The Administration's Plans for Higher Ed Accreditation

Some fundamental changes are coming and they're not good

I’ve been prepping for a Higher Learning Commission accreditation visit coming up in two weeks, which is why I haven’t been writing as much as normal. A comprehensive visit occurs every ten years with an online review happening four years later.

I’ve been involved in accreditation since 2002. This is my fourth time to chair a comprehensive visit team. I’ve also done a handful of the fourth year reviews. My team includes four people in higher education from a range of institutional types. We will be on campus for a day and a half, which I’ve always described as an exercise in applied ethnography. We have 36 hours to understand what life inside the institution is like.

That sense of ethnography is important because the institution first tells its own story. Institutions across the accrediting region agree on a set of criteria for accreditation. The school then provides an argument (creatively titled the “assurance argument”) that demonstrates the ways in which they have conformed to those policies within the context of the university’s unique mission and culture. The argument provides links that purport to document its compliance with the criteria (some better than others). The visiting team must understand the unique culture and read the argument with that framing in mind. Hence, ethnography.

We typically have the assurance argument four weeks prior to the visit. Over that month, the team is reading the report, exploring the evidence, identifying additional needed documentation, and developing questions to ask when we’re on campus. We meet virtually as a team three times before the visit (our second was yesterday). Our primary purpose during the day and half on campus is to affirm the validity of the assurance argument, deepen our understandings of the school, and then to draft an evaluative report, which becomes background for future reviews others will do for the institution.

I share all this because it’s what is occupying my brain at the moment. And I think it’s always good to provide transparency to an often fraught process. Most importantly, however, I’m afraid that this model based on institutional uniqueness and self-understanding is at significant risk of going away under the Trump Department of Education.

Undersecretary of Education Nicholas Kent, courtesy of the Chronicle of Higher Education

This week, the Department of Education released their draft proposal for reforming the accrediting process. In their (paywalled) story, the Chronicle of Higher Education wrote:

The department’s recommendations, foreshadowed in comments by Nicholas Kent, the under secretary, add new layers of responsibility for both accreditors and colleges and seek to codify the administration’s ideological agenda for higher education.

Early discussions about the plans to reform accreditation revolved around the process for creating new accrediting bodies in addition to the more established (formerly regional) ones. I’ve thought of these proposed new bodies as “We’re Not WOKE” accreditation options. They would provide an opportunity for anti-woke state legislators and governors to make sure that they can ignore diversity issues¹.

But the newly proposed rules do much more than that. As the Chronicle reports

But even as the department seeks to reduce its own role overseeing accreditors, the regulations would impose new demands on accreditors in assessing institutions. Accreditors would have to ensure that: 1) All of their own and their members’ policies and procedures comply with both federal and state laws, “including the prohibition of preferential treatment based on protected characteristics, such as race-based scholarships or programs, and preferential hiring or promotion practices.” 2) Colleges comply with the First Amendment and require “viewpoint and ideological neutrality in policy implementation, with protection for religious institutions.” 3) Institutions provide “support for and appropriate prioritization of intellectual diversity amongst faculty.”²

In addition, institutions will be required to show student outcomes at the program and not just institutional level with a particular focus on Return on Investment. This would be a government mandate to ramp up the kind of blind numeracy that has devastated much of liberal arts, social science, and social service programs.

Some states (like my birth state, Indiana) have already adopted viewpoint diversity and institutional neutrality legislation as well as banning special programs based on race or gender. As horrible (and likely unconstitutional) as those requirements are, I think the proposed federal rules are game changers. Not only would they apply to any institution whose students receive federal financial aid funds but the administration has already demonstrated its eagerness to use civil action against universities it deems as out of step.

More fundamentally, the proposed rules completely reverse the assumption of institutional uniqueness I discussed in the first half of this post. At the most literal reading³ every institution will be required to show how it lines up with every other institution. The Department of Education, through its control over the accrediting bodies, will determine what counts as quality higher education.

Universities serving unique populations — like Hispanic Serving Instutions or Tribal schools or any school with a large percentage of Pell or First Generation students — will find themselves at a competitive disadvantage. Unless, of course, the only admit those students who will make their program outcomes look good. Mandates on institutional neutrality and intellectual diversity will disincentivize institutions from addressing contemporary issues.⁴

The Chronicle notes that public discussion on the proposed rules runs from May 18th to May 22nd. I plan to share a version of these comments.

But if these rules are adopted,⁵ my nearly 25 years as an accreditation reviewer is likely at an end. I don’t see how I could in good conscience participate in such a fundamental shift away from university autonomy.

1. The HLC core component about diversity reads “The institution provides opportunities for civic engagement in a diverse, multicultural society and globally connected world, as appropriate within its mission and for the constituencies it serves.” Horrible, I know.

2. Edited slightly as SubStack won’t let me block quote bullet pointed lists so I changed it to numbers.

3. Which the administration likes to do if it doesn’t involve them.

4. There’s been a discussion on social media about why there aren’t protests on college campuses. When you look at the draconian steps this administration has taken and continues to take against pro-Gaza protests in 2023, it’s easy to see why schools are dodging questions about the War in Iran or attacks on Democracy.

5. While it’s true that a future democratic administration could develop a new set of rules, I fear that the damage to the accrediting process may be hard to undo.