ASSURING QUALITY AND ACCOUNTABILITY IN 

POSTSECONDARY EDUCATION:

ASSESSING THE ROLE OF ACCREDITATION 

HEARING

BEFORE THE 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS 

OF THE 

COMMITTEE ON EDUCATION AND 

THE WORKFORCE 

HOUSE OF REPRESENTATIVES

ONE HUNDRED SEVENTH CONGRESS

SECOND SESSION

HEARING HELD IN WASHINGTON, DC, OCTOBER 1, 2002 

Serial No. 107-81 

Printed for the use of the Committee on Education 

and the Workforce

83-028 pdf 

For sale by the Superintendent of Documents, U.S. Government Printing Office 

Internet: bookstore.gpo.gov Phone: (866) 512-1800; DC area (202) 512-1800 

 FAX: (202) 512-2250 Mail: Stop SSOP, Washington, DC 20402-0001
ii

COMMITTEE ON EDUCATION AND THE WORKFORCE 

JOHN A. BOEHNER, Ohio, Chairman 

THOMAS E. PETRI, Wisconsin GEORGE MILLER, California 

MARGE ROUKEMA, New Jersey DALE E. KILDEE, Michigan 

CASS BALLENGER, North Carolina MAJOR R. OWENS, New York 

PETER HOEKSTRA, Michigan DONALD M. PAYNE, New Jersey 

HOWARD P. “BUCK” McKEON, California ROBERT E. ANDREWS, New Jersey 

MICHAEL N. CASTLE, Delaware TIM ROEMER, Indiana 

SAM JOHNSON, Texas ROBERT C. “BOBBY” SCOTT, Virginia 

JAMES C. GREENWOOD, Pennsylvania LYNN C. WOOLSEY, California 

LINDSEY O. GRAHAM, South Carolina LYNN N. RIVERS, Michigan 

MARK E. SOUDER, Indiana RUBEN HINOJOSA, Texas 

CHARLIE W. NORWOOD, JR., Georgia CAROLYN McCARTHY, New York 

BOB SCHAFFER, Colorado JOHN F. TIERNEY, Massachusetts 

FRED UPTON, Michigan RON KIND, Wisconsin 

VAN HILLEARY, Tennessee LORETTA SANCHEZ, California 

VERNON J. EHLERS, Michigan HAROLD E. FORD, JR., Tennessee 

THOMAS G. TANCREDO, Colorado DENNIS KUCINICH, Ohio 

JIM DeMINT, South Carolina DAVID WU, Oregon 

JOHNNY ISAKSON, Georgia RUSH D. HOLT, New Jersey 

BOB GOODLATTE, Virginia HILDA L. SOLIS, California 

JUDY BIGGERT, Illinois SUSAN DAVIS, California 

TODD RUSSELL PLATTS, Pennsylvania BETTY McCOLLUM, Minnesota 

PATRICK J. TIBERI, Ohio VACANCY 

 RIC KELLER, Florida 

 TOM OSBORNE, Nebraska 

JOHN ABNEY CULBERSON, Texas 

JOE WILSON, South Carolina 

 Paula Nowakowski, Chief of Staff 

 John Lawrence, Minority Staff Director

 SUBCOMMITTEE ON 21st CENTURY COMPETITIVENESS 

 HOWARD P. “BUCK” McKEON, California, Chairman

JOHNNY ISAKSON, Georgia, Vice Chairman VACANCY 

JOHN BOEHNER, Ohio JOHN F. TIERNEY, Massachusetts 

MICHAEL N. CASTLE, Delaware RON KIND, Wisconsin 

SAM JOHNSON, Texas RUSH D. HOLT, New Jersey 

LINDSEY O. GRAHAM, South Carolina DAVID WU, Oregon 

MARK E. SOUDER, Indiana LYNN N. RIVERS, Michigan 

FRED UPTON, Michigan BETTY McCOLLUM, Minnesota 

VERNON J. EHLERS, Michigan ROBERT E. ANDREWS, New Jersey 

BOB GOODLATTE, Virginia RUBEN HINOJOSA, Texas 

TOM OSBORNE, Nebraska 
iii

TABLE OF CONTENTS 

TABLE OF CONTENTS................................................................................................................. i 

OPENING STATEMENT OF CHAIRMAN HOWARD P. “BUCK” MCKEON, 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE ON 

EDUCATION AND THE WORKFORCE, U.S. HOUSE OF REPRESENTATIVES, 

WASHINGTON, D.C..................................................................................................................... 3 

OPENING STATEMENT OF REPRESENTATIVE JOHN F. TIERNEY, SUBCOMMITTEE 

ON 21ST CENTURY COMPETITIVENESS, COMMITTEE ON EDUCATION AND THE 

WORKFORCE, U.S. HOUSE OF REPRESENTATIVES, WASHINGTON, D.C. ..................... 4 

OPENING STATEMENT OF REPRESENTATIVE THOMAS E. PETRI, SUBCOMMITTEE 

ON 21ST CENTURY COMPETITIVENESS, COMMITTEE ON EDUCATION AND THE 

WORKFORCE, U.S. HOUSE OF REPRESENTATIVES, WASHINGTON, D.C. ..................... 6 

STATEMENT OF DR. JUDITH S. EATON, PRESIDENT, COUNCIL FOR HIGHER 

EDUCATION ACCREDITATION, WASHINGTON, D.C. ......................................................... 9 

STATEMENT OF DR. CHARLES M. COOK, DIRECTOR, COMMISSION OF 

INSTITUTIONS OF HIGHER EDUCATION, NEW ENGLAND ASSOCIATION OF 

SCHOOLS AND COLLEGES, BEDFORD, MASSACHUSETTS ............................................ 11 

STATEMENT OF DR. LAURA PALMER NOONE, PRESIDENT, UNIVERSITY OF 

PHOENIX, PHOENIX, ARIZONA ............................................................................................. 13 

STATEMENT OF THE HONORABLE HANK BROWN, PRESIDENT AND CEO, DANIELS 

FUND, GREELEY, COLORADO, AND FORMER UNITED STATES SENATOR FROM THE 

STATE OF COLORADO............................................................................................................. 16

STATEMENT OF DR. LINWOOD H. ROSE, PRESIDENT, JAMES MADISON 

UNIVERSITY, HARRISONBURG, VIRGINIA......................................................................... 17 

APPENDIX A -- WRITTEN OPENING STATEMENT OF CHAIRMAN HOWARD P. 

“BUCK” MCKEON, SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, 

COMMITTEE ON EDUCATION AND THE WORKFORCE, U.S. HOUSE OF 

REPRESENTATIVES, WASHINGTON, D.C. ........................................................................... 33 

APPENDIX B -- WRITTEN OPENING STATEMENT OF REPRESENTATIVE JOHN F. 

TIERNEY, SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE 

ON EDUCATION AND THE WORKFORCE, U.S. HOUSE OF REPRESENTATIVES, 

WASHINGTON, D.C................................................................................................................... 37 
iv

APPENDIX C -- WRITTEN OPENING STATEMENT OF REPRESENTATIVE THOMAS E. 

PETRI, SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE ON 

EDUCATION AND THE WORKFORCE, U.S. HOUSE OF REPRESENTATIVES, 

WASHINGTON, D.C................................................................................................................... 41 

APPENDIX D -- WRITTEN STATEMENT OF DR. JUDITH S. EATON, PRESIDENT, 

COUNCIL FOR HIGHER EDUCATION ACCREDITATION, WASHINGTON, D.C. ........... 45 

APPENDIX E -- WRITTEN STATEMENT OF DR. CHARLES M. COOK, DIRECTOR, 

COMMISSION OF INSTITUTIONS OF HIGHER EDUCATION, NEW ENGLAND 

ASSOCIATION OF SCHOOLS AND COLLEGES, BEDFORD, MASSACHUSETTS........... 63 

APPENDIX F -- WRITTEN STATEMENT OF DR. LAURA PALMER NOONE, PRESIDENT, 

UNIVERSITY OF PHOENIX, PHOENIX, ARIZONA .............................................................. 73 

APPENDIX G -- WRITTEN STATEMENT OF THE HONORABLE HANK BROWN, 

PRESIDENT AND CEO, DANIELS FUND, GREELEY, COLORADO, AND FORMER 

UNITED STATES SENATOR FROM THE STATE OF COLORADO..................................... 89 

APPENDIX H -- WRITTEN STATEMENT OF LINWOOD H. ROSE, PRESIDENT, JAMES 

MADISON UNIVERSITY, HARRISONBURG, VIRGINIA..................................................... 95 

APPENDIX I -- RESPONSES TO QUESTIONS SUBMITTED FOR THE RECORD BY 

REPRESENTATIVE RUBEN HINOJOSA, SUBCOMMITTEE ON 21ST CENTURY 

COMPETITIVENESS, COMMITTEE ON EDUCATION AND THE WORKFORCE, U.S. 

HOUSE OF REPRESENTATIVES, WASHINGTON, D.C...................................................... 105 

TABLE OF INDEXES ............................................................................................................... 113
1

HEARING ON ASSURING QUALITY AND 

ACCOUNTABILITY IN POSTSECONDARY EDUCATION: 

ASSESSING THE ROLE OF ACCREDITATION 

___________________________________________

TUESDAY, OCTOBER 1, 2002 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, 

COMMITTEE ON EDUCATION AND THE WORKFORCE,

HOUSE OF REPRESENTATIVES, 

WASHINGTON, D.C.

 The subcommittee met, pursuant to call, at 2:30 p.m., in Room 2175, Rayburn House Office 

Building, Hon. Howard P. "Buck" McKeon [chairman of the subcommittee] presiding. 

 Present: Representatives McKeon, Johnson, Ehlers, Goodlatte, Osborne, Tierney, Wu, and 

Hinojosa.

 Also Present: Representative Petri. 

