Liberal Education

Quality Assurance and Accreditation in Challenging Times: Examining Priorities and Proposed Reforms

For at least two decades, educators, employers and policymakers have confronted an increasingly urgent global hunger for talent—a demand for better-educated workers and more enlightened citizens. Higher education institutions and various oversight entities at the state and federal levels have attempted to respond to this rising demand for education by focusing on policies and practices that support increased graduation rates and improve efficiency.

These considerable efforts notwithstanding, however, current criticism of higher education in general has continued and, most recently, has been directed particularly at the issue of student employability: “whether colleges are graduating students with the skills they need to get jobs and repay their loans.”1 Executive actions announced in November 2015 clarified such expectations explicitly and brought them to bear on the accrediting organizations charged with assuring the quality of higher education institutions eligible to receive federal student aid. Under Secretary of Education Ted Mitchell, quoted in Inside Higher Ed, described the actions as one way of saying to accreditors “‘we’re paying attention to this with renewed vigor and that it’s going to matter’ whether they focus more intently on student outcomes.”2

The White House announcement was only the latest in a series of pronouncements about the effectiveness of higher education, particularly with respect to student preparedness for success in the workplace. Unfortunately, it contributes to a disturbing trend that views higher education almost exclusively in terms of preparing students for remunerative entry-level positions in select fields.

By contrast, for more than a decade, employers have been asking tough but appropriately wide-ranging questions not only about how many college graduates the system generates, but also about how well our nation’s colleges and universities are preparing them to succeed in and contribute to a changing global workplace and society. Business leaders have persistently expressed frustration that college graduates are not achieving the broad, cross-cutting learning outcomes they need at high enough levels to fuel a technology-rich, innovation-driven economy.3 They have also complained that transcripts, resumes, and other forms of documented student learning and credentialing do not provide information enabling those outside the academy to understand clearly what students are learning in college. They don’t know what a specific degree or credential signifies in terms of learning.

Given how much more important a highly educated citizenry is becoming to our nation’s economic and democratic vitality, it is not surprising that policymakers at both the state and federal levels have been setting new priorities, enacting new policies, and proposing reforms. But all too often, as business leaders have expressed their concerns about quality and actual learning outcomes, policymakers have been focusing more on access, affordability, completion and attainment rates, and, more recently, average salaries. While these indicators deserve the attention they are receiving, focusing exclusively on them represents a narrow, utilitarian, and ultimately counterproductive view of education in general and of higher education in particular.

Perhaps ironically, the November 2015 executive actions, while reflecting this limited perspective, offer grounds for hope. By directing attention to accreditation, rather than to a circumscribed set of metrics, they invite a response that embodies respect for higher education in all its complexity and that embodies an appreciation for what students need in order to achieve successful careers and satisfying lives as informed and alert citizens. No one can quarrel with the interest in assuring that, as we graduate more students and implement new approaches to workforce training, new forms of online learning and credentialing, and new educational pathways, we serve students more effectively as we assure the public that educational experiences are of high quality. Those are precisely the priorities of accreditation.

If policymakers take this issue seriously, avoiding hackneyed sound bites (“accreditation ignores student learning”; “accreditation inhibits innovation”) in favor of serious analysis, it may be possible to develop a more productive approach to quality assurance and a better system of accrediting institutions of higher education as guarantors of quality and vehicles for student learning and empowerment.

The potential for productive change

In what follows, we examine the potential for productive change and describe both what we see as promising potential reforms and what we believe might be risky policy directions. We approach these issues in light of two realities. One is the current accreditation system and how it does and does not meet contemporary needs. The second is the movement that has been underway for several decades within higher education to take seriously “learning outcomes”—clarifying what they are, and designing ways to advance and assess them.

A recent blog posting published by The Hill indicates what is at stake and suggests that some policymakers may, indeed, turn their attention to placing meaningful data on learning outcomes at the center of policy reforms. The author notes that, “For all the rhetoric and angst about increasing college prices, the dirty little secret of higher education is that a college degree doesn’t actually represent any particular set of knowledge or skills. We have no idea what our nation is getting—substantively—in exchange for an enormous public investment in higher education and constantly rising private tuition. Do students leave with just a piece of paper or do they leave intellectually with something appreciably greater?”4 This question lies at the heart of both accreditation reform and the learning outcomes movement.

