outcomes, the Commission will likely 

defer granting initial accrediting until a showing of compliance is made or if the institution is unable to demonstrate compliance after given an sufficient opportunity 

to do so, the Commission will deny the school’s application. 

Between accreditation cycles, ACCSC has a robust program approval process. 

Every program offered by an institution must be approved by the Commission before 

the program can be offered. The program applications require an institution to justify the implementation of a new program, show that the curriculum and length has 

been reviewed by an external employment community Program Advisory Committee, and show that the program meets ACCSC’s clock hour to credit hour conversions. 

Connection to Student Achievement 

As I have stated, we believe that the evaluation of program length is linked to 

our evaluation of student learning and outcomes at an institutions. We therefore 

tightly align our student achievement standards to the program objective standards, 

including program length, at our institutions. We view our graduation rate and employment rate benchmarks as tools to identify issues, such as inappropriate program 

length or objectives, and to then develop institutional improvement objectives as a 

means to enhance institutional and student success. I include Appendix II for further detail of our student learning and achievement outcomes standards. 
24 

In the area of student learning and achievement outcomes, ACCSC requires that: 

• Student learning outcomes for each program are consistent with the program 

objectives and meet any relevant academic, occupational, or regulatory requirements; • Student learning outcomes for each program are aligned with the program’s objectives, the occupational area of study, and with the level of education intended 

(e.g., non-degree, degree, degree level); • Student learning outcomes for each program reflect the necessary occupational 

and academic knowledge, skills, and competencies as applicable; • The school has a developed and structured process to assess and evaluate the 

defined student learning outcomes; • The school must demonstrate successful student achievement by documenting 

through its assessment practices that students are acquiring the knowledge, skills, 

and competencies intended by the program objectives; and • The school must demonstrate successful student achievement by maintaining 

acceptable rates of student graduation and employment in the career field for which 

the school provided education. 

Conclusion 

ACCSC believes that its standards represent exemplary practices in the areas of 

program length, program objectives, and student achievement measures for the 

kinds of institutions it accredits. ACCSC does not intend to suggest that its standards could or should be applied to every institution of higher education, but instead 

to show that rigorous standards can be and have been developed in the areas being 

addressed by this hearing. ACCSC’s standards work because they have been developed in a peer review environment that is committed to institutional and student 

success. Accreditors can and should continue to be relied upon to establish these 

standards in conjunction with their institutions keeping in mind the best interest 

of students. Thus, federal law and regulation should also continue its historical reliance on professional accreditors to make the appropriate assessments with its institutions and to refrain from overly prescriptive requirements that may, albeit unintentionally, stifle flexibility and innovation. 

APPENDIX I.—ACCSC PROGRAM LENGTH AND OBJECTIVES STANDARDS

The length of each program offered by the school is appropriate to enable students 

to achieve the program objectives and to acquire the knowledge, skills, and competencies necessary for initial employment in the field for which training is provided. Schools that have or apply for programs that appear to be significantly shorter or longer in clock or credit hours than comparable programs (i.e., within the same 

field of study) will be required to justify the appropriateness of the program length 

(Section II (A)(2)(a), Substantive Standards, Standards of Accreditation). 

For every program, there are detailed and organized instructional outlines and 

course syllabi showing a scope and sequence of subject matter sufficient to achieve 

the program objectives and to acquire the necessary knowledge, skills, and competencies. Programs include the appropriate number of lecture hours and, as applicable, the appropriate number of laboratory/shop and/or externship hours necessary 

to achieve the program objectives (Section II (A)(2)(b), Substantive Standards, 

Standards of Accreditation). 

Each school must have an independent Program Advisory Committee for each program area, and the committee reviews and comments at least annually on the established curriculum of the program and comments as to the appropriateness and adequacy of the program objectives, program length, curriculum content, learning resources, and the adequacy of facilities and equipment (Section II (A)(5)(e)(i), Substantive Standards, Standards of Accreditation). 

Degree programs are measured in semester credit hours or the equivalent quarter 

hours (refer to the Profile of Clock Hour to Credit Hour Conversion form), include 

the appropriate number of lecture hours and, as applicable, the appropriate number 

of laboratory and/or externship hours necessary to achieve the program objectives. 

Degree programs must be comprised of courses with content that is appropriate to 

the level and type of degree awarded (Section II (B)(1)(b), Substantive Standards, 

Standards of Accreditation). 

An associate degree program must be a minimum of 60 semester hours or 90 

quarter hours and a minimum of two academic years. Associate degree programs 

may not exceed by more than 50% the minimum number of credit hours required 

to confer the degree by the appropriate regulatory agency in the state(s) in which 

the school operates. If such minimums have not been established, then generally accepted practices in higher education shall apply. (Section II (B)(2)(b), Substantive 

Standards, Standards of Accreditation). 
25 

A baccalaureate degree program must be designed and offered in a way that appropriately balances distinct types of education and training (i.e., technical and occupationally related courses and general education courses) and distinct levels of 

education and training (i.e., lower level and upper level courses), and must include 

a comprehensive curriculum with appropriate coursework to achieve the program 

objectives. (Section II (B)(3)(a), Substantive Standards, Standards of Accreditation). 

A baccalaureate degree program must be a minimum of 120 semester hours or 

180 quarter hours and a minimum of four academic years. Baccalaureate degree 

programs may not exceed by more than 50% the minimum number of credit hours 

required to confer the degree by the appropriate regulatory agency in the state(s) 

in which the school operates. If such minimums have not been established, then 

generally accepted practices in higher education shall apply (Section II (B)(3)(b), 

Substantive Standards, Standards of Accreditation). 

The length of a master’s degree must be appropriate to enable students to achieve 

the required competencies and skills for employment or advancement in the field 

for which training is provided (Section II (B)(4)(b)(i), Substantive Standards, Standards of Accreditation). 

A master’s degree program must be designed and offered in a way that provides 

for a distinct level of education and fosters independent learning and an understanding of research methods appropriate to the academic discipline. Graduate level 

courses must be based on appropriate pre-requisites and learning outcomes and expectations must be clearly stated to students (Section II (B)(4)(b)(ii), Substantive 

Standards, Standards of Accreditation). 

Master’s degree programs must include a minimum of 30 semester hours or 45 

quarter hours. At least 24 semester hours or 36 quarter hours must be in the technical field for which the degree is awarded (Section II (B)(4)(b)(iii), Substantive 

Standards, Standards of Accreditation). 

ESL program length must be between 600 and 900 clock hours or the equivalent 

credit hours (Section II (C)(2)(f), Substantive Standards, Standards of Accreditation). 

The length of the distance education programs and courses of study must meet 

all necessary requirements outlined in Section II (A)(1), Substantive Standards, 

Standards of Accreditation (Section IX (C)(1), Substantive Standards, Standards of 

Accreditation). 

The school must demonstrate that the content and length of a distance education 

program or course of study are comparable to residential programs. The school must 

justify and provide validation for any deviation from established clock-to-credit hour 

conversions, if applicable (Section IX (C)(2), Substantive Standards, Standards of 

Accreditation). 

APPENDIX II.—ACCSC STUDENT LEARNING AND ACHIEVEMENT STANDARDS

Student learning outcomes for each program are consistent with the program objectives defined by the institution’s program design and development process and 

meet any relevant academic, occupational, or regulatory requirements (Section VII 

(A)(1)(a), Substantive Standards, Standards of Accreditation). 

Student learning outcomes for each program are aligned with the program’s objectives, the occupational area of study, and with the level of education intended (e.g., 

non-degree, degree, degree level) (Section VII (A)(1)(b), Substantive Standards, 

Standards of Accreditation). 

Student learning outcomes for each program reflect the necessary occupational 

and academic knowledge, skills, and competencies as applicable (Section VII 

(A)(1)(c), Substantive Standards, Standards of Accreditation). 

The school has a developed and structured process to assess and evaluate the defined student learning outcomes of the education and training and established competencies (e.g., the application of knowledge and skills to the standard of performance articulated in the program objectives and as expected in the workplace). This 

process may include a variety and combination of methods such as grading, portfolio 

assessment, and criterion referenced testing based on developed and appropriate rubrics (Section VII (A)(2)(a), Substantive Standards, Standards of Accreditation). 

