ACTA is an independent, non-profit organization committed to academic freedom, excellence, and accountability at America's colleges and universities.

ACTA is an independent, non-profit organization committed to academic freedom, excellence, and accountability at America's colleges and universities.

ACTA is an independent, non-profit organization committed to academic freedom, excellence, and accountability at America's colleges and universities.

ACTA President Addresses Department of Education Session on Accreditation

September 6, 2018 by Doug Sprei

WASHINGTON, DC—ACTA President Dr. Michael Poliakoff today urged the U.S. Department of Education to act on reforming the nation’s system of accreditation, citing declining confidence in higher education, alarming tuition costs, and poor student outcomes.

Below is the full statement made in this morning’s session for the Department of Education’s Negotiated Rule Making on Accreditation.


"First, I want to thank you for convening this rule-making session on the issue of accreditation.  Accreditation is, without question, among the most important challenges to improving the American higher education system.

"The concerns with the current system are numerous, and transcend partisan and ideological lines.  In a moment when public confidence in higher education seems to be slipping, it has rarely been more important that quality assurance mechanisms function as they should.  At the same time, it is crucial that institutional autonomy be protected, and that institutions are allowed to perform their missions as defined by their charters and boards of trustees.   It has been said that the genius of the American higher education system is that it is not a system—the diversity and decentralized nature of American higher education has historically been one of its primary strengths. 

"Though the regional accreditation system has historically been a means to balance these considerations, it has become clear that the current system falls very short on both counts. 

"On one hand, several recent studies have shown that, despite the massive increase in the cost of higher education, many students are failing actually to learn much from the college experience—yet the institutions that have ostensibly taught them remain accredited and in good standing.

"On the other hand, the accreditation process often proves onerous and wildly expensive for institutions, while failing to guarantee quality.  But of even more concern is the threat that accreditors often represent to institutional autonomy and mission.  Though the Higher Education Act specifies ten standards by which institutions are to be assessed for the purpose of receiving Title IV funding, a loophole in the law allows accreditors to impose standards beyond those ten.  An elastic clause, 20 U.S.C. 1099b(g) allows for overreach way beyond the statutory mission of guaranteeing an education of quality. Many institutions have found themselves on notice from their accreditor because of internal governance issues—which are not among the specified standards. Examples are the treatment of Thomas Aquinas College and its storied great books program, Westminster Theological Seminary, and Gordon College. Even as we speak, the Higher Learning Commission, which accredits higher education institutions in 19 states, is considering a proposed change in its standards that could threaten religious institutions’ ability to carry out their mission.

"Ideally, this elastic clause would be fixed legislatively, but there are measures that can be taken in regulation.  Specifically, the department should clarify that accreditation for the purpose of access to Title IV funds may only be connected to the ten standards enumerated in the law.  Accreditors, as private and voluntary membership organizations, are of course free to impose any standards they would like—but these arbitrary standards should not threaten the ability of institutions to exist or function due to a loss of Title IV funding streams.

"Our storied colleges and universities need a system of quality control focused on outcomes,  not intrusion into the prerogatives, mission – and, indeed, liberty of America’s diverse institutions."