Accreditation: The pressure to reform—or replace

In an interview published in the Chronicle of Higher Education, Judith Eaton, president of the Council on Higher Education Accreditation, describes the current scrutiny of accreditation as “not new, but . . . more intense and more focused.”5 The principal object of this focus is the system of regional accreditation: six commissions evaluate and “accredit” institutions of higher education in their respective geographical areas. The familiar process of institutional self-study, peer evaluation, and commission action has evolved over more than a century to affirm the educational quality of institutions, prompt their improvement, and confer eligibility for federal funding.

In some respects, the system works well. Unlike regulatory processes in most of the rest of the world, US higher education accreditation is independent of governmental influence, it operates economically, it provides numerous platforms for the spread of innovations, and its reliance on peer review—deans and professors evaluating deans and professors, essentially—has helped preserve the diversity of US higher education, from prestigious research institutions to small Bible colleges.

There’s clearly much to admire. Why, then, the “more intense and more focused scrutiny”?

The pressure to reform or replace accreditation has been growing for more than a decade. The Commission on the Future of Higher Education, the American Council of Trustees and Alumni (ACTA), and the Center for College Affordability and Productivity have all published demands for radical reform.6  Accreditation: A Call to Action for College Trustees, a 2013 ACTA pamphlet, advances many of the concerns others have also voiced:

  • “Accreditation is very costly.”
  • “Accreditors are monopolies.”
  • “Accreditation is rife with conflicts of interest.”
  • “Accreditors interfere with trustee rights.”
  • “Accreditation is no guarantor of quality.”
  • “Accreditation impedes transfer.”
  • “Accreditation stifles innovation.”

Many of these concerns, and especially the last one, motivated US Senators Marco Rubio (R-FL) and Michael Bennet (D-CO) in fall 2015 to propose legislation that would “create a voluntary, alternative [sic.] system of accreditation.” According to the press release from Senator Bennet’s office, such a system could take the place of a “burdensome input-focused accreditation process.” The release quotes Senator Rubio: “We must end the status quo accreditation cartel that stifles competition, encourages soaring tuition costs and limits opportunities for non-traditional students, such as working parents.”7

A few days after the bill was announced, the Wall Street Journal weighed in with an editorial headlined, “Trust Busting Higher Ed.” Commending the Rubio-Bennet bill, the Journal thought it timely that “an obscure network of higher-ed busybodies known as accreditation agencies” would be revealed to the world. “More politicians should study up on how to reform this racket,” said the editorial. Why? According to the Wall Street Journal, the system has become a “cartel” complicit in and perhaps even responsible for tuition increases, grade inflation, the suppression of innovation, and poor student preparation.8

Are radical reforms the answer?

Some reforms clearly are overdue so far as higher education accountability and quality assurance are concerned. In terms of accreditation, with six different commissions operating within their respective geographical regions, each with its own criteria, procedures, and vocabulary, it should not be surprising that there is little understanding of accreditation among the public or, for that matter, within the academy itself. Greater consistency from one region to another, achieved through the elimination of trivial differences in protocol and procedure, would enable accreditation to explain itself far more effectively to its various stakeholders. Greater gains in efficiency lie within easy reach. Accreditation can become far more agile and welcoming of creativity. Accreditors could build on the progress in the learning outcomes movement. They could publish information that facilitates comparisons among institutions and programs without resorting to crude rankings.

But the reforms that have been proposed, which largely fail to acknowledge the considerable progress accreditation has already made, offer approaches to quality assurance and institutional improvement that could well prove less reliable than the current system. A glance back at earlier experiments with alternatives to regional accreditation, such as the disastrous state-by-state approach to providing initial oversight for the GI Bill, could offer a timely caution. Similarly, the dismal performance of many for-profit institutions in the early 1990s was attributed in part to their “accreditation” by organizations hastily cobbled together for the purpose.

The even greater risk in the Rubio-Bennet proposal and the earlier proposals mentioned above is that they could further what Carol Geary Schneider, president of the Association of American Colleges and Universities (AAC&U), described in a letter to the editor of the New York Times as “a narrowing of the American dialogue about the purposes of higher education over the last two decades.”9 Her letter expressed concerns with regard to the “College Scorecard” announced in September 2015, but those concerns arise no less from proposals for “accreditation alternatives.”