The school demonstrates successful student achievement by documenting through 

its assessment practices that students are acquiring the knowledge, skills, and competencies intended by the program objectives (Section VII (B)(1)(a), Substantive 

Standards, Standards of Accreditation). 

The school demonstrates successful student achievement by maintaining acceptable rates of student graduation and employment in the career field for which the 

school provided education. The school supports these rates through student transcripts, the school’s verifiable records of initial employment of its graduates, or other 
26 

verifiable documentation (Section VII (B)(1)(b), Substantive Standards, Standards of 

Accreditation). 

ACCSC Student Achievement Benchmarks 

ESTABLISHED BENCHMARK GRADUATION RATES 

Program Length in Months 

Average Rates of Graduation 

Demonstrates Acceptable 

Student Achievement 

Standard 

Deviation 

Established Benchmark 

Graduation Rates* 

1-3 .......................................................................... 92% 8% 84% 

4-6 .......................................................................... 82% 13% 69% 

7-9 .......................................................................... 69% 14% 55% 

10-12 ...................................................................... 69% 15% 54% 

13-15 ...................................................................... 61% 16% 45% 

16-18 ...................................................................... 59% 17% 42% 

19-24 ...................................................................... 56% 20% 36% 

25-35 ...................................................................... 55% 22% 33% 

36+ ......................................................................... 47% 15% 32% 

*If a school reports a lower graduation rate for a program, that program will be subject to additional monitoring or reporting as deemed 

appropriate. 

ESTABLISHED BENCHMARK EMPLOYMENT RATE 

Average Rate of Employment 

Demonstrates Acceptable 

Student Achievement 

Standard 

Deviation 

Established Benchmark 

Employment Rate* 

All Programs ........................................................... 82% 12% 70% 

*If a school reports a lower employment rate for a program, that program will be subject to additional monitoring or reporting as deemed 

appropriate. 

Chairman MILLER. Thank you very much to all three of you for 

your testimony. 

This is an attempt to set the stage, not so much an attempt to 

inflame the debate. As I understand it, when—Ms. Manning, when 

your—is it Dr. Manning or Ms. Manning? 

Ms. MANNING. It is both. I am quite happy with Mrs., which is 

the hardest one to get. [Laughter.] 

Chairman MILLER. Now I am stumped. [Laughter.] 

Ms. MANNING. I am sorry. 

Chairman MILLER. You stump the chump and you win every 

time. 

Okay. Ms. Manning—where am I?—as I understand it, when 

your accrediting team went out and looked at AIU, which is American Intercontinental University, when they looked through the 

courses I think both at the master’s level and at the undergraduate 

level, if you will, during that process they came away with the conclusion that there was inflation of course credit unit hours being 

awarded to some of those courses. 

There was a setup by which you would take nine units over a 

10-week period, and when they looked, apparently, both at the content and at what would be required for a full-time working student, 

which many at the university or most at the university were, to do 

that it just didn’t add up that you could get all of that in in that 

period of time. Is that a fair summation, not on every detail, 

but—— 

Ms. MANNING. Yes, I think it was. This was a subset of the 

courses—— 
27 

Chairman MILLER. And they made a finding, I think, that caught 

the inspector general’s—which, in fact, said that they felt that this 

was egregious when they compared it to common practices in other 

institutions from which they may have come from or they had experience in the accrediting process. Is that fair? 

Ms. MANNING. That is exactly the word they used. 

Chairman MILLER. Okay. But I mean, is they were comparing it 

to their experience as accreditors and as, in some cases, professors, 

or—I don’t know what the team is made up of—their experience in 

higher education, if you will, both in the for-profit and nonprofit 

world? 

Ms. MANNING. Yes. 

Chairman MILLER. Okay. 

And the inspector general, as I understand, your concern was 

after making this finding the accreditation went forward—you say, 

I believe—without limitations put on it. But your review came after 

this fact pattern took place because you were doing a greater review of various different types of accrediting agencies to get a picture? 

Ms. TIGHE. Yes, that is correct. 

Chairman MILLER. Okay. 

And Ms. Manning, you said during your testimony that this 

problem was raised, you went back, you had a second visit, you had 

meetings, and you think it was addressed. Is that fair to say? 

Ms. MANNING. Correct. 

Chairman MILLER. Okay. So that is sort of the fact pattern. 

So what caught my attention in this is that in this discussion of 

back and forth was the inspector general raising the point that 

Title IV resources are released to students—loans, Pell Grants— 

are released to students based upon whether they are in full-time 

status or part-time status, and that is measured by credit hours. 

And that is based upon an old system which we call the Carnegie 

system, which was based upon sort of seat-time—you had three 

hours for three units, which said that you were an hour a week in 

the class or 2 hours a week in class, and that corresponded to time 

outside the class, whether it is 2 hours or an hour and a half for 

each hour that you were in the classroom. Is that close? 

Ms. MANNING. Yes. 

Chairman MILLER. This is the best I have ever done with a professor. [Laughter.] 

And is that fair, Ms. Tighe? 

Ms. TIGHE. Our concern was that the team made certain estimations of the credit policy at AIU, and as you stated earlier, that 

the Higher Learning Commission did not take really any action 

other than proceed to accreditation, notwithstanding the estimation 

of the team that the certain classes were over-inflated in credit—— 

Chairman MILLER. Do you think they had it kind of backwards— 

they should have not provided accreditation, fix the problem, and 

then decided whether or not to accredit? 

Ms. TIGHE. Or at least while reviewing or before deciding on accreditation, yes, take certain actions to fix those qualms. 

Chairman MILLER. Okay. 

Let me, if I might—and correct me where I am wrong—but my 

understanding is that regarding this nine-unit course over a 10- 
28 

week period of time, both the accreditors and the Inspector General’s Office looked at this and said, ‘‘This is too many units’’—I 

think I am correct saying—‘‘This really corresponds to what a 

three-unit class would be under common circumstances.’’ 

Ms. TIGHE. That is what the team concluded. 

Chairman MILLER. That is what the team concluded. Did you 

conclude differently, or did you have the ability to conclude, Inspector General? 

Ms. TIGHE. We did not make—we did not review the courses ourselves—— 

Chairman MILLER. Okay. You just reviewed what they were finding—— 

Ms. TIGHE [continuing]. Reviewed the team report, yes. 

Chairman MILLER. So, Ms. Manning? 

Ms. MANNING. That was the point I wanted to make. The inflation, also, even in the initial team report, was not that great. They 

were looking at a subset of courses, and these are quarter units, 

and they said instead of nine it probably should have been somewhere around four-and-a-half, but they were never that precise. 

And let me just add one more point, if I may, which is that our 

reports are divided into two sections, and one is assurance or compliance, and the other is improvement. That detail is in the improvement section, and it is in the improvement section in large 

part because it is really not crystal clear whether a course should 

be nine credits, or eight credits, or six-and-a-half credits. What 

they were trying to point to was that there is something wrong 

here and it needs to be looked at and fixed. 

Chairman MILLER. Here is my concern: I know it is not crystal 

clear and I respect the tradition of accreditation. And so you could 

say, reasonable people could differ whether this is worth three 

units, four units, or nine units—apparently not nine units, but if 

you get to six; there was a little bit of discussion of six to three. 

But as a student, when I sign up for a nine-unit course at this 

university at the master’s level, those nine units cost me $5,517. 

Some of that is grants directly from the taxpayer; some of that is 

loans. 

If that course is worth three units it costs me $1,839. All of a 

sudden that unit becomes very important, and I think it becomes 

very important because we are now dealing with education for profit, and that extra unit, repeated 500 times throughout the year for 

500 students taking that class, is worth a lot of money, and repeated 1,000 times, and 10,000 times is worth a lot of money, this 

was sort of the structure, I think, of AIU, you take these nine-unit 

courses and, as we heard on another discussion, if you could get 

this rotation 10 times a year it was worth real money. 

I am not saying that is why it is done, but I am saying all of 

a sudden this discussion between you and the I.G. about minimum—— 

And, Mr. McComis, I set you aside a little bit because you have 

a more specific question about outcomes that you measure your 

schools on. I am not leaving you out of this discussion, but—— 

Mr. MCCOMIS. Thank you. [Laughter.] 

Chairman MILLER. So you start to see the problem for a member 

of Congress is, and this is a very touchy situation. I understand 
29 

that. I am not sure George Miller should be deciding what is the 

value here, but that question somebody has to think about because 

this turns out to be billions of dollars if we are wrong that are 

being expended, and this is a program that we struggle every year 

to meet the appropriations for in this Congress. 

