Comments on Senate HELP Committee Paper, “Higher Education Accreditation: Concepts and Proposals”

Friday, April 24, 2015

Carol Geary Schneider, President, Association of American Colleges and Universities 

As the president of the Association of American Colleges and Universities, the leading national association concerned with the quality, vitality, and inclusiveness of undergraduate education, I am pleased to offer these comments regarding the recently released White Paper on “Higher Education Accreditation: Concepts and Proposals.” 

Founded in 1915, AAC&U now comprises nearly 1,350 member institutions—including accredited public and private colleges, community colleges, research universities, and comprehensive universities of every type and size.  All AAC&U members are required to be accredited by one of the regional accrediting associations. The organization has worked in partnership with these associations in clarifying the core purposes of college learning in the twenty-first century and in testing and advancing best practices for fostering, documenting, and reporting on students’ learning in college.

The White paper released by the committee identifies a range of issues related to accreditation that might warrant reforms to the process of assuring the quality of higher education institutions that have access to federal funds.  Other associations and the accreditors are responding in detail to these proposals.  In concert with these colleagues, we strongly oppose the proposal to uncouple accreditation from institutional eligibility for federal student aid.  Eligibility to receive federal aid should remain tied to quality assurance, both in principle and in practice. 

My response goes only to the issue at the heart of accreditation: accreditors’ responsibility for ensuring that students have equitable access to, and demonstrably achieve, the core components of a high- quality, twenty-first century college education. 

In this context, I urge the committee to prioritize first and foremost the goal of ensuring that all college students participate in high-quality programs that are well-designed to advance a set of essential learning outcomes—sometimes called proficiencies, or cross-cutting competencies—and that accredited institutions make visible their commitment to these learning outcomes and students’ demonstrated achievement of them.  I agree, therefore, with the suggestion in the White Paper that the process of recognizing accreditors could be streamlined to focus more directly on those issues related to “institutional quality and improvement.”  I also strongly recommend that you not set up separate entities for ensuring the quality of stand-alone courses, or sub-components of courses.  Courses and other learning experiences, such as practicums, should be evaluated in the context of degree programs and pathways, with particular attention to the learning outcomes those programs are designed to foster.  It is, frankly, a recipe for disaster to fragment further students’ learning experiences by multiplying the range of “guarantors” for particular parts of degree-related learning.

One particular feature of the current system that is essential to preserve is the designation of appropriate roles related to institutional mission setting and articulation of student learning goals.  Any reforms should keep the role of quality assurance in the hands of institutions of higher education and their membership accrediting organizations rather than shifting those roles into the hands of US Department of Education staff members or some other entity yet to be envisioned, and certain to be costly.

It is not the role of the US Congress or of officials in the Department of Education to legislate on how institutions of higher education should define, ensure, or document quality learning. 

However, it would be appropriate to charge recognized regional accreditors, discretely and as a community, to make good use of the recently achieved broad consensus about learning outcomes and the requisite component elements of a quality college degree.  Several non-governmental organizations and philanthropies (including AAC&U, Lumina Foundation, and several of the regional accrediting organizations) have already come together to articulate an emerging consensus framework on the quality of college degrees.  These efforts have resulted in a widely adopted set of Essential Learning Outcomes developed first as part of AAC&U’s Greater Expectations project[i] and later tested and refined through AAC&U’s far-reaching and very broad-based initiative, Liberal Education and America’s Promise (LEAP).[ii] 

The Degree Qualifications Profile released by Lumina Foundation in October, 2014, built on these earlier national projects and reflects a broad consensus set of outcomes and related educational and assessment practices aligned with current educational and economic research.[iii]   Several of the regional accreditors were directly involved in testing a beta version of the Degree Qualifications Profile and in identifying ways to strengthen it.

Employers have repeatedly expressed their own desire to see that graduates possess these learning outcomes in order to succeed and contribute in the workplace.[iv]

In other words, there now exists a wide consensus across higher education and between educators and employers on the component elements and key learning outcomes of a quality college degree—at the associate and bachelor’s level.  (See attachment for a snapshot of these component elements.)  There also exist tools showing institutions how to design degree programs, both in general education and in major fields, that translate this consensus into guided pathways for students’ successful achievement of the expected learning. 

Recognized accreditors could make good use of these consensus outcomes and be charged with independently developing their own processes for ensuring that students in accredited institutions are provided with clear roadmaps to consensus learning outcomes; that curricula are mapped to a clear set of learning outcomes; and that multiple, proven assessment methods are used—with results made public—to assess the degree to which students are achieving institutional and major-specific learning outcomes.

Currently, the regional accreditors do not use either publicly understandable language or a common language to help stakeholders see what they mean by quality learning.   The work done over the past decade on quality learning outcomes positions accreditors to redress this weakness in their role as guarantors of quality.

I am by no means recommending a “one-size-fits-all” approach to the curriculum or to students’ demonstration of learning outcomes.   While everyone agrees that all students need to develop critical thinking, quantitative reasoning, ethical reasoning, problem-solving, intercultural communication, and other core proficiencies in college, these learning outcomes will take quite different forms in, for example, an engineering program vs. a teacher education program. Accordingly, approaches to teaching and to assessing these capacities will remain, appropriately, in the hands of institutions and educators who work directly with students. 

What I am recommending is that we make these widely shared expectations concerning essential learning outcomes known to the public, known to students, and central both in the review of program design and in practices related to the assessment of student learning outcomes.

These recommendations are consistent with AAC&U’s Board of Directors’ statement, “Our Students’ Best Work: A Framework for Accountability Worthy of Our Mission,” released in a second edition in 2008.  In that statement, the AAC&U Board of Directors affirmed that “the public has questions about the quality of education that colleges and universities are providing, and it deserves to know how well students are doing.  It is time for leaders of education to embrace a set of highly valued and widely affirmed educational goals, establish high standards for each, and assess their achievement across the curriculum.” 

Modifications to the current recognition process should advance this approach while continuing to leave important decisions about curricular and assessment design to educators, faculty members, and institutions of higher education.  As we noted in our earlier statement, “The outcomes recommended here can and will be achieved in different ways, across highly diverse institutional contexts and fields of study.  But these forms of learning are important for all students and should be fostered across the entire educational experience.”[v]


[i] See Taking Responsibility for the Quality of the Baccalaureate Degree (Washington, DC: AAC&U 2004).

[ii] See College Learning for the New Global Century (Washington, DC: AAC&U 2007).

[iii] See The Degree Qualifications Profile (Indianapolis: Lumina Foundation 2014).

[iv] See Falling Short? College Learning and Career Success (Washington, DC: AAC&U 2015).

[v] See Our Students’ Best Work: A Framework for Accountability Worthy of Our Mission (Washington, DC: AAC&U 2008).