The Rubio-Bennet bill may or may not survive Congressional scrutiny—few bills do. But it is worth a look if only because it prompts precisely the concerns Schneider expresses. For instance, the bill’s invidious distinction between “new ways people can learn and acquire skills” and “the traditional four year college degree track” reinforces the outdated narrative that “skills,” quickly obtained and promptly exercised in entry-level positions, may be all that many students need to obtain “good paying jobs.” And it can lead to the kind of divisive (and erroneous) challenge that Sen. Rubio offered during the November 10 Republican presidential primary debate and reiterated immediately afterwards on Twitter: “Welders make more money than philosophers. We need more welders and less [sic.] philosophers.”10

Doubtless, the United States needs competent welders, whether or not they earn more than philosophers. (They don’t.) But at a time when employers are demanding precisely the kinds of high-level problem-solving capabilities that effective undergraduate education should develop—adaptability, an aptitude for continued learning, the ability to create through consultation—the enthusiasm for reducing higher education to a narrow compass of practical skills and for “innovative providers” promising a fast track to entry-level employment deserves careful scrutiny.

The opportunity for genuine reform

Skepticism with regard to the chorus of calls for radical change should not imply an aria in favor of the status quo. Accreditation needs to change—significantly—and its time in the spotlight can be turned to good effect. But for that to happen, educators, students, opinion makers, and political leaders must focus more resolutely on what’s most important to high-quality undergraduate education, namely, student learning. Not “the books in the library.” Not the outdated indictments about the suppression of innovation or the sensationalist rhetoric of “cartel” and “gang.” Not the dubious allure of untested alternate providers. What is needed above all—both for higher education in general and for liberal education in particular—is the expectation, framed by accreditors and embraced by colleges and universities, that every institution, every degree program, and, indeed, every course will define learning objectives that are explicit, understandable, demonstrable, and assessable.

There are many other important contributors to this priority, to be sure. If the expectations of accreditors are to prove constructive, higher educators must respond to them cognizant of important resources, aware of research, and committed to greater student success. State systems, coordinating boards, higher education associations, specialized accreditors, opinion leaders, and statespersons must play a role. But the fact is that despite all the issues that have been raised and all the alternatives that have been advanced, regional accreditation remains the most effective lever for bringing about significant change in higher education in terms of assuring quality and protecting students. Yes, that lever must be deployed with far greater coherence and coordination, and its use must express pursuit of the most pressing priorities. But it is still the most useful tool we have.

The importance of learning outcomes

Colleges and universities have been publishing broad goals and learning outcomes in one form or another for many years. But as any quick review of catalogs and websites will suggest, such outcomes are often abstract, aspirational, predictably vague, and signally forgettable. There are some exceptions, to be sure, but they are just that—exceptions. In contrast to the “learning goals” that may express what institutions wish for their students to achieve, what is needed instead are outcomes that students can understand, that faculty members can use in structuring their courses, and that institutions can cite in affirming their graduates’ proficiencies to employers and graduate schools. Such outcomes, to the extent that they are explicit, understandable, demonstrable, and assessable, can provide essential prompts for curricula that are coherent and cumulative, encourage student persistence, and offer a platform for programmatic and institutional accountability. These carefully delineated and assessed outcomes must become the most important priority in any new reforms of policy and any new approaches to quality assurance.

Fortunately, the development of such outcomes, institution by institution in response to differing missions, areas of strength and focus, and student needs, no longer must take place in a vacuum. Important resources such as AAC&U’s LEAP Essential Learning Outcomes and Lumina Foundation’s Degree Qualifications Profile have been developed consultatively and refined through wide experience. (Both are described below.) They not only offer convenient points of departure for the task at hand. Their use can ensure that outcomes address assessable student demonstration of attainment; clearly reference the importance of integrative, cross-disciplinary study; and include both applied and “liberal” learning.