 Staff Present: George Conant, Professional Staff Member; Patrick Lyden, Professional 

Staff Member, Deborah L. Samantar, Committee Clerk/Intern Coordinator; Kathleen Smith, 

Professional Staff Member; Liz Wheel, Legislative Assistant; Brady Newby, Communications 

Specialist; James Kvaal, Minority Legislative Associate/Education; Joe Novotny, Minority Staff 

Assistant/Education; and Suzanne Palmer, Minority Legislative Assistant/Education. 

Chairman McKeon. A quorum being present, the Subcommittee on 21st Century 

Competitiveness will come to order. 

 I am sure most of you heard over the weekend that our good colleague, the ranking member 

of our subcommittee, Mrs. Mink from Hawaii, passed away. I want to send my condolences and 

my sympathy, to her family and to her constituents of Hawaii and all the people from Hawaii that 

she served for some years. 
2

 I especially will miss her because we have worked together for the last 2 years. You get a 

kind of a special relationship between the chairman and the ranking member, and we have spent 

time at breakfast getting to know each other personally as well as the issues on which we have 

worked together. I will miss her personally in addition to as a colleague and a great member of this 

body.

 I would like to ask Mr. Tierney if he has any comments to make, and then we will join in a 

moment of silence before we begin the hearing. 

Mr. Tierney. I thank you, Mr. Chairman, and I appreciate your words, as I know Patsy Mink's 

family and friends and the staff do also. 

 We are talking about honoring a woman who served with distinction as the Ranking 

Democrat on this subcommittee. I offer my condolences, along with the chairman's, to her family, 

her husband John and her daughter Wendy, especially; also to her staff, who really experienced a 

tremendous loss. Patsy was a great leader. At 74 years old, she had more energy than the staff and 

all of her colleagues together, and she really showed it and exhibited it every day. 

 From the time she was 4 years old, when she insisted by grabbing her older brother's hand 

and forcing him to take her to his first grade class, until the time when she became the first Asian 

American woman to practice law in Hawaii, from her first election to Congress as the first woman 

of color, she broke down barriers for herself first and then for others. 

 She left a legacy of millions of working families that she helped to lift out of poverty with 

education and job training programs ranging from the war on poverty to welfare reform, and left a 

generation of female student athletes for whom she drafted, passed and implemented Title IX, the 

30-year anniversary of which we just commemorated this past June. 

 Patsy provided vision, courage and leadership, spoke out on all the vital issues of the day 

inspiring us, her colleagues, with her fiery oratory on the House floor and her policy negotiations 

that combined her mastery of education and labor issues with her powerful persuasion tool of 

chocolate-covered macadamia nuts. The chairman understands her bribery methods. 

Mr. Chairman, I know my colleagues on the committee staff join me in mourning the loss 

of a valued friend and colleague whose distinguished service to the House and to this committee 

has made a difference in the lives of millions of Americans, and we will miss her dearly. 

Chairman McKeon. Thank you, Mr. Tierney. 

 Now if you would all please join me in a moment of silence for Mrs. Mink. 

 [Moment of silence.] 
3

OPENING STATEMENT OF CHAIRMAN HOWARD P. “BUCK” MCKEON, 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE 

ON EDUCATION AND THE WORKFORCE, U.S. HOUSE OF 

REPRESENTATIVES, WASHINGTON, D.C.

 Thank you. Good afternoon. I want to welcome all of you here today, especially our 

witnesses, and thank you for taking the time to be with us. 

 Next year, as you know, this committee will begin the focus of reauthorizing the Higher 

Education Act, where our main focus will center on examining Federal policy that provides access 

to a high quality and affordable college education. In an effort to begin that process, we are 

holding this and other hearings at the end of this Congress to begin reviewing topics that may be 

addressed during reauthorization. 

 Since my time on the committee, I have always believed that there is nothing more 

important than the education of our citizens, and it is the responsibility of this Congress to afford 

the opportunity for all Americans to get a quality education. While we cannot control which school 

a student chooses to attend, we can certainly work to provide some level of confidence that the 

institution they do attend will live up to its obligation to provide an education that adheres to some 

kind of standard. Most consumers look to accreditors to provide such confidence. 

 If the school and its programs are accredited, the assumption by most is that it provides a 

quality education. 

 The purpose of this hearing is to determine if that is accurate. Over the last few months 

there has been a good deal of conversation about quality education and holding institutions 

accountable for the education that they provide. As a member that is interested in exploring ways 

to open the doors of opportunity for all Americans through access to a quality postsecondary 

education, I believe that we should thoroughly examine the accreditation process. 

 As most know, while there are standards now in the Higher Education Act, there is also a 

provision that allows for expansion of standards as deemed appropriate by the accrediting agencies. 

In that vein, I am extremely concerned that accreditation agencies are imposing standards on 

institutions that have little or nothing to do with academic quality. It is my hope that through this 

hearing, as well as others held next year, we will address this concern and learn in great detail the 

answers to the following questions. 

 Does the fact that an institution gains accreditation mean that it is a quality institution? 

 Is there more accreditors can do to ensure that the education provided by a postsecondary 

education is in fact quality? 
4

 Should there be more independence within the accreditation process rather than continue 

what is now more of a peer review process? 

 Should Congress do more to require specific standards for accreditors and the areas they 

review? 

 I am eager to hear from all of you today so that we here on the committee can better 

understand the accrediting process, how regional and national accreditors interact, as well as their 

roles and responsibilities. We also need to hear what standards are imposed on institutions and 

how to make sure students and their families have a clearer understanding of what accreditation 

means to them as consumers. 

 Again, I thank you for being here today. 

Mr. Tierney.

WRITTEN OPENING STATEMENT OF CHAIRMAN HOWARD P. “BUCK” MCKEON, 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE ON 

EDUCATION AND THE WORKFORCE, U.S. HOUSE OF REPRESENTATIVES, 

WASHINGTON, D.C. – APPENDIX A 

OPENING STATEMENT OF REPRESENTATIVE JOHN F. TIERNEY, 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE 

ON EDUCATION AND THE WORKFORCE, U.S. HOUSE OF 

REPRESENTATIVES, WASHINGTON, D.C.

Mr. Tierney. Thank you, Mr. Chairman. Again, we thank all of the witnesses for being here 

today and giving their time and expertise. 

 Let me apologize up front for the fact that I will be bouncing in and out of here because I 

have another hearing going on upstairs. I will read your testimony; and my staff will be here, and I 

will be in and out trying to make sure that we learn all that we can learn. You are going to provide, 

valuable input and information to us as we address this whole idea of accreditation in the context of 

what we are asking colleges to do and the challenges that our universities are going to meet over 

the next period of years. 

 I want to recognize and acknowledge Dr. Charles Cook for coming to testify before the 

subcommittee today. He is Director of the Commission of Institutions of Higher Education in the 

New England Association of Schools and Colleges in Bedford, Massachusetts, which I am proud to 

say makes up a part of my district. 

 So, Dr. Cook, I want to especially acknowledge you. 

 Accreditation has played an important role, and it ensures, or should ensure us, that our 

postsecondary institutions are providing students with a good, positive education, as the chairman 
5

mentioned. 

 The Department of Education has oversight, as you know, over accreditation.

Nongovernmental, private education associations develop criteria and conduct peer evaluations of 

institutions to determine whether or not standards for accreditation are met. Although the 

Department publishes a list of nationally recognized accrediting agencies, there is considerable 

latitude in the accreditation process; and I am sure we are going to cover just what that latitude is 

and whether or not it ought to remain as is or be changed. 

 Accreditation also plays a significant role in financial aid, as a substantial financial aid 

system is limited to institutions that are accredited by agencies recognized by the Department of 

Education.

 As we begin to address the role of accreditation and higher education, much has changed 

since Congress last reauthorized the Higher Education Act in 1998. I think distance learning will 

no doubt be one issue that I, for one, would like to talk about. I think other members of this 

committee would. 

 We authorized a Web-based education commission in the 1998 reauthorization of the Act. I 

have some concerns about rushing to new conclusions without first getting the evaluation and the 

reports of that committee, or commission. I know that some disagree, as they supported H.R. 1992, 

the Internet Equity and Education Act, last fall. But I think we will have much to examine and 

discuss, both in that report and in your comments, regarding accreditation and distance learning this 

year and in the coming congress. 

 I also have some concerns about the lack of transferability of credits for our students who 

may begin courses at one college, then continue their education at a 4-year college. And I am 

interested in knowing how the curriculums of postsecondary institutions will keep pace with the 

changes in our culture and in our society. 

 So, overall, we need to carefully consider the accreditation process. It ultimately helps us 

shape the education and training that our students receive as they enter life and, certainly, the work 

force. But I never see that as education's primary goal. I think we have got a lot of other things to 

do with our students in terms of citizenship and our next level of innovators and scientists and other 

things that we need. 

 So I want to thank you for coming before the subcommittee today. I will look forward to 

your testimony and I am sure we will appreciate it. Thank you. 

WRITTEN OPENING STATEMENT OF REPRESENTATIVE JOHN F. TIERNEY, 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE ON 

EDUCATION AND THE WORKFORCE, U.S. HOUSE OF REPRESENTATIVES, 

WASHINGTON, D.C. – APPENDIX B 
6

Chairman McKeon. The senior member of our committee, Mr. Petri from Wisconsin, has been 

involved in this issue for some time, and I would like to turn now to him for an opening statement. 

OPENING STATEMENT OF REPRESENTATIVE THOMAS E. PETRI, 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE 

ON EDUCATION AND THE WORKFORCE, U.S. HOUSE OF 

REPRESENTATIVES, WASHINGTON, D.C.

Mr. Petri. Thank you very much, Mr. Chairman. I first of all want to commend you for having 

this hearing and the indication that there may be further hearings as you prepare for reauthorization 

in the next Congress of the Higher Education Act. I have a brief opening statement on the subject, 

which I think is quite important. 