So that $3,600 difference for that course regime—if your 

accreditors were right and it was worth three as opposed to nine— 

that $3,600 is valuable to the student, to the taxpayer. So I don’t 

have the answer on how you deal with this, but I think when you 

understand that for an institution that is in some cases publiclyheld, some cases closely-held, privately-held institutions—this 

question of how you assign credit units now becomes part not so 

much of an academic plan, necessarily, but also of a business plan. 

And I would just raise the question—and I just raise it as a question; I am sure there will be lots of different answers—what is the 

impact of accreditors going up and thinking about unit hours and 

the rest of this—or outcomes, however you want to measure it—in 

light of aggressive business plans, which is somewhat different? 

Now, you can argue that the traditional universities are sitting 

on their haunches awarding three hours because they have always 

awarded three hours—it makes no difference to them because the 

taxpayers are footing a big chunk of the bill to keep the institutions 

going—maybe they should be awarding four hours, maybe they 

should be recognizing other components of this. You know, we 

know this catfight back and forth about traditionals versus new, 

and online, and innovative, and the rest of it. 

So I am not trying to cast it, but all of a sudden when—what 

caught my attention here was that difference in six units is huge 

across the nation. Now again, this practice was found by your 

accreditors not to be conforming either to what they experienced in 

traditional or online or for-profit institutions, however they deliver 

their course material, or the hybrid, both seat time and online 

time. 

So it jumps out, but I think in some cases they are still doing 

this. Now maybe because of the accreditation the nine units is all 

of a sudden worth nine units, but this is, to me, a very difficult 

question that is now—that has been raised by this series of events 

for the Congress of the United States. 

We have about $100 billion out there on the street. The schools 

under your accreditation are about $24 billion a year. The schools 

that you reviewed, Inspector General, were about $60 billion a year 

in combinations of student loans, you know, underwritten by the 

taxpayers, and Pell Grants, and other assistance that is available. 

So the consequence, I mean, the outcome of this discussion—I 

don’t want to turn this into a debate; I don’t want to turn this into 

finger-pointing, but I just want to put it in this context, which I 

think is something we have to recognize. 

You know, I try to think that I have sort of embraced the policies 

on education of disruptive innovators. I mean, I think that is 

healthy for the whole system and I think we have such great opportunities now with technology to deliver education to people 

where they need it, how they want it, how they can understand— 

you know, all of the things that we know about that. 
30 

But this question of how you assign value—and I have a couple 

of minutes left, and I would just like you, if you might, both of 

you—or all three of you, Mr. McComis, if you want to—is just how 

you respond to is this something that is now just accounted for and 

I am out of sequence for, or what are we doing here? 

Ms. TIGHE. Well, can I just interject a moment, is that I think 

you have certainly hit on the range of our concerns, is that ultimately it is about what the student is paying for and what, then, 

the taxpayer is covering for that student. And I think our particular concern in this case was that there wasn’t an effort to immediately mitigate the harm in that students were allowed to continue to enroll in these courses, thus incurring, you know—the 

problem continuing. 

Chairman MILLER. Sure. 

Ms. Manning? 

Ms. MANNING. I don’t want to spend too much time dealing with 

the technicalities, but because this is on the record and because it 

refers to a specific institution I do want to clarify one point. It also 

is a point that shows how messy this issue of credit values is. 

There is talk about nine units and there is talk about three 

units. The problem is that the nine units is measured in what are 

called quarter units, and the three units in semester units. And so 

if you put them in the same matrix it is six versus three or it is 

nine versus four-and-a-half. And I say that, again, only for the benefit of the institution where this is being publicly recorded. 

Let me say, though, that this demonstrates how messy and complex the issue is. And I want to go back to your point, Chairman 

Miller, also, about the—there is an academic plan and an academic 

purpose, but there is also a business plan, and how these perhaps 

come into conflict with each other, and how an academic plan can 

be manipulated to the benefit of a business plan. 

I want to tell you that we share these concerns profoundly, that 

these are concerns that have appeared on the scene of higher education in less than 10 years, have been significant in perhaps 5 

years, and so that one of the challenges for accreditation has been 

to develop the tools for us in order to be able to understand this, 

to manage it, and to apply appropriate standards. And I believe 

that we have worked very hard in the last 2 years precisely to develop those tools and that we have done a good job. The proof will 

be in the pudding, and the pudding is yet to come. 

We are very concerned about what students are paying for. When 

we took that action we knew that we were looking at a subset of 

course, and we knew something, and I think this is really important: There are two ways in which credit value can be wrong. One 

of them is that a student is in class for 45 hours and does 90 hours 

of homework and gets three credits and it is junk; the other way 

is that a student is in class and gets three credits and should only 

have gotten two credits. I think there is a huge difference there. 

In this case we knew that it wasn’t junk. The question was, can 

students learn this within the timeframe? 

What actually was happening was that they were taking these 

nine units in 5 weeks, and what our teams discovered is that students couldn’t possibly be learning all this in 5 weeks. It is acceptable stuff; it meets industry standards. You can’t do it in 5 weeks. 
31 

The way the institution has remediated the program—the problem—is they have split it in two. These are now two four-and-ahalf-credit courses but they are over a 10-week period. 

So it is not that we didn’t take any action. We actually demanded 

this immediate remediation. And when we got up there to look at 

it the institution was ahead of us. They had actually gone further 

than we had required. And I think that is testimony to the effectiveness of a warning or threat from an accrediting agency. 

And at the end of the day if we had not accredited this institution they would have walked away. They were already accredited. 

They would have gone on getting Title IV funds. But it is not—it 

is certain that at the rate that we got it the problem would not 

have been identified and corrected. 

And instead of putting a bunch of students in the midst of their 

programs in the situation of being at an unaccredited institution 

and having a degree of significantly less value, what we did was 

that we took the situation that was there and we remedied it, and 

we took it very seriously, and we continue to take these instances 

very seriously. 

Chairman MILLER. Thank you. 

Mr. McComis? 

For the members, I am using Mr. Guthrie’s time at this time. 

You have been very generous with your time. 

Mr. McComis, if you have a comment? 

Mr. MCCOMIS. So I can’t speak to the specific—— 

Chairman MILLER. No, no. I understand that. 

Mr. MCCOMIS [continuing]. But we, too, find what the—Chairman Miller, what you are describing is course or program stretching, and our board has long felt very strongly about that particular 

issue, and it is one of the leading reasons why they have created 

this multilayered approach to assessment that includes with it a 

very straight clock hour to credit hour conversion for the development of that, but also a demonstration by institutions through student learning and student achievement outcomes, and external review and comment by employment community program advisory 

committees to really look at the design of a program and that it 

is appropriate for that student in terms of the length. We have particular cases where we have taken action against institutions that 

we felt like the program was too long, or in some instances too 

short. 

Chairman MILLER. Thank you. 

Ms. Tighe, did you have anything else that you wanted to add, 

because I am going to turn it over to Mr. Guthrie? Did you have— 

or are you fine? Okay. Thank you. 

Thank you, Mr. Guthrie. 

Mr. GUTHRIE. Thank you, Mr. Chairman. And I agree in line 

with a lot of your comments, just what you made previously. We 

have to figure out—there is a lot of money involved and it is our 

responsibility, as I said in my opening statement, for the taxpayers 

and what is happening with their money. It is our job, so we appreciate that. 

And I appreciate the I.G.’s report. I appreciate what you have 

presented for us. 
32 

And first, to Mr.—Dr. McComis—you know, in your written testimony—because we are trying to figure out how to handle this, I 

guess, and one thing that we are seeing is the department is coming out with a proposed rule on defining credit hour in the federal 

regulations. And can you talk a little bit more about—I think, you 

know, your—my understanding in your written testimony there 

could be some harms that could come about by a federal definition 

of credit hour. Could you elaborate on that? 

Mr. MCCOMIS. So, as I indicated in my oral testimony as well, 

during negotiated rulemaking one of the points that I tried to make 

relative to the definition that was first presented by the department was simply that the use of the Carnegie Unit as the primary 

definition would relegate our straight clock hour to credit hour conversion formula into the other category that they provide—I think 

the language is somewhere along the lines of other comparable 

methods for determining the length of a program or the definition 

of a credit hour. 

