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Witness Testimony of Ms. Carol A. Griffiths, Accrediting Agency Evaluation Unit, Office of Postsecondary Education, Chief, U.S. Department of Education

Good afternoon Chairwoman Herseth-Sandlin, Ranking Member Boozman, and members of the Subcommittee.  I appreciate the opportunity to appear before you today to share with you the Department of Education’s activities related to the accreditation of postsecondary education institutions and programs.  My testimony will describe the U.S. Secretary of Education’s accrediting agency recognition process  -- providing you with a snapshot of the type and breadth of accrediting agencies currently recognized by the Secretary and the components of the recognition process, as well as -- highlighting some of the criteria for recognition and the role of the Secretary’s Advisory Committee in the recognition process.

The Department of Education relies on accreditation by recognized accrediting agencies and State approval agencies as a primary factor in establishing the eligibility of institutions to participate in federal student financial aid programs authorized by Title IV of the Higher Education Act of 1965 (HEA).  Other Federal departments also rely on the Secretary’s recognition of accrediting agencies as an eligibility factor for participation in various programs they administer.   In the context of the recognition process, State approval agencies are units within State Departments of Education that have responsibility for the oversight of postsecondary vocational education.

Authority

Since 1952, the Secretary of Education has published a list of recognized accrediting agencies that the Secretary determines are reliable authorities of the quality of education and training provided by the institutions and programs they accredit.  The initial authority for this was in the Servicemen’s Readjustment Act; the recognition authority is now part of the HEA, which establishes the requirements for recognition of accrediting and state agencies.

Currently the Secretary recognizes 62 institutional and programmatic accrediting agencies.  There are 4 types of institutional accrediting agencies, though the distinctions between them are diminishing. 

National institutional accreditors-- as the name suggests -- accredit schools throughout the United States.  Historically, they’ve accredited private for-profit institutions offering predominantly non-degree, vocational technical education programs.  However, their recognized accrediting activities have expanded to include accreditation at all educational levels, including doctoral degrees and the accreditation of private non-profit institutions.  Their emphasis remains, however, on the accreditation of institutions providing professional, technical, and occupational education programs. 

Regional institutional accreditors, as the label implies, accredit in a specific geographic region of the US.  There are 6 regional accrediting associations  – New England, Middle States, North Central, Northwest, Western, and Southern.  Historically, the regional accrediting associations accredited public and private-nonprofit degree-granting institutions of higher education.  Again, as for-profit education has expanded into the degree-granting realm, regional accreditors have expanded their accreditation activities to include accreditation of for-profit institutions.  Also, as public and private degree-granting institutions have expanded their offerings to include non-degree programs, regional accreditors have augmented accrediting activities to include these non-degree programs. 

The New York State Board of Regents is the sole accrediting body in a third category of institutional accreditor.   The Board of Regents is, by federal statute, eligible to seek recognition for its accreditation of a limited universe of degree-granting institutions (24 institutions) in New York seeking to participate in HEA programs. 

The fourth type of institutional accreditor is the specialized, programmatic accreditor that accredits single-programs and single-purpose institutions, so that those schools may be eligible to participate in the federal student financial aid programs.  These include accreditors of free-standing schools of osteopathic or podiatric medicine, free-standing schools of music, dance, or theater, or schools of mortuary science.  These specialized accreditors accredit a specific type of educational program and are usually closely associated with, or part of, an association of individuals employed in that profession. 

The Secretary’s recognition process also includes 5 State approval agencies in 4 States (New York, Oklahoma, Pennsylvania, and Puerto Rico) that have sought and received recognition for their oversight of public, postsecondary, vocational- technical education in their respective States to enable those programs to participate in student aid programs authorized by Title IV of the HEA.  These agencies are a part of the State educational agency in their respective States, and this recognition enables access to Federal student aid by adults enrolled in programs usually offered through the adult vocational education program of the local K-12 school district. 

The Recognition Process

The recognition process is voluntary.  The Secretary’s recognition is not required for accrediting agencies to exist, or to accredit.   However, recognized accreditation is a requirement for institutions’ and programs’ participation in the Title IV student aid programs and in many other Federal programs.

Also, since the 1992 reauthorization of the HEA, an accreditor must demonstrate a Federal purpose for seeking the Secretary’s recognition.  The accreditor must establish that its accreditation is necessary to enable one or more of its accredited institutions or programs to participate in a Federal program.  Therefore, not all accreditors, even those that may desire to submit to the Secretary’s review process, are eligible for recognition.

Components of the Recognition Process.

To some extent, the components of the recognition process parallel the accreditation process.  Like the accreditation process, the recognition process includes an agency self-review, Department review of the agency’s policies, standards, procedures and practices, solicitation of public input, a review by the Secretary’s National Advisory Committee on Institutional Quality and Integrity (NACIQI), a Committee representative of the higher education community, and a decision by the Secretary.  Each agency is reviewed at least once every 5 years (4 years for State approval agencies).