 Accreditation is almost never mentioned in today's discussions over the escalating costs of 

higher education, declining academic standards and accountability. A closer examination of the 

accreditation system reveals that it does little to address these problems and, in some ways, 

contributes to them. 

 The costs of higher education continue to increase faster than inflation and the Federal 

Government's contribution to student aid increases in tandem. We rely on the accreditation system 

to ensure that a school provides a quality education and is therefore eligible for these Federal 

dollars. But what does accreditation really say about a school? 

 Unfortunately, accreditation, these days, has little to do with academic rigor or educational 

outcomes. Rather, it serves only to show that a school has the right set of inputs. For example, an 

accrediting agency may place an emphasis on schools having a certain number of professors with 

terminal degrees in their field. Yet the question is never asked whether students in classes taught 

by these professors are actually learning anything. 

 I would like to point out that this focus on inputs over outcome is exactly the same criticism 

shaping reforms being discussed for Federal special education policies. Congress has imposed on 

States mandates that we assume will provide the intended educational outcome, but then we never 

ask if those outcomes are being achieved. While this focus on inputs fails to guarantee academic 

quality, it also unnecessarily drives up the cost of higher education. 

 As part of the accreditation process, schools must pay dues to their accrediting association 

and conduct extensive self-studies that require a great deal of time and money and produce 

information of questionable value. Furthermore, accreditors may make recommendations that 

pressure schools to reallocate scarce resources in a manner that may not suit the overall needs of 

the school or may not be the most effective use of those resources. Or, even worse, an accreditor 

may pressure a school to pursue policies at odds with its individual mission. 

 The accreditation process has strayed from the purpose Congress originally intended, but it 

can be changed to provide students and parents with real information about the quality of education 

a particular school provides. Yesterday, I introduced H.R. 5501, the Higher Education Accrediting 
7

Agency Responsibility Act. This legislation eliminates the requirement that schools be accredited 

in order to receive federal student aid funds. It will help to open the accreditation process to 

competition, which will encourage accreditors to evaluate results rather than inputs and provide 

prospective students and parents with meaningful information about a school. 

 Under a voluntary system, colleges and universities that seek accreditation will demand 

from an accreditor quality advice and recommendations that improve the education offered to their 

students. I am sure that this hearing, and others, will help provide us with a better understanding of 

the accreditation system and how we can bring about the needed improvements. 

 Thank you very much. 

Chairman McKeon. I ask unanimous consent for the hearing record to remain open 14 days to 

allow members statements and other extraneous material referenced during the hearing to be 

submitted in the official hearing record. Without objection, so ordered. 

WRITTEN OPENING STATEMENT OF REPRESENTATIVE THOMAS E. PETRI, 

SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, COMMITTEE ON 

EDUCATION AND THE WORKFORCE, U.S. HOUSE OF REPRESENTATIVES, 

WASHINGTON, D.C. – APPENDIX C 

Chairman McKeon. Our first witness this morning will be Dr. Judith Eaton. Dr. Eaton is 

President of the Council for Higher Education Accreditation, where she has served since 1997.

Previously, she was the Chancellor of the Minnesota State colleges and universities. In addition, 

Dr. Eaton has served as President of the Council for Aid to Education, the Community College of 

Philadelphia, and the Community College of Southern Nevada. 

Mr. Tierney introduced Dr. Cook. 

 Then we will have Dr. Laura Palmer Noone. Dr. Palmer Noone is the Chief Administrative 

Officer and President of the University of Phoenix, the nation's largest private university. She has 

also served the University of Phoenix as Provost and Senior Vice President for Academic Affairs. 

Dr. Palmer Noone is a frequent guest faculty lecturer at the Harvard University Graduate 

School of Education's Institution for Education Management and for the Management of Lifelong 

Education Program. In addition, she serves as the Vice Chair of the U.S. Department of 

Education's National Advisory Committee on Institutional Quality and Integrity. 

 I would like to ask Mr. Petri if he would introduce the Honorable Hank Brown. 

Mr. Petri. It is a delight for me to introduce a very respected former colleague who has proven 

that there is life after Congress, both the House and the Senate, who has had a distinguished year 

both as a Representative of the Sixth District in Colorado, but and also 4 years as a university 

president and then earlier this year became President of the Daniels Fund, which is a Colorado 

philanthropy organization that focuses on helping promising high school students obtain a college 

education. So he is in a position to advise us both from a legislative perspective and from 
8

administering a university, discovering the wonders and challenges of that, and how we can 

improve the situation. 

Chairman McKeon. Thank you. 

 I yield now to the gentleman from Virginia, Mr. Goodlatte, to introduce our last witness. 

Mr. Goodlatte. Thank you, Mr. Chairman. I too want to welcome my friend, Senator Brown. But 

I am particularly honored that we have with us today the president of the largest university in the 

Sixth Congressional District of Virginia and, Mr. Chairman, I would note, a university that you 

visited where you previously met President Linwood Rose. 

Dr. Rose has a long, distinguished career at the university. He is actually only the fifth 

president of James Madison University in its 94-year history. He has only covered 4 of those 94 

years so far, so he has a long, long way to go as president. He also previously served in the 

administration of the university for 23 years before that. 

 James Madison University has been repeatedly ranked as the top-rated Masters-level public 

university in the South in polls conducted by U.S. News and World Report. JMU, for the 8th year 

in a row, ranked number one in the South among public universities, and annually ranks as one of 

the nation's best state universities in terms of value. 

 I also want to note, Mr. Chairman, that on the same visit that you made last year to James 

Madison University, Congresswoman Mink joined us as well. And knowing when we hold field 

hearings what a sacrifice it is for Members to visit another congressional district, other than their 

own, during time away from Capitol Hill, I especially appreciated your scheduling that hearing. 

But I also especially appreciated Congresswoman Mink giving up a day of her time to visit 

Harrisonburg and Roanoke and some of the institutions in my district. 

 This is a topic in which I have a great deal of interest. The chairman also knows of his help 

to me for another institution in my congressional district, which has experienced some problems 

with the current accrediting system in the country; and so I will, with great interest, look forward to 

hearing the testimony of all the witnesses, but most especially my friend, Dr. Rose. 

 Thank you, Mr. Chairman. 

Chairman McKeon. Thank you, Mr. Goodlatte. 

 We will now hear from the witnesses, beginning with Dr. Eaton. As you can see there are 

lights in front of you. When you start, a green light will come on and then that means you have 4 

minutes; and then the yellow light comes on and that means you have a minute; and then when the 

red light comes on, your time is up. Your full testimony will be inserted in the record, so if you 

want to paraphrase or shorten it, you have the 5 minutes; and then we will have time for the 

members to ask questions under the same guidelines. 
9

Dr. Eaton.

STATEMENT OF DR. JUDITH S. EATON, PRESIDENT, COUNCIL FOR 

HIGHER EDUCATION ACCREDITATION, WASHINGTON, D.C. 

Dr. Eaton. Thank you, Chairman McKeon. It is a pleasure to be here today. Before I begin my 

comments, please accept on behalf of the Board of Directors of the Council for Higher Education 

Accreditation our condolences on the death of Congresswoman Mink. I know I speak for all my 

colleagues in higher education in the room in saying she will be sorely missed and contributed 

greatly to our work over the years. 

 I am Judith Eaton, President of the Council for Higher Education Accreditation. CHEA, as 

it is affectionately called, is a national coordinating body for accreditation, both institutional and 

programmatic accreditation, here in the United States. We count some 3,000 degree-granting 

colleges and universities among our members, as well as some 60 accrediting organizations. 

 I am here today to provide a brief overview of accreditation, to speak to several of the major 

challenges of accreditation, and to indicate some of the accrediting communities' interests as we 

move toward the reauthorization of the Higher Education Act. 

 Accreditation is the process of external quality review of higher education. Its purpose is to 

assure and to improve that quality. Accreditation review is focused on institutions and programs. 

The institutions may be degree or nondegree, nonprofit or for profit. The programs range from law 

to medicine to business to social work to the arts to psychology. 

 Accreditation is more than 100 years old, and it is indeed an extensive enterprise. There are 

some 80 accrediting organizations in the United States, and as of last year, they accredited more 

than 63 institutions and 17,500 programs. That is done, by the way, with an accreditation staff of 

paid professional and support individuals, full- and part-time, of just about 500 people along with 

several thousand volunteers in any given year that review various institutions and programs. 

 The accreditation process has these key elements: 

 The application of standards of quality developed by the accrediting organizations; 

 Self-evaluation by the institution or program; and then 

 Peer review of those institutions and programs. Accreditation results in a judgment about 

accredited status. 

 Accreditation has enjoyed a 50-year relationship with the federal government. Institutions 

and programs must have accredited status to be eligible for federal student aid and other federal 

funds; and government has a long history of relying on accreditation for information about the 

quality of these institutions and programs. 
10

 Accrediting organizations themselves are reviewed for quality and effectiveness both by the 

federal government through the United States Department of Education and through our 

organization. We have recognition standards, and we review various accrediting organizations 

based on those standards to test the quality of their operation. 

 Accreditation is the primary mechanism used throughout higher education to assure and 

improve quality, and while the details of accreditation practice may not be widely known, students, 

the public and policy-makers do know that being accredited is a powerful signal about the quality 

of a higher education institution and program. 

 We believe accreditation has played a major role in establishing the United States higher 

education, in the eyes of many, as the best higher education system in the world. 

 If I may, Mr. Chairman, you mentioned earlier an assumption that accreditation provides 

quality. Is that accurate? We would say that particular assumption certainly is warranted. 

 Moving on to some of the major challenges facing accreditation at this time, I will mention 

three. First, there is the challenge of accountability and providing more information about student 

learning outcomes. Increasingly, accreditation standards are being revised, and have been revised 

by various accrediting organizations to assure that institutions and programs provide this evidence 

of student learning. 

