In early August, the federal Department of Education held a little known but statutorily required convening to maintain the balance of the higher education quality assurance ecosystem. Almost all US colleges and universities operate in this regulatory ecosystem, often described as the Triad, which consists of state governments that authorize institutions to operate, accreditation agencies that assure educational quality, and the federal government that administers student aid programs. Most higher education stakeholders will likely be familiar with accreditation and may know that state regulations authorize institutional operation within a specific area. However, few will have heard of the third element of the Triad, the National Advisory Committee on Institutional Quality and Integrity (NACIQI), despite its important role in quality assurance.

In spite of its relative obscurity, NACIQI has significant influence on accreditation and access to federal financial aid programs. Formally, NACIQI makes recommendations to senior officials at the federal Department of Education on whether to recognize or re-recognize accreditors, the nonprofit agencies that grant approval to postsecondary institutions to participate in the Title IV federal financial aid program. Informally, NACIQI influences recognized accreditors, and through them, most higher education institutions, by focusing on specific aspects of policy or practice during its twice-yearly meetings and through public reports. For instance, NACIQI’s regulatory sub-committee recently released a 19 page report on issues related to the statutes and regulations governing NACIQI itself and the accreditors it recognizes, some of which could have wide-ranging impacts, from the way institutions assess student success to the way that the Department of Education handles complaints from individuals.

This blog post describes several of the issues raised in the report most closely aligned to NACIQI’s role in ensuring quality of the student experience. There are many interrelated areas of federal policy and accreditation in which NACIQI plays a part, but setting standards for student success, ensuring fair and equitable complaint processes, and finding ways to meaningfully involve the public are the three functions addressed in this report most likely to contribute to more effective institutions that can better serve students..

Closing the Loop on Student Success Standards

The report authors observed that “the statutory provisions with regard to accreditation and student achievement are, in short, a mess,”  noting inconsistencies within the Higher Education Act (HEA) about “what the Department of Education can or must require regarding student achievement.” These inconsistencies include conflicting statutes that require accreditors to include appropriate measures of student achievement in their standards, while at the same time precluding the Department of Education from specifying, defining, or prescribing the standards that accreditors can use. The authors noted that accreditors must set forth expectations for student achievement, but are not required to—and often do not—follow-up with institutions that do not meet the expectations.

“The statutory provisions with regard to accreditation and student achievement are, in short, a mess.”

In addition to admonitions to both Congress and the Department of Education to resolve these inconsistencies, the sub-committee members recommended that accreditors fully assess institutions’ success in meeting expectations around student achievement, rather than simply requiring that standards exist. The sub-committee further recommended that accreditors use the newly reinstated data dashboards as the foundation of an assessment process that helps determine an accreditor’s compliance with the criteria for federal recognition. Such a system could mirror the student learning assessment processes accreditors already require of their member institutions.

Fairness and Efficiency in Processing Complaints

The sub-committee report codifies concerns NACIQI members have long had about accreditors’ processes related to reviewing and addressing complaints about their member institutions.  Under current regulations, accreditors are expected to keep a record of complaints and review complaints against member institutions in a timely, fair, and equitable manner. Addressing NACIQI member concerns about accreditors’ policies and practices for documenting and responding to complaints continues to be a key issue, as the topic also featured prominently in past NACIQI meetings.

The report makes clear the sub-committee’s critiques of the current constellation of complaint processes. Three processes are of particular concern: prohibitions against anonymous complaints, prohibitions on refusing complainants before the complainant has exhausted all relevant institutional processes for redress, and prohibitions against rejecting complaints that are not tied to specific standards of accreditation. Despite the amount of time devoted to complaints during NACIQI meetings, the sub-committee ultimately calls on Department of Education professional staff to offer recommendations for how to make such processes more fair. A separate section of the report addresses complaints made directly to the Department of Education as opposed to complaints lodged with accreditors; the sub-committee members felt an online portal was necessary to enable them to register and report on complaints against accreditors.

Transparency and Public Input

A simple analogy is that NACIQI is to the accreditors as the accreditors are to their member institutions. However, this analogy hides many of the statutory and regulatory restrictions under which NACIQI members attempt to do their work of assuring quality in higher education, including the sometimes nonsensical rules about timing and method of NACIQI’s communication with accreditors and the public. As outlined in the subcommittee report, under current rules, accreditors submit their petitions for initial recognition or renewal 24 months before appearing at a NACIQI meeting, meaning recognition decisions are based on information and data that is two years old; additionally, accreditors are restricted from adding or updating information after the public review period which takes place 12 months before the meeting. These long lead times in the NACIQI review process hamstring accreditors’ ability to be responsive and undercut NACIQI’s goals of transparency and accountability.

The sub-committee report also recommends that NACIQI members have a process for informing accreditors of the questions about their petition that may arise at the recognition meetings, which the statutes currently prohibit. Direct communication between accreditors and NACIQI members is limited to the few hours they spend together during official NACIQI meetings, so there is little opportunity for NACIQI members to raise concerns, ask questions, or express priorities before the live conversation has begun. The NACIQI website even requests that its members not be contacted by any higher education stakeholder or members of the public, diverting all comments to submissions via the Federal Register, undermining the collegiality on which higher education prides itself. These limitations preclude a more cooperative and effective approach to accreditation and quality assurance.

Other Assorted Issues

The sub-committee report raised other areas of concern regarding the regulations governing the accreditation ecosystem. These include 1) how Department of Education accreditation relates to other federal programs (such as Health and Human Services health education programs); 2) the quality of nursing degrees from programs that are only accredited by a state board or specialized nursing program accreditor (as opposed to being part of an institution that has otherwise received institutional accreditation); 3) the direct role of NACIQI and the Department of Education in approving military programs; and 4) several areas of accreditor board membership and industry reputation.

Major Takeaway

Overall, this report reveals NACIQI members’ collective sense of frustration at their inability to enact their priorities as part of the quality assurance Triad. It also outlines priorities for the changes it would like made to the policy environment in ways both large and small. The report calls on other federal entities, including most notably Congress and the Department of Education, to take action because it is not empowered to make changes to its own operating procedures, requirements for recognition, or modes of communication. This lack of statutory and regulatory autonomy prevents NACIQI from being as effective or efficient as it could be in assuring quality of the educational experience for students.