Such resources have emerged as part of the broader “learning outcomes” movement. That movement has been fueled not only by external pressures, but also by educators who have been concerned—especially in the face of changing demographics and changing patterns of college attendance—about the intentionality of curricular pathways and the actual levels of learning our institutions are providing to students. As early as 2002, a national panel convened by AAC&U noted that, “In their progression toward a degree, large numbers of students enroll at two, three, or more institutions, also taking courses online. For them college can be a revolving door. In the past, students relied on one institution to provide degree programs and, they hoped, to deliver a logically sequenced education. While coherence may have been illusory even then, newer attendance patterns place greater responsibility on students themselves to create meaningful learning from a supermarket of choices.”11

More recently, AAC&U published The Quality of a College Degree: Toward New Frameworks, Evidence, and Interventions, which demonstrates that this trend toward student swirl has only increased. The report calls on institutions and systems of higher education across which students are swirling to collaborate on clarifying expected learning outcomes and demonstrating students’ achievement as they progress: “It is time now to build on the momentum of current efforts to improve curricular design and learning outcomes assessment, time to reclaim and redirect the national dialogue about what matters in college. This must be done in ways that honor the distinctive missions of individual institutions and that ensure all students are well served by higher education.”12

These pressures and concerns all have driven a steady increase in attention to how we define and develop learning outcomes and how we measure how well students are actually achieving them in and across all kinds of institutions. Goals for degree completion, such as those of President Obama and of Lumina Foundation,13 set important objectives for providing many more Americans with high-quality credentials, but such goals are meaningless unless “high quality” is defined.

How does that happen? Higher education institutions must understand more clearly the links between setting clear aspirational learning goals, assessing students’ actual learning and achievement, and tracking students’ progress toward completion. The clarity of such goals is key to students’ understanding of their own progress and, thus, to their motivation to stay engaged. A demonstrable connection between quality learning and persistence points to an important but often overlooked principle: students who know what they are expected to learn are likely to work more strategically and efficiently to accomplish their own “big goals.”14

Regional accreditation: The problem or the solution?

Is regional accreditation less concerned with student learning outcomes and less explicit in its expectations of accredited institutions than it should be? Or does regional accreditation remain our most promising avenue to achieving genuine reform in higher education through a developing consensus on such outcomes? The answer to both questions is, well, yes.

Regional accreditation has in one sense been a leading influence in clarifying expectations for clear statements of learning outcomes. For decades, regional accreditors have insisted that their member institutions identify clear learning outcomes for their students and that they follow a serviceable approach to gathering data and using those data to improve student achievement of such outcomes. In fact, as observed in Higher Education Accreditation: How It’s Changing, Why It Must, “accreditation has provided an important external motivation for what is routinely described as the ‘assessment movement.’”15

But there are several caveats. First, because of differences among the regional accrediting commissions, their influence has been inconsistent. Second, “accreditation has [also] been the beneficiary of a movement institutions and higher education organizations have embraced independently,”16 that emphasizing the importance of clearly defined outcomes. While a positive indicator in one respect, diverse institutional initiatives represent a further complicating factor in the quest for a workable consensus on a shared outcomes framework. Finally, while effective assessment requires evidence that specific learning outcomes are being accomplished, the degree of specificity required varies considerably from one accreditor to another. Regional accreditors may call for outcomes and define processes for assessing them, but they often shy away from mandates about specific knowledge and skill areas required for quality degrees.

A consequence of this complex picture is that, while many institutions of higher education may realize that they need to be more transparent about learning outcomes, they often undertake defining and assessing such outcomes through unique approaches that discourage comparisons. Further, rather than developing a clear statement of institutional outcomes, they may restrict their efforts to certain departments, programs, or schools. Of even more concern is a finding that the results of developing and assessing learning outcomes are rarely used to improve student learning.17

Regional accreditation clearly has an important role to play in clarifying expectations regarding the development of clear learning outcomes at every level—institutional, programmatic, departmental, course—according to widely recognized standards. Such expectations naturally include the use of such outcomes to assess and document student performance, to track student persistence, and to improve institutional performance. Further, the influence of the accreditors will become far more persuasive to the extent that they express such expectations according to a developing consensus.

