To: Program Integrity and Institutional Quality Committee

From: Jamienne S. Studley, Negotiator, Institutional Accreditors 

Michale McComis, Negotiator (Alternate), Institutional Accreditors

Laura Rasar King, Negotiator, Programmatic Accreditors 

Subject: Change of Accreditors – Section 600.11 

Date: February 27, 2024

Thank you for your attention during this busy time to this brief memo on Sec 600.11. 

There is broad support among accreditors for the proposition that institutions should be 

able to change accreditors to serve their mission, students, and quality improvement 

efforts. Currently, the Secretary reviews any request from an institution seeking to 

change accreditor based on an examination of “reasonable cause,” which may not 

include a situation where an institution is avoiding sanction or adverse action. 

Separately, accreditors are required to have “voluntary” membership. These screens

operate alongside the Department’s regulatory oversight of accrediting agencies to 

assure that agencies apply core accreditation standards and required procedures to 

promote quality. 

Accreditors agree with the Department that it is not in the best interest of students or 

institutions for institutions to change accreditors frequently. Those actions could 

undercut both the accountability and improvement functions of accreditation. From an 

operational perspective, excessive switching could make it difficult for agencies to 

properly make decisions about capacity and siphon off resources better directed to 

students. We respect that the Department is seeking to create reasonable guardrails 

and conditions as to how it will exercise its authority and make decisions under these 

rules. 

Notes and questions: 

1. The proposed language under 600.11(a)(1)(C) would prohibit an institution from 

moving to a new accreditor if it has “not yet completed two full accreditation cycles 

with its current accrediting agency.” ED has proposed adding a proviso that 

institutions might return to their prior accreditor. We look forward to further 

discussion of this section. 

a) The controlling measure of accreditation ‘cycles’ is the time between 

comprehensive reviews of institutions for initial or reaffirmation of 

accreditation. Agencies set the time between comprehensive reviews 

(within federal maximums) and the periods currently range from 6 to 10 

years. Referring to a number of ‘cycles’ could yield inconsistent results 

and difficulty in monitoring. It is also unclear whether a period of 

candidacy would count as a “cycle.” Is the Department’s intent to assure 

a minimum number of review rounds, or to assure a consistent period of 

time of accreditation by one agency before a move would be allowed to 

another? 
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b) The regulation might be revised to provide that, rather than an absolute 

barrier, the Secretary take into account in determining “reasonable basis” 

whether an institution has moved recently or how long or how many cycles 

it has been with the current agency. That could be in the form of a 

rebuttable presumption or similar mechanism to balance the Department’s 

apparent interest in controlling changes without unduly constraining 

institutions in circumstances that may not be foreseeable now. 

c) How is the Department advising states with actual or potential legislation

on this subject with regard to provisions that mandate changing

accreditors every cycle or on a specific timetable? North Carolina law, for

example, includes such a provision.

2. The proposed language under 600.11(a)(1)(D) would prohibit an institution from 

moving to a new accreditor if it “has been directed to select a particular accrediting 

agency by a party other than the institution.” We would appreciate insight into how

the Department would define and determine whether an institution has been 

“directed” to change accreditors. While this discussion is understandably driven 

by recent and potential state laws, any new restrictions and tests should also 

be adaptable to other situations and types of institutions and minimize

unintended consequences. 
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