The issue with that is once you begin looking at transfer of credit 

issues it is, ‘‘Well, your institutions don’t offer units that are defined by this Carnegie Unit and so therefore they can’t be 

transferrable,’’ when I think that actually our credits are more rigorous because they don’t allow for outside preparation. It is, again, 

largely our institutions are career-oriented and much of that work 

has to be done in the classroom, and in the lab, and on externship. 

So the narrow definition, I think, could, you know, maybe unintentionally, stifle the opportunity for students to be able to transfer 

those credits. That was the point that I was trying to make. 

Mr. GUTHRIE. And one of the concerns would be—is that if we 

are paying just for credit hour—I understand that that could be 

manipulated—but if you are paying for credit hour you are not necessarily paying for the outcome, and you measure the outcomes. 

And how, in your accreditation process, when you look at outcomes, 

can you go back and see that maybe credits were misallocated or 

misawarded, so—by checking—not just looking at the credit hours, 

you look at the outcomes, and from the outcomes or the quality you 

say you can go back and say that credit has been—credit hours 

have not been allocated properly, which is a way of catching a 

problem, too. 

Mr. MCCOMIS. Sure. So the way that we utilize our student 

achievement outcome benchmarks is to identify potential problems, 

and when a particular program—because we do it by program, not 

by institution—when a particular program begins to demonstrate 

either lower graduation rates or employment rates that fall below 

those benchmarks we begin to do a—require the institution to start 

talking to us about the viability of their program, or efficacy of 

their efforts to improve retention, or graduation, or employment, 

and try to identify the root cause of those lower outcomes. 

Traditionally what we would see is that if a program, you know, 

was too long in length that graduation rates might suffer; if it was 

too short in length employment rates might suffer because the students are not attaining the necessary competencies. So we are looking to really identify that optimal balance between the program design and content with student achievement outcomes. 

Mr. GUTHRIE. Okay. Thank you. 
33 

And then, Ms. Manning—or Dr. Manning—can you describe 

what processes you have in place to ensure that your peer review 

teams—and how you evaluate institutions to ensure that they are 

assigning proper credit hours? I mean, what process do you use to 

see if your peer review teams have—what processes do your peer 

review teams use to ensure the institution is assigning proper credit hours? 

Ms. MANNING. In the normal course of a review, not when there 

has been a problem identified like this one that we were talking 

about earlier, this is part of the review that is conducted on the 

adequacy of the student learning. It is also true that in areas 

where we are required by regulation on behalf of the federal government to look into specific issues we ensure that every team addresses the issues, and with the knowledge that the team will address it the institution is required to address it. 

The normal procedure is that you have a team on the campus; 

it is made up of a number of people with different disciplinary 

backgrounds. They will sample—from the institution’s point of view 

it is an arbitrary or random sample—courses. They will look at syllabi, they will talk to faculty, they will talk to students, they will 

look at the program outcomes that have been identified. 

We require all our institutions to be engaged in assessment. You 

can’t assess unless you have goals and stated outcomes. We require 

those for every program on the institution. 

We test with a random sample, and that is random, not randomized. 

Mr. GUTHRIE. Could you check against—if you say this course in 

other institutions is typically a three-hour course, this one they are 

giving a four-hour course? I mean, do you compare across institutions or just within the institution itself? 

Ms. MANNING. No, we tend to look at—well, it is looking at the 

institution itself against a background of the knowledge of the evaluator who is looking at it. The distinction between a three-unit 

course and a four-unit course is something that I would be very 

hard put to argue is actually a valid distinction that you can really 

make. There would be, I think, much greater variation between 

many three-unit courses at different institutions, or even in different classrooms in the same institution. 

Mr. GUTHRIE. Okay. Because I can see a lot of English 101 at one 

school is three hours, at the next school it is three hours, at the 

next school it is three hours, but a lot of the issues we are concerned about are nontraditional students and probably nontraditional courses, and that, I mean, that is one of the questions I 

guess we have to grapple with as we are going. 

But before I run out of time I do have one more for Dr. McComis. 

You said that you look at the outcomes and then you make actions 

based on the outcomes. What actions can you take? I mean, what 

point do you leave—if you find that you have a program you say 

is of low quality or not meeting the quality, what actions do you 

take as an accrediting agency? 

Mr. MCCOMIS. So there are several programmatic and institutional actions that are available to the commission to remediate 

poor performance in any given program. At the programmatic level, 

an institution might be placed on reporting, where they will have 
34 

to continually go back to the commission and talk to them about 

their improvement efforts, what have they identified as being some 

of the root causes for the lower outcomes, whether those are internal or external, whether they are market forces or whether they 

are internal program content issues. 

They will need to work to identify those and then to assess and 

remediate. When an institution is placed on some form of outcomes 

reporting there are limitations that are associated with that as 

well. 

From there the actions can certainly escalate to other kinds of 

programmatic actions if improvement is not made to require an institution to suspend enrollment while an investigation continues, to 

cease enrollment, or to revoke programmatic approval or distance 

education approval. Institutional actions would include show-cause 

orders or probation orders. 

And probation orders are important because of the transparency 

that is associated with them. Our board requires that once you 

place an institution on probation they have an obligation to tell 

current and prospective students about that action. It becomes public on our Web site and we also identify that for all federal, state, 

and other accrediting bodies as well. 

Mr. GUTHRIE. What kind of frequency for that final—the one you 

just described, what kind of frequency—you have, what, 700—over 

700 schools you—— 

Mr. MCCOMIS. We do, yes. 

Mr. GUTHRIE. Okay, how many would be on this—— 

Mr. MCCOMIS. On probation at any given time? 

Mr. GUTHRIE. Just public—I don’t want you to say it if it is not 

public. 

Mr. MCCOMIS. Maybe 10—five to 10 institutions, for a variety of 

different reasons. 

Mr. GUTHRIE. Okay. 

Thank you. That is my question—— 

Chairman MILLER. Would the gentleman yield for 1 second? 

Mr. GUTHRIE. I will yield. 

Chairman MILLER. Ms. Manning, you said—and I think you correctly say—it would be very difficult to tell the difference between 

a three-unit course and a four-unit course—hard for accreditors to 

do. But this particular institution, that is $613—1,000 students. 

That is a lot of money. 

This is a problem. I am not making this out that we disagree on 

this. This is a problem. 

Before, for all of the reasons we know, when you are trying to 

look at common practices across institutions of higher education, 

and content, and value, and the rest of that, but we now are confronted with this issue that each of those determinations carries a 

cost to the taxpayer. And yet, I want institutions to be able to set, 

you know, to set the content and the course and the time that 

makes sense in terms of what the student is hoping to get out of 

that course if they enroll in that. 

But what we could dismiss in another setting today we have to 

contemplate how we thing about it before we make that determination that it is just a distinction we can’t make, because, you know, 

one of the things we have learned about fees—people learn from 
35 

the telecommunications industry, they like to assess a little tiny, 

tiny fee a billion times a day. And one unit here and one unit there 

doesn’t sound like much, but across this country at these prices, 

you know—geez, if they did it at Harvard it is worth $1,600. Think 

of that. 

Mr. Andrews? 

Mr. ANDREWS. Sounds a lot like—— 

Chairman MILLER. Thank you. 

Mr. ANDREWS [continuing]. Sounds a lot like 401K fees, Mr. 

Chairman. 

Chairman MILLER. It does seem like it. 

Mr. ANDREWS. I would like to thank the chairman for calling this 

hearing because I think it is part of a broader effort this committee 

is embarking upon to try to find quality measurements for higher 

education in the country. A lot of our laws come from an era where 

there was a consensus about quality, correct or incorrect, and there 

was a debate about quantity. 

I think that the dramatic technological and pedagogical changes 

that we have undergone have rendered that consensus about quality to be obsolete, and I think that our committee is going to be 

involved and we need the help with each of you, as witnesses, in 

conducting an assessment of what quality really means in this new 

world. And I think this morning’s hearing is a great step in that 

direction. 

Ms. Tighe, thank you for the good work that you have done. I 

want to be clear that your report did not draw any conclusions or 

distinctions with respect to differences with respect to the ownership of schools involved, right? You didn’t find any pattern that 

would discriminate or distinguish traditional not-for-profits, from 

publics, from for-profits. Is that right? 