 Increasingly, accrediting organizations are taking those who are indeed skilled at collecting 

and evaluating evidence of student learning, and consider student learning as part of the 

information needed to make judgments about accredited status, and putting them on their 

accrediting teams which go out to visit institutions and programs. 

 CHEA, I might point out, has been instrumental in that capacity building and accreditation 

in the last several years. We have, for example, designed and tested an accreditation review solely 

for competency-based institutions. We tested this at Western Governors University. We last year 

published a key decision-making model for incorporating outcomes in accreditation review; that is, 

what do accrediting organizations have to do better to more fully address student learning outcomes 

in their reviews? 

 We have just concluded a series of workshops, working with accrediting organizations in 

this capacity building. We plan to continue our efforts into next year, working directly with 

accrediting commissions addressing such topics as the following: what good practices are there that 

can be used by various accrediting organizations as this relates to student learning outcomes? 

 We are also providing additional public information about graduation rates, retention, 

student mobility; and we have certainly taken on the issue of assuring quality and distance learning 

through revision or creation of new accreditation standards for this purpose. 

 Three things quickly as we prepare for reauthorization: 
11

 We want to sustain our valuable partnership with the federal government. 

 Further, we want to make sure that this partnership continues the useful division of labor 

between our government and accreditors, accreditors having primary responsibility for assuring 

academic quality, government having primary responsibility for assuring that Federal funds are 

spent wisely. 

 We also look forward, Mr. Chairman to continuing the very important work you and 

Congresswoman Mink initiated with reducing burden in higher education through reducing 

regulation, the FED UP initiative, and we hope that this features prominently in the higher 

education reauthorization. 

 I thank you for your attention, and I would be happy to respond to any questions. 

WRITTEN STATEMENT OF DR. JUDITH S. EATON, PRESIDENT, COUNCIL FOR HIGHER 

EDUCATION ACCREDITATION, WASHINGTON, D.C. – APPENDIX D 

Chairman McKeon. Thank you. 

Dr. Cook.

STATEMENT OF DR. CHARLES M. COOK, DIRECTOR, COMMISSION OF 

INSTITUTIONS OF HIGHER EDUCATION, NEW ENGLAND 

ASSOCIATION OF SCHOOLS AND COLLEGES, BEDFORD, 

MASSACHUSETTS 

Dr. Cook. Thank you, Mr. Chairman. 

 I am Charles Cook, Director of the Commission of Institutions of Higher Education of the 

New England Association of Schools and Colleges, one of eight regional accrediting entities in the 

United States that accredit colleges and universities. I appreciate the opportunity to testify before 

you today describing the nature and work, as well as the challenges facing regional accreditation.

 Accreditation of institutions of higher learning is an American invention. It was created 

nearly a century ago by the colleges and the universities themselves as a nongovernmental response 

to the need for a mechanism to identify those institutions of higher learning worthy of attendance. 

 Since its inception, it has been a remarkably successful enterprise in providing meaningful 

quality assurance upon which our citizenry, government at every level and industry have come to 

depend. Indeed, accreditation is now an essential for any legitimate institution of higher learning. 

 As noted, there are eight regional accrediting commissions. Each accredits those degreegranting institutions within a specific multi-state geographical area; and together they accredit 
12

approximately 3,000 colleges and universities. 

 Regional accreditation has become the most sought after medallion, recognizing 

institutional quality in American higher education. By definition, accreditation is a status granted 

to an educational institution found to meet or exceed stated criteria for educational quality. 

Regional accreditation applies to the institution as a whole, and while it does not guarantee the 

quality of individual programs or graduates, it does provide reasonable assurance as to the context 

and quality of the education offered. 

 If regional accreditation is about quality assurance, it is also about quality improvement. 

That is, accreditation processes are designed to identify institutional weaknesses and otherwise 

facilitate and to encourage positive institutional change. 

 Accreditation standards among the eight regional commissions vary in detail. However, in 

terms of the values they express, their general outline and objectives are quite similar. Because the 

object of attention is the institution as a whole, standards address not only educational 

programming, but also those resources that directly support it, and such institutional characteristics 

as student services, fiscal well-being, and administrative capacity and integrity. 

 Regardless of the details found in the standards of each commission, the institution found to 

meet these standards could be said to have appropriate purposes, have the resources to accomplish 

those purposes, be able to demonstrate that it is accomplishing its purposes, and give reason to 

demonstrate that it will continue to accomplish its purposes into the foreseeable future. 

 If the regionals' criteria are similar, so too are the processes by which the standards are 

applied. Every institution undergoes a periodic evaluation, normally every 10 years, with 

opportunities to monitor institutional developments in the interim. 

 The evaluation process begins with institutional self-study; that is, the college or university, 

through a broadly participatory effort, is asked to assess itself against accreditation standards, 

identifying what it does well, to determine the areas in which improvements are needed and to 

develop plans to address those needed improvements. 

 With the results of this effort in hand, a team of peers, administrators and faculty from other 

accredited institutions, undertake an evaluation of the institution, again applying accreditation 

standards and writing a report of their findings. This document is considered by the accreditation 

commission itself, which makes the determination regarding accreditation and also, in doing so, 

typically identifies areas needing the institution's attention. 

 It is worthy to note that the work of regional accreditation is carried out primarily by 

volunteers. The commissions themselves have only small paid staffs. Across the United States 

every year, literally thousands are involved in the work of accreditation, again on a voluntary basis. 

 American higher education has been and continues to be remarkably dynamic. Innovative 

programming, off campus and evening and weekend classes and, more recently, electronically 

mediated instruction are examples of this. These developments have tested conventional 
13

assumptions, raised fresh questions about the essential nature and content of the educational 

experience and the resources required to support it. 

 Regional commissions have responded by maintaining higher standards and also 

recognizing that the education can be provided in a variety of ways. Over the years, too, the focus 

of attention in the regional commissions has shifted the content of its standards increasingly to 

educational outcomes or learning outcomes. 

 We believe that regional accreditation has the support of its members and the public at 

large, but as a human institution, it is not perfect. Sometimes it finds itself behind the curve in 

terms of the developments at institutions. 

 Another challenge we have is to insert a meaningful emphasis on student learning outcomes 

into our criteria. Here we believe we are somewhat ahead of our colleges and universities. 

 Let me sum up by saying that a higher education is the envy of the world for good reason.

We wouldn't lay claim to the notion that accreditation is the cause of this. Nonetheless, it is one of 

the important conditions that has produced that result. It is for that reason that many countries 

throughout the world seek to learn from American accreditation experience and adapt it to its 

circumstance. 

 We look forward to continuing to serve our member institutions and the public by providing 

meaningful quality assurance. Again, I appreciate the opportunity to testify before you today. 

WRITTEN STATEMENT OF DR. CHARLES M. COOK, DIRECTOR, COMMISSION OF 

INSTITUTIONS OF HIGHER EDUCATION, NEW ENGLAND ASSOCIATION OF SCHOOLS 

AND COLLEGES, BEDFORD, MASSACHUSETTS – APPENDIX E 

Chairman McKeon. Thank you. 

Dr. Palmer Noone.

STATEMENT OF DR. LAURA PALMER NOONE, PRESIDENT, 

UNIVERSITY OF PHOENIX, PHOENIX, ARIZONA 

Dr. Palmer Noone. Good afternoon, Chairman McKeon and distinguished members of the House 

subcommittee. It is my honor to have been invited today to testify. 

 I am here as the President of the University of Phoenix, the largest private university in the 

United States. The university is a regionally accredited institution accredited by the North Central 

Association, one of the regional accrediting bodies of the U.S. However, because of our unique, 

geographically distributed system, we operate within the borders of all six of those geographic 

territories. 

 The system of regional accreditation has served the University of Phoenix well over its 26 

years. However, we believe the regional associations are demonstrating they are equipped to judge 
14

the academic quality of institutions. We do not, as an institution, support further overlap of the 

Department of Education's role in the traditional quality assurance function of the accreditation 

process.

 The traditional triad of the accrediting body’s responsibility for quality assurance, the 

Department of Education's oversight of compliance and the States' role in consumer protection 

continues to serve the public well. As we look forward to the future and meeting the growing and 

diverse educational needs of the country, it is imperative that this triad stays appropriately 

balanced, while ensuring quality. 

 And strength of educational programs remains key. Unnecessary and burdensome overlap 

in the roles and responsibilities threatens to weigh down this process and prevent institutions of 

higher learning from quickly responding to and meeting the needs of the Nation's workforce. 

 The current system of overlap has already created many challenges for institutions such as 

mine. The geographic expansion of an institution has created such a challenge for the regional 

system because many institutions now operate in multiple regions. The Council of Regional 

Accrediting Associations, CRAC, created an interregional protocol for dealing with these 

challenges through fostering joint cooperative accreditation visits. 

 The University of Phoenix was among the first institutions to participate in this new 

protocol, and for the most part, it has worked well. But the time and the expense of the process 

have been somewhat onerous. 

 It is obvious that we, as an institution, have taxed the abilities of the regional bodies to 

cooperate. Each regional accreditor evaluates according to the same criteria, but judges the 

compliance with different standards. When an institution such as mine goes through an 

accreditation visit, it is often faced with meeting the standards of six different regions, as well as 

those of the State in which it operates. 

 Compliance with these differences is not a question of simply meeting the highest level of 

standards, since the standards are sometimes inconsistent and, at worst, disconsonant. These 

differences result in institutions' and accrediting bodies' refusal to acknowledge accreditation by 

another region as equivalent, thus reducing the portability of degrees. Students then have fewer 

options for transfer and often must repeat courses, which may result in additional student debt load. 

 From a public policy perspective, it is clearly preferable to have baseline recognition count 

for transferability of degrees and credits, and that should be ensured with accreditation by a 

recognized body. 