In response to an invitation from the Bill and Melinda Gates Foundation, Peter T. Ewell of the National Center for Higher Education Management Systems has written a white paper titled “Transforming Institutional Accreditation in US Higher Education.” In it, he asserts repeatedly the critical importance of statements of what degree recipients should know and be able to do. The credibility of accreditation is at stake, certainly, but so too is the quality of certificate and degree programs. Ewell calls on accreditors “to map or otherwise justify their own core expectations for institutions with respect to learning outcomes to some kind of external reference point like the Lumina DQP or AAC&U’s LEAP outcomes.”18

Ewell also observes at several points that while reforms advanced by particular regional accreditors may be encouraging, real progress will depend on their continuing to find common ground with respect to processes, standards, and vocabulary—especially, we would emphasize, insofar as expectations for and standards governing learning outcomes are concerned. Fortunately, there is an impressive legacy of cooperation on which regional accreditors may draw. But much more remains to be done if the regional accreditors are to speak with one voice on learning outcomes.

Progress on many fronts

AAC&U began focusing attention on the clarity of learning goals and on ways to advance those goals as early as 2000, when it launched an initiative called Greater Expectations: The Commitment to Quality as a Nation Goes to College. With that initiative—which engaged not only educators, but also civic and business leaders—AAC&U began a long-term effort to work throughout higher education on the issue of learning outcomes. In the signature report issued as part of Greater Expectations in 2002, AAC&U noted that “the central question is simple: what should all students be learning in college? No matter their aspirations or prior preparation, what will all graduates require to lead personally fulfilling and socially responsible lives? What learning should result from an undergraduate education of quality, whether gained from study at a selective liberal arts college, an urban university, an open-enrollment community college for part-time adults, online courses, or a combination of them all?”19

AAC&U built on its work in Greater Expectations, which had involved dozens of colleges and universities that were leaders in intentionality about learning outcomes, when it launched the Liberal Education and America’s Promise (LEAP) initiative in 2005. Through LEAP, AAC&U has continued to test a set of what it came to call “Essential Learning Outcomes,” and has repeatedly documented strong agreement among employers and educators on cross-cutting outcomes such as critical thinking, problem solving with diverse peers, and communication skills. Hundreds of colleges and universities and eleven state systems or statewide consortia now have engaged with the LEAP initiative to clarify their own learning outcomes; to scale the use of evidence-based, high-impact educational practices; to align their curricular pathways with expected outcomes; and to develop effective and meaningful ways to assess students’ achievement of those outcomes.

In 2011, Lumina Foundation released the initial beta draft of the Degree Qualifications Profile (DQP), adding yet another important element to this national movement to clarify and measure student achievement of learning outcomes. The DQP was crucial because it clearly delineated levels of learning corresponding to specific degrees (AA/AAS, BA, and MA) and “got specific” about how students could and should develop and demonstrate their learning. The DQP applied the concept of learning outcomes to the actual design of educational programs.

Since its launch, LEAP has expanded to a large family of projects, including several designed explicitly around the DQP.20 And the DQP itself has been revised to reflect the experience gained through such projects. There is, in fact, widespread engagement with this effort to articulate learning outcomes and to demonstrate, clearly and publicly, the degree to which students are achieving them.

The risks—and opportunities ahead

Can the long-deferred debate over the reauthorization of the Higher Education Act (HEA) provide a platform for reasoned, well-informed discussion of the roles of accreditation and how accreditation might be strengthened? Perhaps. But polarization within Congress suggests that on this issue, as on others, the loudest voices expressing the most obdurate opinions may draw the most attention. If those voices prevail, we may exchange a system of quality assurance that has evolved over time to provide responsible oversight and incentives for improvement for some cobbled-together process managed by a cobbled-together agency.

The result of a clumsy, politically driven reform could be substantive growth in federal influence on higher education, a dramatic increase in the costs of accreditation, far less discriminating processes of review, and, over time, a diversion of scarce public resources to educational entities that add little, if anything, to students’ meaningful learning and long-term development. Instead of propelling improvements in attainment rates and quality learning, we could face a decline in the effectiveness of higher education, access to higher education, and diversity within higher education. In such an atmosphere, the “narrowing” of vision with respect to higher education would in all likelihood accelerate.

But an unprecedented convergence of factors—the presidential primaries, heightened public concern about college affordability, and the necessity for renewal of the HEA—means that higher education accreditation, if it is to survive in its present form, must document the improvements it has made, make clear its intent to make further improvements, and, in sum, manage a convincing response to those who “love to hate” the system. It remains to be seen whether that will happen. But even such advances would not suffice if genuine improvement is the object. The most constructive, influential, and, indeed, game-changing initiative accreditors could take on is the constructive reform found in the emphasis suggested above, namely, that of clarifying expectations concerning learning outcomes. No undertaking lies closer to the heart of the academic mission. And none has greater potential for informing public understanding and improving student success.