Ms. TIGHE. Well, we covered a sample of each kind of school 

when we looked at each accrediting agency. 

Mr. ANDREWS. But there isn’t any pattern that would distinguish 

the results among the three? 

Ms. TIGHE. No. 

Mr. ANDREWS. Okay. 

The second thing I wanted to ask was, in the review of the work 

that Dr. Manning’s agency did you highlighted one particular instance, which we want to talk about in a minute. Were there any 

other instances of accreditation that you found that called for special highlighting? I understand the basic conclusion was that there 

was not a definition of the credit hour nor guidance, but were there 

any other situations of specific school review that you felt the need 

to call attention to? 

Ms. TIGHE. No. In our review of the three accrediting agencies 

we did not see any other instance like that one. 

Mr. ANDREWS. And in the case of Dr. Manning’s organization 

how many accreditations did you look at that they had performed? 

Ms. TIGHE. We looked at, for her organization, I think roughly 

eight different institutions. 

Mr. ANDREWS. Okay. So it is one that we are focusing on here 

out of that eight. 
36 

Now, Dr. Manning, I wanted to get the timeline straight on the 

one that is controversial here. Am I correct that your team visited 

this school in March of 2009? 

Ms. MANNING. Yes. 

Mr. ANDREWS. And your team did find this—they did use the 

word ‘‘egregious’’? 

Ms. MANNING. They did. 

Mr. ANDREWS. And the fact pattern that was egregious was that 

in their judgment coursework that should have been awarded, say, 

four-and-a-half credits was awarded nine. Is that right? 

Ms. MANNING. That is right. 

Mr. ANDREWS. Okay. Now, when they discovered that what remedial action—you testified that now what the institution has done 

is to break that course into two 5-week, four-and-a-half-unit 

courses, and in your judgment that satisfies the problem. When did 

the institution do that? 

Ms. MANNING. They did that in the course of the fall of 2009. 

Mr. ANDREWS. In the fall of 2009. So were there students between the March 2009 review and the fall of 2009 that continued 

on in this nine-credit course that should have been four-and-a-half? 

Ms. MANNING. Yes. 

Mr. ANDREWS. Okay. And I don’t mean this as a rhetorical question, but why did your organization choose—as I understand, the 

remedial measure that you chose was to sort of point this out to 

the school and encourage them to do something about it. Is that a 

fair characterization? 

Ms. MANNING. I think ‘‘encourage’’ is a soft word. 

Mr. ANDREWS. But you didn’t—— 

Ms. MANNING. We threatened. 

Mr. ANDREWS. Okay. But you didn’t withhold their accreditation. 

Ms. MANNING. We did not withhold their accreditation. 

Mr. ANDREWS. Okay. What was the basis of that—if it is not proprietary or subject to litigation—what was the basis of that remedial judgment? Why didn’t you recommend a suspension or at least 

an—here is our concern: The records would then show that between the spring of 2009 and sometime in the fall of 2009 students 

were paying more than they should, taxpayers were paying more 

than they should. It was evidently corrected by the fall, but why 

the interim? Why did we permit that interim to occur at all? 

Ms. MANNING. You know, I think the—part of this is to see 

whether it is a question of were they being overcharged or was 

there a deficit in academic quality in what they were getting. I 

think that is really the difference. We were saying, ‘‘You can’t have 

learned this much.’’ It would have been lovely to correct this instantly, but we do not believe that it could have—you can’t correct 

these things overnight; you have agreements with students. 

Mr. ANDREWS. My time is up, so I have this final question: Why 

didn’t you decide to make their accreditation conditional upon fixing this by some date certain? 

Ms. MANNING. Well, in effect we did that. We accredited them, 

and we told them—— 

Mr. ANDREWS. But if they had not made this decision voluntarily 

they would still be accredited, wouldn’t they? 
37 

Ms. MANNING. No. If they had not made this decision we would 

by now have been moving to withdraw their accreditation. We 

would have—— 

Mr. ANDREWS. Was it a condition of their accreditation? 

Ms. MANNING. We have not had a practice of expressing it as a 

condition, but we do have a practice of saying, ‘‘This must be remediated and you must come back by this date and show us that you 

have remediated it.’’ 

Mr. ANDREWS. So you are saying it is the functional equivalent 

thereof? 

Ms. MANNING. Yes. 

Mr. ANDREWS. Okay. 

Thank you, Mr. Chairman. 

Ms. TIGHE. Well, I was just going to point out that at the time 

we did our field work, which was late in the summer of 2009 the 

remedial measures being instigated by Higher Learning Commission were a requirement of a self-study by AIU and then a focused 

visit that was scheduled for, actually, this coming school year. Now, 

I obviously can’t speak to what measures were taken since that 

time. 

Mr. ANDREWS. I understand. 

Chairman MILLER. Mr. Hinojosa? 

Mr. HINOJOSA. Chairman Miller, thank you for having this critically important hearing on the inspector general’s review of standards and programs linked in higher education. As subcommittee 

chairman on higher education I am committed to ensuring that our 

institutions of higher learning and career and technical colleges 

provide high-quality educational and training programs to all students. The inspector general’s findings are of great concern to me. 

At this time I have a question for Inspector General Kathleen 

Tighe: In your testimony you indicate that the explosion of online 

education in recent years has made it even more difficult to assign 

credit hours and assess student achievement. I strongly support 

the Department of Education’s proposed regulations pertaining the 

definition of a credit hour. 

Tell me, what types of minimum standards should accrediting 

agencies develop to ensure that students and taxpayers receive 

what they are paying for? 

Ms. TIGHE. Well, I think the most critical standard is the one we 

have been sort of talking about today, which is the definition of a 

credit hour. I think that it is not only the vehicle that—you know, 

the unit that most, you know, institutions use to define—you know, 

to have students pay for classes, it is how federal student aid gets 

dispensed, which is ultimately our concern. 

And I think it is that definition, which I think in truth we are 

not looking at it from the perspective of it has to be the Carnegie 

Unit; I think it can be a flexible definition, and I think that it can 

take into account student outcomes and the other things. But I 

think it ultimately is up to accrediting agencies to develop a definition. 

Mr. HINOJOSA. Since we see some colleges with quarterly semesters and then others that are the regular semester—and I am not 

sure about the for-profit colleges—couldn’t we just make everybody 

be standard on the same length of time? 
38 

Ms. TIGHE. Well, I think you could do that, but I think it is probably not necessary to do that. I think that you can have a credit 

hour mean something and have different program lengths even 

with that. 

Mr. HINOJOSA. Okay. 

My next question is to Dr. Manning with the Higher Learning 

Commission. In your testimony you have underscored the need for 

accrediting agencies to focus on student learning outcomes. Do you 

agree with the inspector general that it is necessary for accrediting 

agencies to have a precise definition of a credit hour and establish 

minimum requirements for program length in addition to considering learning outcomes? 

Ms. MANNING. I think that we can work with a definition of credit hour as has been proposed. Where I think we are skeptical is 

whether that definition will, in fact, ensure the quality of what a 

student learns in those hours. And the understanding of what a 

student should learn not in so many credit hours but in introductory chemistry is something that is well held by the professors of 

chemistry. 

And our argument has simply been that we have not had lax 

standards because we haven’t told them what that is. We have 

worked on a system where we have brought in people who understand that and who hold institutions to those standards. 

And let me just say also, with reference, as well, to Chairman 

Miller’s earlier point: Because this is always a slightly fuzzy area 

that is another reason why it is so important for us to say, ‘‘Minimum standards don’t do it.’’ You have got to significantly exceed. 

We want high quality. 

Mr. HINOJOSA. My last question is to Dr. McComis: What are accrediting agencies doing now to ensure that there are minimum 

graduation rates, placement rates, and licensure rates for the vocational education programs? Address my question for the public colleges versus the for-profit college or university. 

Mr. MCCOMIS. So, I can speak most specifically about our agency. 

We have, since 1998, had quantitative standards for graduation 

rates and employment rates for each program offered within an institution. 

Those rates are calculated—the required benchmarks, thresholds 

that we use—are calculated through collecting annual data from 

each program offered by our institutions and aggregating those and 

coming up with an average and then a standard deviation. The 

standard deviation represents the benchmark because it represents 

those—the lowest-performing group within the set of data that we 

are using. 