 Institutions such as the University of Phoenix, who operate across state lines, also have the 

ability to help the nation in critical workforce shortages such as in the areas of nursing and 

teaching. Yet we are faced with another problem. As we jokingly refer to it, the states each think 

they invented higher education. As a result, each state feels the need to enforce a duplicative level 

of oversight, which sometimes leads to a burdensome level of oversight that rises to the level of 

accreditation review. We recognize that this may be a cost of doing business, but it does create a 
15

structural impediment to any real national initiatives that might allow us to deal with critical 

shortages in any effective way. 

 I would suggest that this committee consider the following issues: 

 Accreditation as a method of self-regulation should continue, but with an emphasis on 

standardization amongst accrediting bodies to allow for portability of degrees and workforce 

preparedness.

 State regulations should then, in turn, focus on consumer protection and not be viewed as a 

substitution for accreditation nor another level of accreditation review. 

 This afternoon, I would also like to briefly mention the work of the National Advisory 

Committee on Institutional Quality and Integrity, referred to as NACIQI. Last October, I was 

pleased to be asked to serve as a member and vice chair of this committee, which plays an 

important role in the accreditation arena. 

 NACIQI was created by Congress in 1992 and held its first meeting in 1994. The 

committee is comprised of 15 members who are knowledgeable concerning higher education and 

who represent all sectors and types of postsecondary institutions. The primary function of the 

committee is to advise the Secretary on accreditation, as well as institutional eligibility and 

certification issues; and to date, the committee has focused most of its attention on accreditation 

matters. 

 The Secretary's criteria pertain to the agency's accreditation policies and procedures and, 

most importantly, the standards that the agency expects its institutions and programs to meet in 

order to gain or retain accreditation status. 

 The agency is required to have standards that address certain areas. For instance, the 

agency must cover curricula, standards that deal with student achievement, standards that deal with 

students' support services, and so forth. After reviewing all written documentation and considering 

oral argument, NACIQI votes on whether to recommend recognition and forwards its 

recommendation to the Secretary of Education. 

 It has been my experience that the members of NACIQI have been diligent in exercising 

their responsibility to the Secretary, to the education community, to the taxpayers, and to the 

students, who are the consumers that deserve quality education. I have submitted additional 

information regarding the Department of Education and NACIQI into the record, and I remain here 

for you to ask any questions you may have about my testimony. 

 Thank you very much. 

WRITTEN STATEMENT OF DR. LAURA PALMER NOONE, PRESIDENT, UNIVERSITY OF 

PHOENIX, PHOENIX, ARIZONA – APPENDIX F 
16

Chairman McKeon. The Honorable Senator Brown. 

STATEMENT OF THE HONORABLE HANK BROWN, PRESIDENT AND 

CEO, DANIELS FUND, GREELEY, COLORADO, AND FORMER UNITED 

STATES SENATOR FROM THE STATE OF COLORADO 

Senator Brown. Thank you Mr. Chairman. Let me express my appreciation for an opportunity to 

share some thoughts with you today and commend the committee for this hearing. The 

subcommittee's willingness to take testimony and to considering the question can be a great help as 

you view reauthorization in the coming year. 

 I want to commend for your study and your reading a report just issued by the American 

Council of Trustees and Alumni. It is entitled "Can College Accreditation Live Up to Its Promise?" 

I think it contains an excellent overview of the question, and has some excellent suggestions that I 

believe you will find worth reviewing and looking at. 

Mr. Chairman, I want to make it clear that I am here to testify as to my own views and not 

necessarily to represent either the organization that I work for now, which is the foundation, or the 

university that I worked for in the past or other entities, who should not be blamed for my views 

that are a bit different from some of the other members of the panel. Simply let me suggest to you 

what I believe is a reality of the past two or three decades in American higher education. 

 There has been a dramatic and, I believe, a scandalous grade inflation that has taken place 

countrywide. You simply cannot look at higher education in this country and be comfortable with 

what has happened with regard to grade inflation. 

 The reality is that grade inflation has hit all of our institutions, or almost all of our 

institutions, from the best to one to the worst. The fact is, this has not been a factor, nor has it been 

detected, nor has it been, I think, checked by our current system of accreditation. It has gone 

unchecked, and it threatens the very quality of the institutions that we have. 

 Secondly, I don't believe you can look at our system of higher education and the institutions 

therein and not be shocked by the abandonment of strong core curriculum requirements across the 

board. Almost without exception universities have moved away from a strong, vibrant, healthy 

core curriculum requirement. 

 Are there exceptions? Yes, there are. But there are fewer and fewer of them. So I take a 

different view with regard to quality assurance, and it is at least my view that the current system of 

accreditation does not assure quality and, thus, does not meet the mandates set out in the 1952 act. 

 There is an organization that has, at least in my university, asked important questions in the 

last few years. They ask about curriculum. They ask about retention. They ask about grade 

inflation and a number of other quality indicators that were not asked about in the accreditation 

system. It is the State itself that helps fund the university, and also has a direct interest in its 

quality; and they ask tough questions. My hope is that the committee would be willing to consider 
17

making it clear that it is possible for the States that wish to, to set up their own accrediting system. 

 You would not have to eliminate the current accreditation organization that now exists, but 

I believe the States can provide a positive alternative, a competitive accreditation system that will 

look at real quality and ask tough questions and help ensure, I think, a stronger system of 

accreditation. 

Mr. Chairman, I look forward to responding to any questions that the committee might 

have. Thank you. 

WRITTEN STATEMENT OF THE HONORABLE HANK BROWN, PRESIDENT AND CEO, 

DANIELS FUND, GREELEY, COLORADO, AND A FORMER SENATOR FROM THE STATE 

OF COLORADO – APPENDIX G 

Chairman McKeon. Thank you. 

Dr. Rose.

STATEMENT OF DR. LINWOOD H. ROSE, PRESIDENT, JAMES 

MADISON UNIVERSITY, HARRISONBURG, VIRGINIA 

Dr. Rose. Thank you, Mr. Chairman, members of the subcommittee. It is a pleasure to be with 

you today. 

 As has been indicated, I serve as President of James Madison University in Harrisonburg, 

Virginia. James Madison is a selective, public, comprehensive university of 15,400 students. The 

institution is generally regarded as a leader among colleges and universities in the assessment of 

learning and skill development. I appreciate the opportunity to offer a few remarks to the 

committee on the topic of institutional accreditation. 

 James Madison University is accredited by the Southern Association of Colleges and 

Schools' Commission on Colleges. The Commission on Colleges of the Southern Association of 

Colleges and Schools is the recognized regional accrediting body in the 11 U.S. southern States and 

in Latin America for associate, baccalaureate, master's and doctoral degrees. The Commission on 

Colleges is the representative body of the College Delegate Assembly and is charged with carrying 

out the accreditation process. 

 Having been at JMU for 27 years, I have participated in and observed the regional 

accreditation process firsthand. As a member of the Executive Council of the Commission, I have 

witnessed the transmission of the accrediting body's expectations from one of establishing minimal 

thresholds for performance to the promotion of campus culture for institutional effectiveness and 

accountability. I have seen this move from the measurement of inputs as surrogates for quality to a 

focused effort on the evaluation of student learning and progress. 
18

 Although the procedure will change in January 2004, each college and university applying 

for accreditation or renewal of accreditation is currently required to conduct a comprehensive study 

of its purpose, programs and services. On each campus, faculty administrators, staffs, students, 

trustees, and others serve on committees that study all aspects of the institution, report their 

findings and offer advice on improvement. This process results in a document evaluating the 

institution's effectiveness in reaching its stated goals and its compliance with the criteria. 

 At the culmination of the self-study, the Commission on Colleges sends a visiting 

committee of professional peers to the campus to assess the educational strengths and weaknesses 

of the institution. The written report of the visiting committee helps the institution improve its 

programs and also provides the basis on which commissions--excuse me, on which the commission 

decides to grant, continue, reaffirm or withdraw accreditation. 

 During the typical 4-day visit, committee members examine data and conduct interviews in 

order to evaluate the quality and the accuracy of the self-study and ascertain whether the institution 

is in compliance with the criteria. The committee offers written advice to the institution, develops 

a consensus on its findings, and completes a draft report. Finally, the committee presents an oral 

summary and an exit report to the chief executive officer and invited institutional officials on the 

last day of the visit. 

 The departure of the committee from campus does not mark the end of the accreditation 

process. The visiting committee report and the response of the institution on the findings of the 

economy are reviewed by the Committee on Criteria and Reports, a standing committee of the 

Commission. The Committee on Criteria and Reports recommends action on accreditation to the 

Executive Council of the Commission. The Executive Council, in turn, recommends action to the 

Commission on Colleges, which makes the final decision. These decisions are announced to the 

College Delegate Assembly during its annual business session. 

 In a typical cycle, reaffirmation of accreditation occurs every 10 years. James Madison 

University just last year completed our self-study, and we hosted a visiting team of peer 

professionals in April. We have responded to the visiting team's recommendations and await 

action by the Commission on Colleges at its December meeting. 

 Like James Madison, most institutions will correct any deficiencies identified by the peer 

review process. If an institution fails to correct deficiencies, it may be placed on sanction or may 

lose its accreditation depending on the seriousness or duration of the deficiencies. 

 Earlier, I referred to a transition in accreditation philosophy and methodology. The 

membership concluded that the standards and practices employed by the COC in accreditation 

needed review and modification. Following a comprehensive review and drafting process, led by a 

13-member steering committee, the total membership of the Commission on Colleges adopted new 

principles of accreditation foundations for quality enhancement in December of 2001. 

 The accreditation review project had five goals: 
19

 First, develop valid, relevant, clear, and concise standards that concentrate on best practices 

in higher education and recognize the Commission's diverse membership; 

 Two, streamline the internal review process; create better value for the institution and make 

it more cost effective; 

 Three, enhance the effectiveness, efficiency, and consistency of the external review process;

 Four, increase attention to student learning outcomes and institutional improvement; and 

finally,

 Five, ensure that standards and review processes foster a strong culture of institutional 

integrity, are appropriate for the changing higher education environment, and benefit the institution 

and the public. 

