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Submission For The Record of Jean Avnet Morse, Middle States Commission on Higher Education, on behalf of the, President, Council of Regional Accrediting Commissions

Mr. Chairman and Members of the Committee, I appreciate the opportunity to submit testimony on the issue of whether the work of accreditors and state approval agencies (SAAs) overlaps.  This issue was raised in the March 2007 GAO report on VA Student Financial Aid, and I have been asked to comment.

Summary:

Regional accreditors already cooperate with state licensing agencies to prevent duplication.  It is not likely that accreditors' general review of all areas overlaps with the areas relating specifically to veterans.  The research that would be required into the varying practices of 60 accrediting agencies and specific requirements for SAAs would probably be extensive.

The Role of Regional and Other Accreditors

I am the president of the Middle States Commission on Higher Education of the Middle States Association of Colleges and Schools. The Commission has a membership of more than 500 colleges and universities located in Delaware, Maryland, New Jersey, New York, Pennsylvania, the District of Columbia, Puerto Rico, the U.S. Virgin Islands, and in other countries.

I am testifying on behalf of the Council of Regional Accrediting Commissions, known as C-RAC.  It includes the seven U.S. regional accreditors that accredit institutions enrolling over 16,000,000 students.  Regional accrediting agencies have assured the quality of higher education in the United States for over 100 years, providing self-regulation and shared assistance for improving education.  For the past 50 years, these agencies have supported federal funding functions: when an agency is "recognized" by the U.S. Department of Education, the students of institutions accredited by that agency are eligible for federal grants and loans under Title IV of the Higher Education Act.

1.  There is not a single type of accreditation review.  Although all accreditors review the areas required by the Higher Education Act and USED regulations, the review varies among 3 different types of accreditors within types of accreditors.

The three types of accreditors are "regional," "national," and "specialized."  Of the 60 accreditors mentioned in the March 2007 GAO report, most are specialized accreditors.

Seven regional accreditors (such as mine—the Middle States Commission on Higher Education) accredit only degree-granting institutions of higher education.  There are over 3,000 regionally accredited institutions.

National accreditors (such as ACCSCT, which was interviewed by the GAO) accredit institutions across the U.S. that may or may not grant college degrees and that have historically fallen within specific types of categories (distance learning, etc.).  They are expanding their coverage.

Specialized accreditors accredit specific programs, such as law or medicine, rather than whole institutions.

Some accreditors of each type are "recognized" by the U.S. Department of Education.  These are "gatekeeper" accreditors whose accreditation allows students at accredited institutions to receive federal grants and loans.  Unrecognized accreditors are not governed by the federal regulations for "recognized" accreditors.

My testimony relates to regional accreditors.

2.  Accreditors review and monitor colleges and universities at no cost to taxpayers.

Evaluators, task force members, and other experts virtually volunteer their time.  A small permanent staff is supported by dues and fees. Training and other activities are paid for by attendees.

Therefore, even if there were overlap between SAAs and accreditors, the government would not be paying twice.

3.  Accreditors do not typically interact with SAAs.  The GAO report notes that the reviews conducted by the SAAs and accreditors might overlap.  However, because accreditors rarely work directly with SAAs, it is difficult for us to determine this based upon actual experience.  When accreditors work with a state agency, it is typically its Department of Education (the "licensing" agency described on p.10 of the GAO report).  (See # 6,7, & 8 below for how overlap is prevented between licensing and accreditation.)  However, the Department of Education only serves as the SAA in 31 states.  Even in those 31 states, the personnel who handle SAA matters are not always the licensing personnel with whom accreditors work.

4.  For the six core duties of SAAs described briefly by the GAO on page 9, a careful review of the statutes and regulations governing SAAs would be required to determine how they relate to the federal regulations for "recognized" accreditors and the actual practices of accreditors.

(a) "Approval of Programs":  Accreditors approve some, but not all programs.  The federal criteria for review by "recognized" accreditors do not relate to veterans.

(b) "Visits to Facilities": Accreditors visit facilities in some, but not all, cases.  Again, the federal regulations for visits from "recognized" accreditors do not refer specifically to veterans.

(c) "Technical Assistance to Individuals at Facilities":  Accreditors require that accredited institutions provide student support services, but the federal regulations for student services requirements by "recognized" accreditors do not specifically refer to the "technical assistance to individuals" required of SAAs.

(d)  "Outreach":  Accreditors do outreach, but not specifically to veterans.

(e)  Liaison with Other Service Providers:  Accreditors "liaise" with other service providers, but my agency's standards to not specifically relate to veterans.

(f) Contract Management:  Accreditors review institutional contracts in some cases, but probably not in the areas required of SAAs.

5.  The GAO states that "similar categories of standards exist across agencies, but the specific standards within each category vary and the full extent is unknown."   This is correct.

Accreditors certainly address 6 of the 7 areas listed on page 15 of the GAO report.  However, interests and coverage of state and federal agencies differ from those of accreditors.  The GAO report gives examples of how SAA requirements may exceed those of accreditors (p.15).

Those areas are: student achievement; curricula, program objectives, and faculty; facilities, equipment, and supplies; recruiting and admissions practices; and record of student complaints.

6.  Many states in our region require both initial and ongoing accreditation as a pre-condition for licensing institutions of higher education.

This reflects their practice of relying on accreditation to ensure compliance and monitoring in areas that states do not evaluate themselves. This is done to avoid duplication.

7.  Accreditors and state agencies in the Middle States region have also established other methods of preventing duplication.

Middle States convenes periodic meetings with state licensing agencies to compare practices and to avoid duplication.

We invite representatives from state agencies to join our visiting teams, in order to prevent duplication.

Conversely, Middle States' policies state that institutions may submit materials prepared for state agencies to satisfy Middle States' requirements.

Thank you for the opportunity to submit testimony about these issues.