As I said earlier, we then require each institution to demonstrate 

that their programs exceed those benchmarks, and if they don’t 

they move into some kind of monitoring mechanism, anywhere 

from heightened monitoring that, over time, could lead ultimately 

to some other kind of institutional action, all the way up to revocation of accreditation. 

Mr. HINOJOSA. My time has run out. I yield back. 

Chairman MILLER. Mr. Petri? 

Mr. PETRI. Mr. Chairman, thank you very much. And thank you 

for scheduling and holding this important hearing. 
39 

And, Ms. Tighe, welcome to your new assignment. You have—— 

Ms. TIGHE. Thank you very much. 

Mr. PETRI [continuing]. You have a very big and important job, 

and I—probably it is basically almost impossible. 

I have a lot of concerns about the whole accrediting process. I 

thought it worked very well when it was voluntary and groups of— 

on one basis or another—of schools, institutions, would get together 

for mutual evaluation, and self-help, and setting standards, and 

helping the public then choose based on that approach. 

We built on that when we got into the student loan business, and 

G.I Bill of Rights, and all of this after World War II thinking that 

that was a pretty good proxy for quality in one thing and another, 

and it didn’t work very well so we put in a whole new process to 

look after student loan repayment rates. But anything that we do 

seems to create a system where people start gaming it. 

And as long as we focus on inputs—trying to define an hour or 

something like what are a credit hour—we are avoiding the fact 

that we could just give a test to people before they went and after 

they went and see if they made reasonable progress and fine the 

school if they didn’t, or some simple sort of a thing where you actually—because different classes are going to have different requirements, and as you said, distance learning, and the 101 different 

ways around this. It is basically never going to happen. 

And even in accrediting, when I meet with the accreditors with 

the schools in my district what they say is, ‘‘We are so different. 

We are accreditors. We define what our objective is and they try 

to measure us on basically how we achieve the objectives we have 

defined.’’ And so that is kind of a circular thing, and what it has 

to do with quality or anything else is beyond me. So I don’t know 

if you have any observation on that. 

And the other area we are wrestling with as a committee is the 

90-10 rule, and what if people are gaming it. And it turns out, evidently that applies over a very short period of the repayment of 

loans, meaning we should have a longer period and we should look 

at if these proprietary or other schools are giving other aid to students and then they are using it to come within the 90-10 rule— 

is that really what we are talking about? It is a huge problem, and 

we are going to have to get a handle on it or we are going to have 

another big mess on our hands. 

Ms. TIGHE. We would agree. I mean, we are obviously always 

looking to—I mean, that is part of our job is looking to people who 

game the system. 

I think as far as your first point, I think, you know—yes, I think 

one theoretically could just give a test at the beginning and then 

measure, you know, academic engagement and student, you know, 

learning on that basis. The problem is, I think that is a difficult 

way to dispense, you know, federal student aid. 

And for better or for worse the way we do that is by credit hour, 

and I think it ought to have some meaning to the student and to 

the taxpayer that is somewhat—that both allows for innovation in 

learning, but yet gives some minimum requirement. And, you 

know, that is sort of, you know, why we went in and did our review. 
40 

The 90-10 rule obviously concerns us. We have had a number of 

cases—investigations—based on schools who are gaming that issue. 

It is something we are also concerned about. 

Mr. PETRI. Thank you. 

Chairman MILLER. Mr. Bishop? 

Mr. BISHOP OF NEW YORK. Thank you, Mr. Chairman, and thank 

you for holding this hearing. 

And thanks very much to the panel. 

I used to administer a college in New York State, and so my experience—New York State is very prescriptive; if you want to have 

an academic program in New York State you have to register with 

the State Education Department even if you are a private college, 

and the State Education Department uses the Carnegie Unit as a 

measure of an academic credit. I have to say, we found that to be 

very helpful to have some minimum threshold level that defined a 

credit, that defined a course, that defined the length of the semester, and so on. 

Dr. Manning, you had said in your comments this morning that 

the definition of the credit hour is deeply understood. You also said 

that this issue is messy and complex. 

So I have two sort of related questions: one, if it is deeply understood what is the harm in citing some minimum level that reflects 

that deep understanding? And if, in fact, this is messy and complex 

wouldn’t we deal with some of the messiness and complexity if we 

had some clear minimum definition of what constitutes a credit 

hour? 

So I guess my question is, what is so unhelpful about having a 

minimum definition, and what about a minimum definition would 

preclude innovation, would preclude the kinds of new molds of educational delivery we are working towards? And what about a minimum definition would make it more difficult to measure outcomes, 

which we all agree is where we want to be? 

I had a lot of questions. I am sorry. 

Ms. MANNING. Yes. Let me try at least to get at most of them. 

First of all, I want to just say that in my written testimony I 

said—I may not have made it clear in the oral testimony—that we 

do not believe having a definition will cause harm. I think that is 

the first thing. 

When I say it is deeply embedded, we all have lived with the 

credit hour for all of our working lives. We do find it very useful. 

It is so deeply embedded in so many different things that higher 

education does that it is actually hard to conceive how we would 

manage if we took it out. 

So there is no question that it is there and it is understood, and 

there is no harm in writing it down. There will be costs involved 

in demonstrating compliance, and I think that is something that is 

always a question with regard to regulation. And these are tight 

times, as you know, for everything, including higher education. 

Mr. BISHOP OF NEW YORK. May I interrupt you? 

Ms. MANNING. Sure. 

Mr. BISHOP OF NEW YORK. Would the costs that are involved in 

demonstrating compliance—would they outstrip the cost that would 

be involved in demonstrating outcomes? 
41 

Ms. MANNING. I don’t think they would. Not at all. I think that 

the—there is a serious cost to demonstrating outcomes, but our belief is that if you don’t demonstrate outcomes you don’t know what 

you are doing. That is, it is the Yogi Berra thing, right, if you don’t 

know where you are going you will never know if you got there. 

So we require institutions to define objectives for every program. 

We don’t second guess those objectives. We are not program 

accreditors. We accredit an entire institution. 

So the question is, would the messiness and complexity be helped 

by a definition? The definition gives you a way, gives you a metric. 

Every institution uses it. 

I was really referring to the fact, frankly, that if you go on most 

campuses—and perhaps the campus that you were on had this 

same thing—and you ask the scientists about the credits in the humanities they will tell you they are soft because there is no math. 

And exactly how you distinguish between three credits of chemistry, or how you compare three credits in chemistry and three 

credits in English is frankly beyond me. 

So that is the kind of thing that I meant by messy. You are accrediting a, you know, medical school, you are accrediting fine arts 

majors—it is a whole wide area. 

But again, let me repeat: I do not think the definition of a credit 

hour will do harm. I just feel that if our primary shared goal is a 

quality of what is being delivered to students in this country then 

the credit hour—it won’t impede it, but it won’t contribute to quality. 

Let me add one more thing about why we get so nervous about 

these kinds of definitions. If you think about 15, 20 years ago, if 

we had had—at that time if there had been a definition it would 

not, as the proposed regulations that were published yesterday do, 

take into account the idea of you making equivalencies based on 

learning objectives and student outcomes; it would have simply 

been the Carnegie Hour—3 hours in the class is three units plus 

6 hours of homework. 

And you know, I don’t know how, under those circumstances, we 

would have developed online learning and taken advantage of the 

immense opportunity the Internet offers. And I think, frankly, one 

of our problems right now, though it is not our major problem, is 

that people tend to conflate online learning with for-profit delivery. 

Eighty percent of the institutions in this country do a significant 

amount of online learning; it presents enormous opportunities to 

people who are place-bound, people who have full-time jobs, and so 

forth. 

And so that is an example, if you do a what if historically, that 

says to you, ‘‘Does having tight minimum standards always work 

for the greater good?’’ It wouldn’t have. The regulations that have 

been proposed have more flexibility, and we recognize that. 

Mr. BISHOP OF NEW YORK. Okay. 

Thank you. 

Chairman MILLER. Mr. Polis? 

Mr. POLIS. Thank you, Mr. Chair. 

Dr. McComis, thank you for sharing with us the policies and 

practices of the Accrediting Commission of Career Schools and Colleges. In your testimony you expressed concern about federal regu-
42 

lations potentially exacerbating the difficulty that students attending our schools—your schools—already have in the area of transfer 

of credit. I found this to already be a big problem for many students in my state who thought they could transfer to a public or 

nonprofit college or university after attending a for-profit school 

but then later found out that the credits that they had earned were 

not recognized or accepted. 