 The new process is reliant upon two key principles: institutional integrity and commitment 

to quality enhancement. It is divided into three sections: core requirements, comprehensive 

standards incorporating mission, governance and effectiveness, programs and resources, and 

federal mandates not included as part of the comprehensive standards. 

 The institutional self-study is replaced in this new process by an enhanced institutional 

profile submitted by the CRC, by compliance certification and by the institution's Quality 

Enhancement Plan. These documents will be reviewed by the off-site peer review committee and 

on-site peer review committee and, ultimately, by the Commission. 

 It is hoped that the new process will be; 

 First, less prescriptive; 

 Second, allow for greater institutional flexibility; 

 Third, focus institutional resources and manpower on issues of greatest concern to the 

institution;

 Fourth, be more cost effective; and 

 Fifth, assume an institutional level of maturity. 

 Eight institutions have piloted the new review procedures in their accreditation reviews over 

the last 2 years. The new standards and review processes modified in accord with the lessons 

learned from the pilots will become fully effective in January 2004. Regional training sessions are 

now under way for institutional leaders to learn more about the application of the principles. 

 While the methodology and focus of peer review may change over time, the primary 

purpose of accreditation remains to enhance educational quality throughout the region by 

improving the effectiveness of institutions and ensuring to the public that institutions meet 
20

standards established by the higher education community. 

Mr. Chairman, I appreciate the time today. Thank you very much. 

WRITTEN STATEMENT OF DR. LINWOOD H. ROSE, PRESIDENT, JAMES MADISON 

UNIVERSITY, HARRISONBURG, VIRGINIA – APPENDIX H 

Chairman McKeon. Thank you.

Well, this is a great panel that we have here. I wish we could spend hours just kind of in a 

little roundtable, learning from each of you. I am going to use my time to ask a few questions here. 

Dr. Eaton, there is some concern that schools accredited by regional accreditors refuse to 

accept the transfer of credits from schools that offer similar courses, but are nationally accredited. 

Is this a problem? And what can we do to ease the transfer of credit? 

Dr. Eaton. Thank you, Mr. Chairman. 

 We do have some instances where students will experience difficulty transferring credits 

from nationally accredited institutions to regionally accredited institutions. We have limited 

evidence of this. Its happening once is undesirable; I am aware of that. CHEA has acknowledged 

that we need to do work in this area. 

 We have developed and can make available to you a policy statement on transfer of credit 

that we ask our accrediting organizations to follow. It is several pages long, but the fundamental 

point in that transfer policy statement is that while transfer of credit decision-making should be 

done at the institutional level, it is an academic decision about curriculum, about standards; that 

nonetheless, when making this decision and considering these credits, institutions should not rely 

only on accredited status. They should look at more than accredited status, rather than simply 

reject from consideration credits that students are attempting to transfer, because of the accredited 

status of the sending institutions. 

 We have worked with the 19 institutional accreditors, regional and national, in the United 

States, whether they were part of CHEA or not, in developing this and in developing a follow-up 

document, a transfer framework where we attempted to provide some concrete suggestions on what 

institutions can do as they consider and then make decisions about transfer of credit. Given our 

strong belief that this decision-making must remain at an institutional level, we think this kind of 

policy framework, and the types of suggestions that we have in the framework will be helpful to 

these institutions and will, frankly, remind them about the significant responsibility associated with 

transfer of credit. 

Chairman McKeon. Thank you. 
21

Dr. Cook, how have you and other accreditors addressed student-learning outcomes? What 

assessments do you review to evaluate if a student has learned? 

Dr. Cook. I have honestly said that this has been one of our great challenges. 

 There has certainly been an emphasis, on student learning outcomes in the accreditation 

process for at least 15 years. Within our criteria, we ask institutions to develop appropriate 

mechanisms to assess the results of the learning process, because our institutions vary a great deal 

in terms of mission, and of types of programs. We don't have a recipe book for them. 

 But we have worked closely with institutions to help them in this area. We, along with 

several of the other regional commissions, have enjoyed grant support to facilitate this. Honestly 

said, this is an area of continuing effort and concern. I anticipate that we will be working on this 

for some time. 

 Institutions, particularly faculty, often find this a difficult area. Those on the outside may 

see it somewhat easier than do faculty. 

 Certainly there are specific examples. For example, a community college in New England 

spends a lot of time assessing their general education outcomes. Can their graduates read and write 

at a collegiate level? Do they have the kinds of skills that might be provided in a given vocational 

program? For liberal arts colleges, the challenges are greater because the learning outcomes, 

including creating good citizens and good thinkers, tend to be more elusive. 

Chairman McKeon. You have probably all participated at one level or another in the 

accreditation process. When accreditors come to the school, do they spend any time in the 

classroom? Do they look at anything that the instructors are doing? Do they do any interviewing 

of students? Do they do any interviewing of employers that employ students when they leave? 

 Anybody. 

Dr. Palmer Noone. It has been my experience that the accreditors do sit in the classroom and 

evaluate what the faculty is doing in the classroom, and also speak with students and faculty 

regarding their experiences. 

 It has not been my experience that they have spent any time with employer surveys. 

However, we have always provided that information to them, so maybe they have simply accepted 

that as documentary evidence. 

Dr. Eaton. Mr. Chairman, not recently, but I have been a consultant, evaluator, and a team 

member in three different regions in regional accreditation long before I was ever in this position.

We did all of the above, including having meetings with advisory committees of employers, groups 

that were advising specific fields, for example, business or computer technology. We did look at 

curriculum, we did meet with faculty, we did meet with students, and we did meet with employers 

and representatives of specific employers. 
22

Chairman McKeon. Is that standard? Well, my time is up. But you talked about a 4-day visit. Is 

that all done within that 4-day period? 

Dr. Rose. Yes. It is conducted within the 4-day period. I have not experienced external visitors to 

the campus actually going to classes that are currently active. However, it is a very common 

experience for accrediting teams to visit with faculty members, review course syllabi and things of 

that nature. That kind of interaction does occur. 

Senator Brown. My experience would be that sessions with students are often not focused on 

their academic experience as much as general concerns about the university. I have never heard the 

time that the folks spend in the classroom be remarked on as anything but minimal, if it existed at 

all.

 I might say though that at least the state I am from did care about outcomes and did assess 

them. They assessed them by looking at professional exams that people took and a variety of other 

things indicating the quality of the courses. 

 It brings up one of the potentials here that is not being met by the current accreditation 

system, but that it is possible to meet if you would allow States to enter this arena as well. 

Chairman McKeon. Thank you. 

Mr. Hinojosa.

Mr. Hinojosa. Thank you, Chairman McKeon. I apologize that I was not here for the first part of 

the presentation made by members of this panel. I was working on some legislation and some bills 

that were being presented on the House floor. 

 I want to take this opportunity to ask some questions, and will address the first one to the 

Honorable Mr. Hank Brown. I understand that you are a former Congressman, a former United 

States Senator, and for that I want to thank you for your wonderful public service given to this 

country and to all the people of this nation. I want to ask you, with the experience that you have as 

a former president of a university in Colorado, how would you go about improving the 

accreditation of colleges, and how would you advise us to take advantage of the reauthorization of 

higher education that is coming up this next year so that we can require accountability of colleges 

receiving Federal monies for research, for program development, for outreach and recruitment of 

students into their universities, and finally helping students graduate, something that I am very 

concerned about? How would you do that? 

Senator Brown. Congressman, thank you for your kind words. It is true that I have had a difficult 

time holding a job. But I guess my impression after leaving academia in July is that this field 

would benefit from competition. The current 1952 Act, if I understand it correctly, does not 

prohibit other associations from offering accreditation. So it is not a monopolistic act in that sense, 

but it is boiled down to a very limited choice, at least in the accreditation field. 
23

 One of the areas I hope you look at is making it clear that states can indeed put together an 

accreditation system if they wish to in this area. I am not sure it is prohibited, but I think 

clarification on that would be helpful. 

 Secondly, I would hope the act would encourage the looking to objective standards for 

measuring quality. And I am not talking about inventing new ones, but I think there are some 

numbers that exist. If you major in accounting, the CPA exam is a national exam that measures 

your abilities and your knowledge in that area, and it is one that is reasonable for accounting majors 

to look to. Engineers have a similar exam. Teachers in many States have a similar exam. Students 

going on to graduate school have the opportunity to take the Graduate Record Exam. I would not 

suggest to you that there is one exam for everyone or that everyone should have an exam to look at. 

But I think there are enough good measures in that area, we ought to encourage accreditation 

reviews to take a look at results enough to draw the attention of universities to preparing students 

for the objective exams that their students do need to face. 

 So, talking about competition, I think it would be helpful to draw attention to 

comprehensive exams that measure outcomes. I do think a greater emphasis in terms of the 

accreditation process and looking at outcomes, more time in the classroom, et cetera, would be 

helpful as well. 

Mr. Hinojosa. I thank you for the response. And how would you require that colleges that have a 

high dropout rate do something about it? I can tell you that Hispanic students in colleges have a 

record of about half of them dropping out even from completing their community college, which is 

in most cases a 2-year period to get that associate degree. How would you go about correcting 

that?

Senator Brown. One of the most interesting things I did as president of the university was try to 

think through that problem. I went around to the high schools in Colorado and asked the high 

school counselors what they thought and who did the best job. Interestingly enough, a number of 

the high schools agreed that the U.S. Army did the best job. I said no, I am talking about recruiting 

for college. But what the Army did in their recruiting is that they went into the homes of Hispanic 

students. As you are obviously well aware, Hispanics typically come from a very close family 

relationship. The desire to leave home that is incumbent in many of us is not necessarily 

incumbent in that family structure. Their talking to the families was a key ingredient. We think we 

made a difference by involving the family in that recruiting. 