Eligible accrediting agencies seeking recognition must demonstrate their compliance with the criteria for recognition published in 34 CFR Part 602.  As a first step of the process, an accreditor conducts a self-review of its compliance with the Secretary’s criteria for recognition and submits a statement of its requested scope of recognition along with a narrative describing its compliance with each of the 18 criteria for recognition and documentation evidencing that compliance.  The agency also submits to observations of its activities and reviews of its files by Department staff.  State approval agencies must demonstrate compliance with 34 CFR Part 603 in the same manner.

The requested scope of recognition includes the range of accrediting activities for which the Secretary recognizes an accreditor.  This includes the types of accrediting activity –  institutional or programmatic, types of degrees or certificates, geographic area of accreditation, type of pre-accreditation if any, and activities related to distance education, if any.  Accreditors may, and many do, conduct activities outside their recognized scope of accreditation.  For example, a number of U.S. accreditors also accredit foreign institutions, but as the Secretary’s recognition authority is limited to U.S. institutions, the Secretary does not evaluate an accreditor’s activities in relation to the foreign institutions and this aspect of an accreditor’s activities is not included in the agency’s recognition.

The 18 recognition criteria are used to examine an accrediting agency’s organizational structure and administrative and fiscal responsibilities; the agency’s standards and their application, enforcement and review; and the agency’s operations regarding monitoring and oversight of its accredited institutions and programs.  There are also criteria that address an agency’s adherence to due process, conflict of interest practices, and its practices regarding its responsiveness to complaints and the public notice of its accreditation decisions.

An agency’s organizational structure is evaluated with a focus on the ability of the agency to demonstrate that its accrediting activities and decisions are separate and independent from influence by related, associated, or affiliated trade or membership organizations.

The agency must demonstrate its administrative capability to conduct its accreditation activities by evidencing the composition and competency of staff, evaluators and decision makers who are free of conflicts of interest.  It must also demonstrate its financial viability to carry out its accrediting functions. 

The agency must demonstrate that its standards are sufficiently rigorous, and adequate to measure the quality of the education and training of the institutions or programs it accredits, and that they continue to be relevant to the education and training needs of students.  The areas for which the accreditor must have standards are outlined in statute and include an evaluation of curriculum, faculty, fiscal/administrative capacity, admissions, recruiting and publications, student services, facilities and resources, and the institution or program’s success with respect to student achievement.

The agency must demonstrate that its accreditation decisions are consistent, based on its published standards, made without conflict of interest, that its institutions and programs are provided due process, and that the agency has processes for evaluating change and for monitoring its accredited institutions or programs.

Department staff evaluate the written evidence, observe one or more accrediting agency activities, such as training sessions, agency evaluations of institutions or programs, accreditation decision meetings, file reviews, or appeal hearings.  From this evaluation and observation, the staff draws conclusions of compliance and drafts a report of findings that is provided to the agency.  The agency then may respond with further evidence of its compliance with the criteria.

A concurrent step in the process, public input, is solicited via Federal Register notices inviting comments regarding the agency’s compliance with the Secretary’s criteria. 

National Advisory Committee on Institutional Quality and Integrity (NACIQI)

The final step before reaching the Secretary is a review of the agency by the Secretary’s National Advisory Committee on Institutional Quality and Integrity (NACIQI).  This is a 15-member committee authorized under the HEA and appointed by the Secretary to advise her on matters related to accreditation.  This Committee, representative of the higher education community, meets twice a year (June and December) and, in a public forum, reviews each agency’s petition for recognition.  In preparation for that review, the Committee members are provided all agency information and the Department staff analysis of the petition.  After hearing from Department staff, the agency and any 3rd parties present at the meeting, the Committee deliberates and makes a recommendation to the Secretary to grant, defer, or deny recognition.  For accrediting agencies, the period of recognition cannot exceed 5 years.  Decisions on agencies that have outstanding issues may be deferred and the agency given a limited window of 12-months in which to correct deficiencies.   The agency may appeal the Committee’s recommendation to the Secretary.  With or without an appeal, the Secretary makes the final decision.

In conclusion, the Department of Education recognizes 62 accrediting agencies and 5 State approval agencies as reliable authorities of the quality of education provided by postsecondary institutions and programs.  This recognition process is a critical part of the oversight needed on a variety of Federal programs that provide access to approximately 90 billion dollars annually by institutions of higher education, students, and their families.  The recognition process is comprehensive and on-going and includes input from entities both internal and external to the Federal government.  I hope this information is useful to you, Madame Chairwoman, and I would be pleased to answer any questions you or any of the other members of the Committee may have.