Monday, September 01, 2014


The Accreditation Conundrum

Are accrediting bodies toothless jellyfish, or jackbooted thugs?  

Reading these two articles next to each other, it’s easy to be confused.

The first, by Andrew Kelly, suggests that accreditation agencies amount to the enforcers for a producers’ cartel.  Given that “peer review” underlies regional accreditation, the definition of “peer” matters.  If a new provider comes along that doesn’t resemble its predecessors in important ways, then it’s entirely likely that the “peers” will find a reason to reject it.  But once you’re in the club, it’s remarkably rare to get kicked out.  Kelly notes that institutional eligibility for Title IV financial aid is a binary variable -- yes/no -- so the usefulness of any “in-between” or “warning” findings has to rest on the credibility of the ultimate weapon.  If a college actually believes that the ultimate weapon might be used, then warnings and such may work.  But if nobody seriously believes that the ultimate weapon would actually be used, then anything short of it is merely ceremonial.

Kelly’s position, I think, is that part of the higher education cost spiral can be explained by incumbents engaging in cartel-like behavior, with accrediting agencies acting as the border patrol along the boundaries of the cartel.  We can urge accreditors to be more open-minded, but that would violate their basic reason to exist.  Incumbents protect each other.

Except when they don’t, as in San Francisco.  The San Francisco Examiner noted last week that the California legislature passed unanimously (!) a bill to require the statewide community college accreditor to report directly to the legislature.  The motive was to bring the accreditor to heel, so that it wouldn’t follow through on its threat to shut down CCSF, or make similar threats in the future.  

The California case provides a fascinating counterpoint to Kelly’s thesis.  Whatever position you take on it, CCSF is an incumbent provider.  The ACCJC attempted to shut it down.  CCSF hasn’t been rescued by its fellow incumbents.  It has been rescued by judges and legislators.  The “peers” were prepared to close it; political figures from outside of higher education made sure that didn’t happen.

The “cartel” thesis really struggles to explain CCSF.  CCSF’s tuition, as is true of community colleges generally and California community colleges in extremis, is markedly low.  The indifference to pricing that cartels are supposed to enable didn’t happen in this case.  (To the extent that price increases did happen, they were tied directly to cuts in legislative support.  Even after those increases, though, tuition there is still low.)  And the “peers” were far more willing to be the bad guys than the general public was.

A single counterexample doesn’t necessarily tank a thesis, but it does raise some questions.  If the accrediting agency is really captured by incumbents, why is it giving incumbents a hard time?  Alternately, if it has an anti-incumbent agenda, as some have suggested, why?  If nothing else, the seeming “rogue” status of ACCJC calls into question the idea that peer review is necessarily clubby and insular.  In this case, it seems almost hostile.  The very independence from its sponsors that Kelly sees as an impossible dream strikes the California legislature as a clear and present danger.  

I’m thinking that maybe we should be a little more circumspect about inferring organizational behavior from a simple, preconceived theory.  Yes, peer review can be insular, but it can also be exacting or even vicious.  Yes, accreditors can create barriers to entry, but they can also force a certain honesty on providers who rely on federal financial aid.  (I’ll go farther.  If regional accreditors are such lapdogs, why do most for-profits avoid them in favor of so-called “national” accreditors?  And if regional accreditors are so clubby that nobody can get in, how is it that Phoenix and DeVry did?)  In my neck of the woods, I’ve seen NEASC work positively with SNHU’s competency-based College for America, despite the very real threat that a competency-based degree could pose to incumbents.  In that case, I applaud NEASC for being forward-looking.  That’s exactly what I would hope a group of concerned professionals would be.

So no, I don’t think of regional accreditors as either spineless or jackbooted.  And I’d be wary of any analysis that needs them to be one or the other.

You buried the lede, although I do believe that CCSF ignored the requests from their accreditor because they didn't think there would be any consequences for doing so. They clearly did not understand the national push that has led every regional agency to add Learning Outcomes Assessment to their requirements.

SNHU proves, unquestionably, that innovation is possible within the existing accreditation system.

(The multi-decade existence of non-traditional forms of delivery such as credit by exam or self-paced courses and now hybrids or fully distance classes that are not tied to seat time also supports this view. Some of those have been, and remain, quite cost effective.)

The fact that nationally accredited schools and colleges are outside the alleged cartel while community colleges are inside of it proves that COST is not a result of limitations attributable to regional accreditation.

Contrariwise, the examples cited in the linked speech by Marco Rubio show (to someone who knows the difference between a research university and a culinary career school) exactly why there is a spectrum of cost between different kinds of colleges and schools that is unrelated to accreditation.

I would argue that he finds it easier to assert that some third accreditation group (presumably profit driven) would be better than the ones that exist than he would do trying to prove with data that schools being denied accreditation or having it revoked have quality programs.

But perhaps he just wants to change Title IV so that students at schools on probation or warning get only a fraction of the support that ones at fully accredited schools get.
I think that CCSF may be an unusual case in many ways, in that no one other than accrediting agency saw serious problems at CCSF. Many of the flaws the agency pointed to had little to do with the education that CCSF was providing, and much to do with the agency's narrow vision of how they would run a college.

Most of my experience with external review is that the process provides useful feedback to institutions and individual departments, but at a fairly high cost in terms of faculty time. But WASC reviewing UC seems to have a better process than ACCJC reviewing SFCC.
The "cartel" thesis is a thing that I recognize from my academic economist days -- everything bad must come from regulation, nothing bad can come from anything else. There's also a general incapacity within the econ profession, especially on the dexter side, to acknowledge the existence of concepts like professionalism or ethics.

In this case, it's the basic standards associated with the accrediting body. It can't be that we've systematically defunded higher ed while providing an ever-more-sought-after product. It has to be the evil cartel!

Anyways, it's a cultural thing. You learn to ignore it as background noise once you're part of the profession, but yeah, it looks weird as hell to outsiders.
PunditusMaximus: The dexter side?
Right-wing. Obviously out-clevered myself.

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