 The foundation I am with specializes in helping low income students go to college. Their 

standard is not the student’s grades, but rather the student’s potential as a human being. We think 

the key of our efforts is to prepare students for college. We have been successful with more than 

90 percent of the students that go through our prep program: they go to college, stay in college, and 

we believe they will graduate. I don't mean just prepare them academically. I mean prepare them 

in terms of what to expect, how to study, how to prepare, what life is like, and so on. At least it is 

our sense that in a significant portion of low-income families, particularly ones where no one in the 

family has gone to college, a significant effort needs to be made to prepare them for that life, 

because it is different than what they expected and different from what other students have in their 
24

backgrounds. That preparation is a key ingredient for how they do when they get to college. 

Mr. Hinojosa. Thank you very much. 

 Could Dr. Eaton possibly respond to my request, Mr. Chairman? 

Chairman McKeon. I think we need to go to the other members. 

Mr. Hinojosa. Yes. I didn't realize that they had come in. Go ahead. 

Chairman McKeon. Thank you. Mr. Petri. 

Mr. Petri. Thank you. I have a concern and a question. How do we do it? My understanding is 

that the federal government really didn't get into this business until about 1952, after we got quite 

active through the G.I. Bill, various other grants, and education grant programs. One of the 

motives for having accreditation was to make sure that they were legitimate schools, that they 

weren't fly-by-night outfits, and that people weren't being ripped off. As time went on, we ended 

up experiencing very high default rates on our student loans. As a result, we set up a whole new 

procedure to try to deal with that problem because the accreditation program didn't really work. 

But we didn't examine the accreditation program. One of the concerns is that we are delegating to 

private organizations, rather than government organizations, whether or not colleges, universities, 

and schools in the United States have access to enormous amounts of federal money. That one 

decision determines whether or not they survive. It is almost too much on a one-switch decision.

As a result, almost no one, if anyone, is ever really disaccredited. They are kind of nudged along 

and put on various lists and so on. It seems to me that we haven't thought through very well what 

we are really trying to do with this process and how it works and what the accountability should be. 

 So I wondered in that connection, Senator Brown, if you could just tell us how it works 

from your point of view as something coming in from outside, into academic life as a university 

administrator and then confronting the accreditation. Does it happen every year or is it something 

that only happens every decade? Is there a constant review so that people know what is going on? 

How does this actually work? 

Senator Brown. I think that the panel members have done a wonderful job in walking through 

that. The university I was at had a very pleasant experience with their accreditation. During my 

tenure we got a clean bill of health, which was the first clean of bill of health they have gotten in 

over 2 decades. 

 What had happened in the past was that they would have had visits where they were never 

denied accreditation, but a revisit was scheduled. That ended with the very good accreditation we 

had.

 I am going to say that I found it to be a bizarre experience, because I looked at the records 

of the previous accreditation that apparently was not good enough to end the question. You simply 

couldn't tell from the report what the concern was. It wasn't spelled out. For example, the library 

wanted more money, and so they were successful in getting in that accreditation report a notation 

that the library should receive more money in future years. I found, on checking out, our library 
25

got more money as a portion of the university budget than other libraries in the nation did from 

other universities. So it seemed to be a bizarre note. 

 The accreditation offered an opportunity for entities within the campus to come and express 

their objections or concern, or lobby for more money from the trustees. But in terms of specific 

suggestions that dealt with substantive issues on the campus, at least the previous accreditation 

reports I looked at were not very helpful nor very clear in that way. However, it sent a clear 

message that you had better not have anybody unhappy on the campus when the visit comes 

around.

Mr. Petri. Is it an expensive process? Do you pay to the accrediting associations for the 

opportunity to be accredited? 

Senator Brown. There would be other experts here that are much more able than I to address that.

But my impression was that the fees that you pay for membership are not extraordinary; they are an 

expense, but they are not overly high. You do pay some expenses for the visit. Probably the 

largest expense is the preparation for it. 

 My own sense about that preparation expense is that while it is a significant expense, it is 

probably reasonable for an institution to go through that self-examination process. So I personally 

ended up feeling there was value towards that portion of the expense. 

Mr. Petri. Would it make sense to allow people to choose one of the regional accrediting 

organizations rather than just stick to their own regions? There seems to be some element of 

competition that way. If they are all qualified to do the job, why do you have to take the one that 

you happen to reside in? Why couldn't you choose a different one if it made sense? 

Senator Brown. My impression is that there is some flexibility. There is simply not a lot of 

accrediting agencies, though. That is a phenomenon that the committee may want to look at in this 

regard. Obviously, I have urged you to consider making it clear states could do it, but my 

impression is that you haven't created a monopoly here. It is possible for other organizations to 

come forward. I do think the process would benefit by some additional competition in that area, 

though.

Chairman McKeon. I would like to welcome a good friend, my State Assemblyman George 

Runner and his wife, who will become the Assemblyman next year. They are here in town on 

special invitation from the White House. He authored a bill in California, the Amber Alert, which 

has been very, very big in California, and he is here to work with the White House on trying to get 

that to become a national law. Welcome George and Sharon. Thank you. 

Mr. Goodlatte.

Mr. Goodlatte. Thank you, Mr. Chairman. Senator Brown, I was pleased to hear you express 

some concern about grade inflation and the lack of core curriculum requirements. I wondered if 

you had some specific proposals for how dealing with those might be incorporated into the 
26

accrediting system. 

Senator Brown. Yes, Congressman, I do have some thoughts in that area. If you permit me, I 

think it has reached scandalous proportions, and it is among the greatest schools in the country as 

well as those that are not so great. Recently, Harvard got a great deal of attention when 91 percent 

of their graduating class graduated with honors. That means you literally could be in the bottom 10 

percent of your class and graduate with honors. I think the expression is, what a country. 

 Yale was embarrassed a few years ago by the fact that a student had admitted a phony 

transcript. It turned out that they actually had a little over a two-point grade average at a 

community college before the student entered Yale. At the time it was discovered, the student had 

over a three point at Yale. 

 My own university where I went to undergraduate school, the grade average that would put 

you in the top 10 percent of your class now puts you in the middle of your class, the same grade 

average. At the university I headed, I found that in one of our departments in education, the 

average grade was a three point six. Apparently it had quite outstanding students. 

 The simple fact is this needs to be part of any accreditation; that is, to see if the grading 

system accurately measures performance and does provide some difference between a student that 

is good and a student that is outstanding. If one doesn't provide that differentiation with the 

grading system, grades become less than meaningful. Also, I don't think that then one provides the 

incentive for excellence and the reward for excellence and hard work that we would expect our 

institutions to do. I think it is a matter of making sure it is included in the criterion that is looked at 

for accreditation. 

Mr. Goodlatte. Dr. Eaton, is it? 

Dr. Eaton. I think a number of the standards of both the institutional and programmatic 

accreditors do include attention to student achievement and the terms and conditions under which 

grades are earned. Accrediting organizations do not stipulate what a grade distribution ought to be, 

nor what should, in my view, an accrediting organization attempt to dictate to a faculty member 

how he or she might go about determining the extent to which a student has learned in an 

individual classroom. 

Mr. Goodlatte. But short of doing that, how do you impose some kind of a standard that would 

bring us back away from having 91 percent of the students graduating with honors? What is to 

distinguish them from amongst themselves if that is the case? 

Dr. Eaton. My sense, Congressman, is that this is an issue that is much, much broader than 

imposing standards or accreditation. It has to do with the extent to which colleges and universities 

are taking a hard look at the demands that they are making on students, the expectations they have 

of students to obtain some kind of credential or degree. I can see accrediting organizations raising 

these issues and working with colleges and universities and programs to say, that the colleges and 

universities need to be more rigorous or more demanding, if indeed that is required. There is a lot 

of debate out there about the extent of grade inflation, and in a number of places there is debate on 
27

whether one can make the case that it exists or not. There are pros and cons in the research on that 

issue.

 But nonetheless, an effort to enhance the rigor across the board in higher education 

institutions and programs can be undertaken. Accreditation can be part of that endeavor and part of 

a movement toward increased rigor, but it is not only a matter of accreditation. And I for one 

would have a great deal of concern about efforts to standardize across all types of institutions and 

programs. 

Mr. Goodlatte. My time is running out. I noted, Dr. Rose, in your testimony that one of the 

specific objectives of the accreditation review project was to increase attention to student learning 

outcomes and institutional improvement. I wonder if you have any specific ideas or suggestions 

with regard to how, for example, you measure that. 

Dr. Rose. Well, I think that is exactly where this issue will be addressed. When comparable 

information about a student's success is available to us beyond just the grades that individuals 

attained in classes, we assess their performance. At my own institution, we have a number of 

academic performance measures that are applied to our students. It will ultimately be difficult for a 

faculty member to explain the performance of a student in his or her class if that performance isn't 

paralleled in the results of student learning in the assessment tests that our students take as part of 

their general education requirements and then in their major. 

 That kind of conflict will become obvious to other faculties, and I think that pressure in 

itself will hopefully drive us back to a representative system that demonstrates variation among our 

students.

Mr. Goodlatte. Thank you, Mr. Chairman. 

Chairman McKeon. Thank you. 

Mr. Ehlers.

Mr. Ehlers. Thank you, Mr. Chairman. 

 First, I will put my two bits in about grade inflation. I am appalled at it, and I appreciate 

your perspective, Senator Brown. I feel exactly the same way. I taught at higher educational 

institutions for 22 years and could see the trend beginning when I was there. It has gotten 

considerably worse since then. Let me also observe, I see it from the other end now as I interview 

individuals for positions or for recommendations. Within the past 2 weeks I had one student say 

she had a 3.9, another that her GPA was about 3.6, and I found that I really didn't know what that 

meant. I don't know how to factor that in. I find at that point you almost have to resort to 

something universal, such as saying what was your ACT or SAT score when you started. But that 

is not a good measure, either. 