The higher education community as a whole must come together and seize this opportunity. We can take advantage of the remarkable progress made on learning outcomes and on the consensus about what really matters for success in today’s world in terms of learning. As Carol Geary Schneider makes clear in this issue of Liberal Education, the higher education community is poised and ready to provide specificity on quality learning in college. Accreditors, in partnership with their member institutions, must seize the high ground and lead the way. But the clock is ticking. And the time for action is upon us.


1. Michael Stratford, “Shaming Accreditors,” Inside Higher Ed, November 6, 2015,

2. Ibid.

3. See Hart Research Associates, How Should Colleges Prepare Students to Succeed in Today’s Global Economy (Washington, DC: Association of American Colleges and Universities, 2007); Hart Research Associates Falling Short? College Learning and Career Success (Washington, DC: Association of American Colleges and Universities, 2015); Gallup, What America Needs to Know about Higher Education Redesign (Washington, DC: Gallup, 2014).

4. Mary Nguyen Barry, “Is Our Children Learning?,” Congress Blog, The Hill, August 18, 2015, (emphasis added).

5. Goldie Blumenstyk, “What the Public Wants from Accreditation” (an interview with Judith S. Eaton), Chronicle of Higher Education, August 7, 2015,

6. See Secretary of Education’s Commission on the Future of Higher Education, A Test of Leadership: Charting the Future of US Higher Education (Washington, DC: US Department of Education, 2006); American Council of Trustees and Alumni, Why Accreditation Doesn’t Work and What Policymakers Can Do About It (Washington, DC: American Council of Trustees and Alumni, 2007); Andrew Gillen, Daniel L. Bennett, Richard Vedder, The Inmates Running the Asylum? An Analysis of Higher Education Accreditation (Washington, DC: Center for College Affordability and Productivity, 2010).

7. “Bennet, Rubio Propose Alternative to Accreditation that Shifts Focus to Student Success,” on Senator Michael Bennet’s official website, September 30, 2015,

8. “Trust Busting Higher Ed,” Wall Street Journal, October 4, 2015,

9. Carol Geary Schneider, letter to the editor, New York Times, September 21, 2015.

10. Marco Rubio, Twitter post, November 10, 2015, 6:12 p.m.,

11. Association of American Colleges and Universities, Greater Expectations: A New Vision for Learning as a Nation Goes to College (Washington, DC: Association of American Colleges and Universities, 2002), 2.

12. Debra Humphreys, Heather McCambly, and Judith Ramaley, The Quality of a College Degree: Toward New Frameworks, Evidence, and Interventions (Washington, DC: Association of American Colleges and Universities, 2015), 1.

13. See “Remarks of President Barack Obama—As Prepared for Delivery; Address to Joint Session of Congress,” White House, February 24, 2009,; Cliff Adelman, Peter Ewell, Paul Gaston, and Carol Geary Schneider, The Degree Qualifications Profile (Indianapolis, IN: Lumina Foundation, 2014).

14. See, for example, Thomas R. Bailey, Shanna Smith Jaggars, and Davis Jenkins, Redesigning America’s Community Colleges: A Clearer Path to Student Success (Cambridge, MA: Harvard University Press, 2015).

15. Paul L. Gaston, Higher Education Accreditation: How It’s Changing, Why It Must (Sterling, VA: Stylus, 2014), 124.

16. Ibid.

17. See George D. Kuh, Natasha Jankowski, Stanley O. Ikenberry, and Jillian Kinzie, Knowing What Students Know and Can Do: The Current State of Student Learning Outcomes Assessment in US Colleges and Universities (Champaign, IL: National Institute for Learning Outcomes Assessment, 2014).

18. Peter T. Ewell, “Transforming Institutional Accreditation in US Higher Education” (white paper, Bill & Melinda Gates Foundation, March, 2015), 19.

19. Association of American Colleges and Universities, Greater Expectations, 21.

20. For more information about the LEAP initiative, see

Debra Humphreys is senior vice president for academic planning and public engagement at the Association of American Colleges and Universities. Paul L. Gaston is Trustees Professor at Kent State University.

To respond to this article, e-mail, with the authors’ names on the subject line.

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