On your Web site of your organization you describe how the need 

for greater portability of educational credits has reached a critical 

point and that your efforts continue to increase the options that are 

made available to students and graduates, from your institutions 

who are interested in continuing their education. So really, it 

seems to me that defining a credit hour and establishing procedures for accrediting agencies to determine whether an institution’s 

assignment of credit hours is acceptable would help expand credit 

portability. What are your thoughts on that? 

Mr. MCCOMIS. Well, as I indicated earlier, I think that once you 

have the definition there it becomes the definition, and we don’t 

currently use the Carnegie method; we use the clock hour to credit 

hour conversion method. And so it does not take into account outside preparation. 

So once the federal government defines what a credit hour is as 

the Carnegie Unit, if you are not using that that is another opportunity and excuse for an institution to say, ‘‘Your credits are not 

transferrable,’’ even though the content is—can be completely comparable, maybe even more rigorous. There is just that opportunity 

for that to occur. 

So, as Ms. Manning has indicated, we don’t object to, necessarily, 

a regulation, but that a great flexibility within that regulation that 

maybe provides criteria for what a credit hour is as opposed to 1 

hour and 2 hours, as the Carnegie Unit puts forth—or maybe some 

other option that would allow for comparable credit hour conversions. 

Mr. POLIS. You know, there is a recent article in the Chronicle 

of the Higher Education, May 27th, and the president of the Career 

College Association, which represents most of the schools that you 

accredit, was quoted saying that the inspector general’s report was 

‘‘silly.’’ I would like to solicit your opinion with regard to whether 

you agree with that characterization of the report that our committee is holding a hearing on today. 

Mr. MCCOMIS. Well, I don’t agree with that characterization. I 

think that all the work that the I.G. has done in this area has been 

extremely important, and our agency has benefited from it as well. 

We underwent an I.G. investigation in 2002 relative to program 

length; they made some excellent recommendations and we followed up on many of them, and I think strengthened our process. 

Mr. POLIS. Do you find it troublesome that the president of the 

association representing most of the schools you accredit would 

consider this report, which you believe is a serious component contributing to quality—do you find that troublesome that the president found that to be silly? 

Mr. MCCOMIS. I don’t know the context within which that statement was made, so I really couldn’t comment as to it. 
43 

Mr. POLIS. You say you also want the department to refrain from 

overly-prescriptive requirements so they don’t stifle flexibility and 

innovation, and I think we all share that same concern. But I also 

think we agree that protecting the integrity of federal financial aid 

programs from inflated credit hours, improper designation of fulltime student status, et cetera, are also of paramount importance 

not only to taxpayers but to the kids themselves. How do you recommend that the proposed rules can balance those two goals? 

Mr. MCCOMIS. So, I think one of the things that the I.G.’s report 

did was certainly to bring to light that there may be some competence issues with the way in which accreditation might evaluate 

program length and credit hour definitions. I think, largely, that 

accreditors do that very well, and the one case that has been cited, 

I think, may not be representative across the board. 

So, you know, looking at opportunities, again, multilayered reliance upon accreditation to work with their institutions to define 

the best opportunities for their students is really important—again, 

not against a regulation, but looking for that regulation to be stated in such a way that provides for potentially even the unknowns 

in program design and development as they will occur over the 

coming years, as Ms. Manning has already testified. 

Mr. POLIS. Well, thank you. 

And I yield back. 

Chairman MILLER. Mrs. McCarthy? 

Mrs. MCCARTHY. Thank you, Mr. Chairman, and I appreciate the 

hearing. I think it has probably been very educational for all of us. 

But I think one of the things that we are looking at—not only looking at the credit, but I think that the larger amount is, how do we 

measure the quality of the education that we are looking at when 

the students graduate? 

So I guess that I will ask Mr. McComis on what improvements 

do you think should be made to the accreditation process for proposing that they are carrying over a reliable measure of institutional quality for the purpose of awarding of Title IV funding? 

And, Dr. Manning, you know, in your testimony several times 

you had mentioned that you do think that the department proposal 

rule on a credit hour will lead us to the higher quality which we 

all seek in higher education, so what I am looking for is what is 

the recommendation of how do we get to finding out how we get 

the higher quality of education and how do we find that with the 

students that are graduating? 

Mr. MCCOMIS. Yes, ma’am. I will go first. 

So, recently our agency has sought to work on that question, and 

we have developed a number of student learning assessment and 

outcome standards that we have put into place as of last year that 

really focus on a process of assessment, that really look to the institution being able to demonstrate—not necessarily through quantitative measures—but being able to demonstrate what is the process that they use to determine that a student has acquired the necessary skills and competencies and knowledge at a level that would 

provide the institution with an opportunity to award that student 

with a credential. 

How did that student, in the vocational and career-oriented 

areas—how did you make a determination that that student is 
44 

competent to go out and be a nurse, or a truck driver, or a technician? What were the tools that you used? What were the rubrics 

that you used? What were the tests that you used? What determinations did you come to through that process? 

That, coupled with our graduation and employment rates, make 

for this—and also the use of external program advisory committees 

made up of the employment community—provide us with this multilayered approach, and those are the approaches that I think will 

lead us down to a path of greater confidence in the quality of those 

programs. 

Mrs. MCCARTHY. Just quickly, too, don’t the states, especially 

with the courses that we are talking about, whether it is nursing, 

truck driving, they either get certified or they have to take a state 

license test? I mean, isn’t that also a quantity of proof? 

Mr. MCCOMIS. Yes, ma’am, it could be. It is one of several indices 

that an institution could use to demonstrate student learning. 

Mrs. MCCARTHY. Dr. Manning? 

Ms. MANNING. Thank you. I think that to get at the quality—and 

again, I want to make sure we have said this—we actually do use 

credit hours, but what we don’t use is a strict definition, and part 

of this has to do with the fact that we believe people know what 

credit hours are, at least the evaluators that we use. 

But to get at what I believe is your question about how are we 

going to improve and how are we going to assure that we get higher quality, I think assessment is the key to it, and I think that the 

assessment is best carried on at the institutional level because it 

needs to be relative to what the institution is teaching. And remember that the institutions we accredit are often very complicated; they will often have a couple of hundred programs, not a 

program, and programs that are very different from each other. 

What we need to do—and we have been working on doing this 

for about 20 years—is to hold the institutions accountable for having assessment measures appropriate to each and every one of 

their programs based on program objectives. And then—and this is 

the part that is the next challenge—we have actually gotten institutions to be pretty good about assessment. 

There is something in the businesses called ‘‘closing the loop,’’ 

and that means when you assess and you discover that you are not 

getting the results you want what do you do about it and what 

changes do you make in how you teach, how you run your program, 

what your curriculum is, to improve those results? 

And we encourage the use of multiple indicators so that in professional fields, for example, when there are licensures exams, that 

is something that should be taken into account. When these are 

undergraduate programs and students are seeking to go on to graduate work the success rate should be taken into account. 

And so I think that pressure for more assessment and for more 

transparency about the outcomes of student learning is something 

that should be sustained. 

Mrs. MCCARTHY. Thank you. 

I yield back. 

Chairman MILLER. Ms. Hirono? 

Ms. HIRONO. This is pretty interesting. You know, I think that 

when we talk about accrediting I am looking for objective measures 
45 

because how can you measure what the value of a liberal arts education is versus all those other professions, such as law, medicine, 

engineering, nursing, where licensure is one way that you can objectively determine whether or not the quality has been there. So 

at the least I would—I think it makes sense that we have some 

sort of minimal national objective definition. 

And I don’t think, Ms. Manning, you are objecting to that. How 

we are going to get to the quality issues where—on things like 

English, literature, I don’t know, and I kind of go with what you 

just described, that the institutions should be encouraged to develop those kinds of assessment tools. 

Let’s face it, by the time we get to higher education I think that 

so many of our colleges and universities—the quality issue is one 

that is based on their reputation and any number of factors that 

are very difficult to measure. So based on what I am—I am sorry 

I was late for this hearing, but it seems to me that we are going 

in the right direction with what the inspector general is proposing. 

If anybody has any further comments? 