 Let me make a suggestion, and I, incidentally, disagree with you, Dr. Eaton. I think there 

are ways that the accreditation process can measure this by comparing to the professional exam 
28

grades and looking at that compared to where institution X, the one you are visiting, stands in those 

and how that compares to their grade average that they are giving out. 

 Another point that has been raised here by Congressman Petri is the measurement of 

outputs, and I am very nervous about measuring outputs in terms of grades because I think they 

become somewhat meaningless. It might make sense to have students to take the ACT or SAT 

afterwards and compare it to their pre-college administration and use the difference as a measure of 

how well the institution has done rather than a final result. Because obviously Harvard has very 

high admissions scores and SAT and ACT; other schools may not, but the other, the smaller 

institution or the liberal arts college that Dr. Cook referred to may actually have done a much better 

job with their students in bringing them up from where they were to what they have become. 

 But I really think the grade inflation is a major problem, and I call it the Lake Woebegone 

effect, because everyone today has to be above average. It is not just in college, it is in elementary 

schools and high schools as well. Fifty years ago, if you got a low grade in elementary school and 

you came home, you were in trouble with your parents. Today, when you get a low grade in 

elementary school and come home, the parent marches down to the school and the teacher is in 

trouble. It is just a different attitude. We have to recognize that average does mean average. It is 

the mean. You have to have the same number of below average as above average. 

 I would appreciate any comments or reaction to my statements. Dr. Eaton. 

Dr. Eaton. I think we are talking about two things here, sir. One is, how many of a certain type of 

grade are you giving. That is the Harvard example. And that is what to me people generally mean 

when they refer to grade inflation. And then second, what did it take to earn that grade? Which I 

think is perhaps the even more critical question. That is, if that person with whom you had the 

interview had this very high average but there weren't adequate demands or expectations placed on 

that person to achieve the kinds of competencies you were expecting for employment, how do we 

deal with that issue? I think we have seen a good deal of that. I am an employer, too. I have seen 

it. How do we combat that issue? What I am suggesting is that, A, accreditation is part of the 

solution but certainly not the whole solution. B, I am raising significant questions about whether 

standardizing grading across institutions is a solution or not. I have very, very serious reservations 

about the effectiveness of that. 

Mr. Ehlers. I am not suggesting that. I very carefully avoided that. I said we have to have some 

means of comparison. So if on the professional engineering, for example, institution A students get 

very high scores in the professional engineering exam, and in institution B they get lower, and yet 

institution B students had higher grades, you know there is something wrong with the grading 

system at institution B, or at least you know there is a relative problem there. 

 I am just saying it is a problem that has to be addressed. It has become a runaway problem. 

You cannot have meaningless grades. I recognize full well the differentiation. I taught physics. I 

happen to be a physicist. In the physics major classes my grades were very high because these 

were very high performing students. They were tackling very, very difficult topics and doing well 

on them. But I would also give low grades to those who didn't perform well. But when I taught 

non-majors in the lower division courses, my grade distribution was more in tune with what I 
29

thought the college as a whole should be, because I was dealing with students from all areas of the 

college. 

 Are there any other comments? Let the record show that Senator Brown is nodding.

Hesitantly, but he is still nodding. I yield back, Mr. Chairman. 

Chairman McKeon. I understand, Dr. Palmer Noone, you may need to leave to catch a plane. 

Dr. Noone. Yes, sir. 

Chairman McKeon. When you need to leave, leave, unless we have lost the plane already. 

Dr. Noone. Thank you. 

Chairman McKeon. Thank you. 

 You know, in listening to this discussion and the grade inflation, it reminds me that in L.A. 

County (where I am from) they have begun grading restaurants for their cleanliness. I go to a lot of 

restaurants, all the fast food, all of them, and they all have an “A.” I don't know what the criteria 

are, you know. I doubt that they are all of the same cleanliness level. Maybe there is a very low 

standard to get an “A.” I don't know. I did see one place once that was a “B.” But I have gotten to 

the point where, kind of like Dr. Ehlers, I kind of wonder what grades mean anymore. 

Mr. Wu.

Mr. Wu. Thank you, Mr. Chairman. I think that I need to improve the circles in which I travel, 

because in my travels I have come across restaurants with A, B, and C ratings, and this is of deep 

concern.

 I will be brief. I understand that there has been some discussion of whether accreditation is 

necessary as a precondition for student financial aid. I understand there is some divergence of 

opinion on that. And I guess I just wanted to put out for inquiry and discussion whether the 

accreditation process is of some help in, shall we say, quality control and eliminating some of the 

problems that we may have had in the past with certain institutions and receiving financial aid. 

 Dr. Eaton, perhaps we could start with you. 

Dr. Eaton. Thank you. I think the evidence is clear that accreditation has been helpful in that 

regard. That is not to say that every institution in the country that is accredited meets every 

exacting standard anyone might have. It is to say that you can reasonably rely on an institution if 

indeed it is accredited. We know that we had a major issue 10, 12 years ago with regard to fraud 

and abuse. We know that. We strengthened the accreditation procedures. We strengthened, as 

was indicated earlier, some of the law and regulation with regard to student financial aid. It took 

both things. It took a strengthening of accreditation that did occur as well as the changes in the law 

with regard to fiscal and administrative issues to bring about that reduction in default rates. 
30

 So I would say, sir, that indeed it is effective. We can talk about ways in which we might 

want to make it even more effective in the future. But the absence of any screen at all I think 

would be decidedly problematic. 

Senator Brown. Congressman, I would have a slightly different view. It does appear to me, if you 

look at the record, that indeed accreditation has been helpful in spotting institutions that are in 

financial trouble. There it has indeed identified institutions. While there have been very few that 

have been denied accreditation, it does help in that area. My belief is that it has not been effective 

in terms of offsetting standards on academic quality. Is it of some help? I think that is quite true. I 

think accreditation is going to exist whether or not you make it a condition of getting federal 

student assistance or not. 

 I think accreditation has a value and it will continue to have a value and will continue to 

exist. But I would separate it in your thinking from whether or not what standards you set allow 

students to get financial aid. My hope is you would, in thinking about financial aid, set standards 

you are comfortable with in regard to quality that are not now being identified by the current 

accreditation system. That can be done by ensuring additional entities are involved in 

accreditation, and it can be done by empowering states or making it clear that states can move 

forward in this area to ensure that the minimum quality is there. It can be done by toughening up 

the standards that you set for accreditation. It can also be done by the allowing the marketplace to 

set the standards. 

 Obviously, one of the things that happens here is that it is not just federal money that goes 

to support the institutions, it is students' money as well. 

 So it can be done by a variety of things, but at least in my mind the serious questions 

involving the declining curriculum demands and declining grading standards are not being met by 

the current system. 

Mr. Wu. Are there any other comments? 

 Let me just follow up, Senator Brown. If your view is that the marketplace should be an 

important mechanism here, isn't the availability of Federal financial aid in essence a marketplace 

factor if accreditation is necessary for the availability of Federal financial aid? I mean, that is an 

incentive-based system. Do you agree with that? 

Senator Brown. Sure, it is an incentive, and I am going to say I think it is reasonable for the 

Federal Government to look to standards. I don't think you want to abandon any check here in 

terms of monitoring where federal money goes. But I think it is unrealistic to assume that we are 

really doing a good job of valuing academic quality with the current system. 

Mr. Wu. Thank you very much, Mr. Chairman. 

Mr. Ehlers. Mr. Chairman, I wonder if you could just yield a few seconds. 
31

Chairman McKeon. Mr. Ehlers, please. 

Mr. Ehlers. I just wanted to add one additional comment on this issue, something I think would be 

legitimate for the accrediting agencies to do, and that is to require institutions to do surveys of their 

graduates. I know at the one institution I taught at, a very good liberal arts college, one of the 

highest ranked in U.S. News and World Report, a number of the departments did that every year, 

surveyed employers of their graduates over the past 5 years to see what their responses were about 

what the institution had done right, and had not done right. Information of that sort I think would 

be very useful to the accrediting teams as they come in. 

Chairman McKeon. Thank you very much, and I understand Mr. Hinojosa has some other 

questions.

Mr. Hinojosa. Mr. Chairman, if I could submit my questions in writing to save some time. 

RESPONSES TO QUESTIONS SUBMITTED FOR THE RECORD BY REPRESENTATIVE 

RUBEN HINOJOSA, SUBCOMMITTEE ON 21ST CENTURY COMPETITIVENESS, 

COMMITTEE ON EDUCATION AND THE WORKFORCE, U.S. HOUSE OF 

REPRESENTATIVES, WASHINGTON, D.C. – APPENDIX I 

Chairman McKeon. I appreciate that. Any other members who weren't able to make it here 

today, we will keep the record open. We would appreciate, if you hear from those questions from 

other members, if you could answer for the record. As we move forward on this, there will be I am 

sure more discussion on this area. It is a very important issue that we will be looking into as we go 

through the reauthorization process. 

 Thank you again for being here. I would encourage you to stay involved. As we go 

through the reauthorization process we could use your help and expertise. Thank you very much. 

 If there is no further business then, the subcommittee stands adjourned. 

 [Whereupon, at 4:05 p.m., the subcommittee was adjourned.] 
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113

TABLE OF INDEXES 

Chairman McKeon, 1, 2, 6, 7, 8, 11, 13, 16, 17, 20, 21, 22, 24, 25, 27, 29, 31 

Dr. Cook, 11, 21 

Dr. Eaton, 9, 20, 21, 26, 28, 29 

Dr. Noone, 29 

Dr. Palmer Noone, 7, 13, 21 

Dr. Rose, 8, 17, 22, 27 

Mr. Ehlers, 27, 28, 30, 31 

Mr. Goodlatte, 8, 25, 26, 27 

Mr. Hinojosa, 22, 23, 24, 31 

Mr. Petri, 6, 7, 24, 25 

Mr. Tierney, 2, 4, 7 

Mr. Wu, 29, 30 

Senator Brown, 16, 22, 23, 24, 25, 26, 30