Ms. MANNING. I could respond to that a bit with particularly 

your concern about how do you measure liberal arts education, for 

example, also because I am a liberal arts educator so it hits right 

home to what I do. And I just wanted to offer you something that 

might give you a little optimism about how we can be working on 

this. 

It is not coming out of the accrediting community. The leadership 

on this project is coming out of the American Association of Colleges and Universities where they have been working to create rubrics in which—under which it is possible to assess the outcomes 

not of English versus history, but the outcomes of a liberal arts 

education, and not just a liberal arts education, but liberal education for all students, because we believe that the outcomes, the 

goals of liberal education are important for engineers and doctors 

just as they are for people who go on to become English professors. 

And so that work is progressing and it is something that is 

being—the outcome, the results of that work are being adapted by 

more and more colleges and universities across the country. And so 

I think you will see a kind of more articulated consensus, and 

therefore a basis on which to benchmark what students learn even 

in the liberal learning part of their education. 

Ms. HIRONO. Well, could you give me an example of what would 

be a measurable outcome for the value of a liberal arts education? 

I am not quite understanding—— 

Ms. MANNING. Oh, you look at the large questions about what is 

it—you know, why is it a good thing to major in English, or major 

in history, or in philosophy? And what we say is, it is not because 

the country needs a whole number of people who have read Shakespeare; it needs a number of people who can think critically, who 

can read at a high level, who can solve problems, who can work together in teams, who can have a global perspective, which is something we need in our—— 

Chairman MILLER. Keep going. I love this definition of a liberal 

arts graduate. 

Ms. MANNING. No, I am going to stop. [Laughter.] 

Chairman MILLER. Makes me feel so good. 
46 

Excuse me, Ms. Hirono. 

Ms. HIRONO. Okay. Thank you very much. 

Thank you, Mr. Chairman. 

Mr. MCCOMIS. I would just add, if I could, I think your question 

actually goes to the issue of the difference amongst accreditors and 

the difference amongst the institutions that they accredit and the 

importance of those agencies being able to work with their institutions. My agency doesn’t deal with liberal arts; we are very careeroriented, so it is—we can have different kinds of standards because 

of that, and we do. 

And so I wouldn’t suggest that every institution would be able 

to meet our standards that offer those liberal arts educations. I 

think that would be very difficult for some of them to do. So again, 

just an important distinction about the importance of accreditors 

being able to work with their institution to define those outcomes. 

Ms. HIRONO. I agree, because some institutions, as you say, you 

know, graduates of your institutions, there are measurable—objectively measurable—standards that you can apply. Not so much in 

the liberal arts side, although I am glad to know that there are developing measures there, too. But I think that that should be—I 

tend to go with what Ms. Manning is saying, that it is the institutions that should develop those and not some federal requirement 

or standard. 

Thank you. 

Chairman MILLER. Thank you. 

We are almost done here. Earlier, in my opening questions, I 

raised the question, what is the impact of an invested business 

plan and the needs of some for-profit institutions. And in reading 

from the alert memorandum, when the discussion was that the difference between AIU’s credit policy at that time—not today, at that 

time—and the common practice of higher education, the difference 

was—where they stated it was egregious. I go on to read to say 

that it essentially permits an undergraduate degree completion student to get a bachelor’s degree or an associate degree plus 1 year 

of full-time equivalent study, not 2. This calls into question the integrity of AIU degree and must therefore rectify quickly if AIU is 

to retain an accredited status. 

And reading from the memorandum in the next paragraph, ‘‘The 

implication of this analysis is far-reaching for AIU, affecting degree 

requirements, faculty requirements, and financial aid policies. The 

current policy of awarding a bachelor’s degree for an associate plus 

10 nine-credit courses seems actually the equivalent of an associate 

plus 30 semester hours, so the current degree is the equivalent of 

an associate plus 1year of full-time study, not 2. The team viewed 

this as a matter affecting the integrity of AIU. If the credits were 

to be properly calibrated, students who evaluate AIU’s value proposition in terms of cost of degree, time to degree, may see that the 

cost and time double. If AIU cannot raise the cost of degree without 

losing too many students and if 90 quarter units requires 20 

courses, not 10, then the number of faculty needed to serve the existing level of student enrollment would double, increasing the instructional cost above the current 12 percent of revenues.’’ 

Next paragraph: ‘‘Unless students are willing to pay more for 

their degrees the net effect would be to raise the percentage of rev-
47 

enue spent on instruction toward a figure that is more typical of 

the online universities represented on this team.’’ 

Next paragraph: ‘‘The recalibration of credit awards might also 

affect the meaning of a full-time student eligibility for federal student loan aid. AIU has been requiring all upper-division students 

to be full-time, meaning that they take nine credit units per 5-week 

session. This policy may need to be reconsidered, permitting students to study part-time.’’ 

And then it says, ‘‘The team provided further support of detail 

support of its finding.’’ This paragraph starts, ‘‘The current practice 

of AIU students to take nine credit courses every 5 weeks thus, in 

a 15-week period comparable to a semester in other universities, 

the AIU student would take 27 credits, comparable to 18 semester 

hours or six three-semester hour courses.’’ 

This would be an overload for a full-time student at a university 

on the semester system, given that the typical AIU student is also 

working full-time and may be—and have family obligations, or 

want to ‘‘have a life,’’ in addition to their studies. It is doubtful that 

the AIU student could hold down the equivalent of six semester 

courses on top of this. 

The footnote that refers back to the question of unless students 

are willing to pay more for their degrees the net effect would be 

to raise the percentage of revenue spent on instruction more typical 

of the online universities represented—I assume that means the 

members of the team, that some of them were from online universities. 

The footnote says, ‘‘The team found that according to CEC’s 2007 

financial statements that the profit of the Career College Corporation attributed to AIU was in excess of $40 million. The team stated that AIU’s expenditures on instruction, as a percentage of revenue, is low by comparison to other proprietary institutions familiar with—familiar to the team and that it is likely to be related to 

the issue of credit equivalency.’’ 

There you see how this is woven in and out, how these determinations are made. I don’t pretend to know the answer to this, 

but I don’t think that we can ignore that this is an overlay on 

what—as much as we talk about the Carnegie Hours changing, and 

looking at outcomes and equivalencies, as even the department has 

just done with this proposed rule, what has also changed is that 

now institutions have requirements to shareholders, to profit margins, to the stock market, and to others. And I think you heard 

from the range of questions here that this is a matter of serious 

concern. 

We have votes—I wanted to get back to Mr. McComis on how 

they sort of accredited, and I recognize the different institutions— 

you do not do liberal arts, but you do have certain minimums, and 

I was sort of interested in whether that—but I am not going to ask 

you to answer whether you sense that that is a race to the bottom, 

as perhaps was suggested if you did it across the board, that that 

might be the case. 

But I am also concerned about the discussion that went back and 

forth between Ms. Manning and the inspector general. And I think 

it is a very legitimate discussion, this question of if you are not 

going to have input requirements—seat hours, I guess that is what 
48 

that was—and minimums, and we are transitioning to outcomes as 

another measurement but we don’t have any minimums in outcomes. How is Congress to know whether or not we, as stewards 

of the taxpayers’ money, are in fact purchasing value for people 

who are hungry for the education, the knowledge, the skills that 

it brings to them? 

But I think maybe—I don’t know know whether we will do that 

in the hearing or whether we will do that in the committee briefing 

where we might ask you to come back, and some others from the 

community, to have that discussion, because I think it is important 

because we see even again, from the proposed rule, that a transition is taking place here, but we have this huge overlay of this 

$100 billion that is out there on the street. 

I want to thank you very, very much for your time. I didn’t want 

this to go into a back and forth about this. I think that this particular case raises a whole series of issues that we have had a very 

difficult time trying to even articulate in the congressional setting. 

I don’t think any of you were set out to do that, but I think that 

is how I view both the work of the accrediting agency, of the I.G., 

of the institution’s response, and I just want to thank you for your 

participation and your expertise. And we will be following up with 

you again, if you don’t mind. 

Thank you very much. 

And with that, the committee will stand adjourned and Ms. 

Hirono and I will see if we can beat—well, we only have to beat 

100 of our colleagues to the floor. 

Thank you very much. 

[Whereupon, at 11:49 a.m., the committee was adjourned.] 

Æ