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History and Context of Accreditation in the United States
| Also refer to: Overview of Accreditation in the United States |
In the United States, institutions of higher education are permitted to operate with considerable independence and autonomy. The United States has no Ministry of Education or other centralized federal authority exercising control over the quality of postsecondary educational institutions, and the states assume varying degrees of control over education. As a consequence, American educational institutions can vary widely in the character and quality of their programs. To ensure a basic level of quality, the practice of accreditation arose in the United States as a means of conducting nongovernmental, peer evaluation of educational institutions and programs. With the passage of the HEA in 1965, Congress expanded the role of accrediting agencies by entrusting them with ensuring academic quality of the educational institutions at which federal student aid funds may be used subject to oversight by the federal government through the recognition process. Private educational associations have adopted criteria intended to reflect the qualities of a sound educational program and have developed procedures for evaluating institutions or programs to determine whether or not they are operating at basic levels of quality. Although accrediting agencies promulgate standards to ensure institutional quality, agencies have no legal control over educational institutions or programs.
Under the HEA, the Department does not have the authority to recognize accrediting agencies for the accreditation of private or public elementary and secondary schools. If an accrediting agency which is recognized by the Department for higher education also accredits elementary and secondary schools, the Department's recognition applies only to the agencies' accreditation of postsecondary institutions or programs.
Some Important Functions of Accreditation
- Assess the quality of academic programs at institutions of higher education
- Create a culture of continuous improvement of academic quality at colleges and universities and stimulate a general raising of standards among educational institutions
- Involve faculty and staff comprehensively in institutional evaluation and planning
Note: Accreditation does not provide automatic acceptance by an institution of credit earned at another institution, nor does it give assurance of acceptance of graduates by employers. Students should contact the receiving institution to help determine whether credits are transferrable. Acceptance of credit or graduates is always the prerogative of the receiving institution or employer. For these reasons, besides ascertaining the accredited status of an institution or program, students should take additional measures to determine, prior to enrollment, whether their educational goals will be met through attendance at a particular institution. Those measures should include inquiries to institutions to which transfer might be desired or to prospective employers, as well as any private or governmental entity responsible for licensing or certifying graduates to work in the field for which the educational program is intended.
Primary Accrediting Activities
- Standards: The agency, in collaboration with educational institutions and/or programs, establishes standards.
- Self-study: The institution or program seeking accreditation prepares an in-depth self-evaluation report that measures its performance against the standards established by the agency.
- On-site evaluation: A team of peers selected by the agency reviews the institution or program on-site to determine first-hand if the applicant meets the established standards.
- Decision and publication: Upon being satisfied that the applicant meets its standards, the accrediting agency grants accreditation or preaccreditation status and lists the institution or program in an official publication with other similarly accredited or preaccredited institutions or programs.
- Monitoring: An accrediting agency monitors each accredited institution or program throughout the period of accreditation granted to verify that it continues to meet the accreditor's standards.
- Reevaluation: The agency periodically reevaluates each institution or program that it lists to ascertain whether continuation of its accredited or preaccredited status is warranted.
Types of Accreditation
There are two basic types of educational accreditation, one referred to as "institutional" and the other referred to as "specialized" or "programmatic."
Institutional accreditation applies to an entire institution, indicating that each of an institution's parts is contributing to the achievement of the institution's objectives.
Specialized or programmatic accreditation normally applies to programs, departments, or schools that are parts of an institution. The accredited unit may be as large as a college or school within a university or as small as a curriculum within a discipline. Most of the specialized or programmatic agencies review units within an institution of higher education that is accredited by an institutional accrediting agency. However, certain agencies also accredit professional schools and other specialized or vocational institutions of higher education that are freestanding in their operations. Thus, a "specialized" or "programmatic" agency may also function in the capacity of an "institutional" agency. Some of these "institutions" are found within non-educational settings, such as hospitals.
The Accreditation Group (AG)
The Accreditation Group has been established within the Department of Education to deal with accreditation matters. Located in the Office of Postsecondary Education, the Group carries out the following major functions with respect to accreditation:
- Continuously reviews standards, policies, procedures, and issues in the area of the Department's accreditation responsibilities.
- Administers the process by which accrediting agencies and state approval agencies secure initial and renewed recognition by the Secretary.
- Serves as the Department's liaison with accrediting agencies and state approval agencies.
- Consults with institutions, associations, state agencies, other federal agencies, and Congress regarding accreditation.
- Interprets and disseminates policy relative to accreditation issues for the Department.
- Conducts appropriate research and investigates complaints against recognized accrediting agencies and state approval agencies.
- Interacts with the NACIQI during the recognition process. Also provides limited administrative support to NACIQI members.
- Works directly with the National Committee on Foreign Medical Education and Accreditation. Also provides administrative support to NCFMEA members. AG staff reviews the medical education standards used in foreign countries for comparability with the medical education standards used to accredit medical school in the US.
- AG staff reviews applications (6) foreign veterinary accrediting agencies to determine if their accreditation standards are acceptable.
- AG staff also periodically reviews military degree programs in accordance with Federal degree granting authority regulations.
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Summary of the Recognition Process for Accrediting Agencies
The process for the recognition of accrediting agencies is set forth in 34 CFR Part 602 Subpart C. Summary of the application and recognition process is provided below.
Accrediting agencies desiring recognition by the Secretary of Education must apply and demonstrate their compliance with the criteria for recognition set forth in 34 CFR Part 602 Subpart B. An accrediting agency's application for recognition generally consists of a statement of the agency's requested scope of recognition, evidence of the agency' compliance with the criteria for recognition set forth in part 602, and supporting documentation (state approval agencies are review using different criteria).
An agencies' application for initial recognition or renewal of recognition consists of a narrative statement, organized on a criterion-by-criterion basis, showing how the agency complies with the regulatory criteria. Depending on the recognition criterion, the narrative may be detailed or streamlined, and in all cases must be accompanied by clearly referenced supporting documentation demonstrating that the agency meets the requirement. Below is an example of some (not all) of the documentation that agencies must include to support its application for renewal and initial accreditation:
- Accreditation standards and procedures
- Operational policies and procedures
- Most recent externally audited financial statement.
- Published list of accredited institutions or programs.
- Self-study guidelines
- Guidance and training materials for on-site evaluation team members
- Sample completed self-studies.
- Sample on-site evaluation reports
- Sample institution or program responses to on-site evaluation reports
- Sample minutes of decision meetings, and decision letters
- Agency's constitution and bylaws
- List of complaints received by the agency against accredited programs or institutions.
Application for Initial Recognition
Recognition is granted by the Secretary to an agency that meets certain federal eligibility requirements and can demonstrate compliance with all of the criteria for recognition, establishing through its accrediting actions and decisions that it is a reliable authority regarding the quality of education offered by the institutions or programs it accredits. The Accreditation Group accepts applications for initial recognition after consultation and based on workload.
Agencies seeking initial recognition should contact the AG to discuss the basic eligibility requirements and the application process. If the Department staff believes the accreditor meets the basic eligibility requirements, the agency will be provided with the information needed to submit an application through the Department's electronic system.
To request consideration at a particular meeting of the NACIQI, an agency seeking initial recognition must submit its application as directed by the AG.
An agency considering applying for initial recognition is encouraged to contact the Accreditation Group as early as possible to discuss its possible application and to afford staff the opportunity to observe several accreditation activities and to conduct file reviews. Because observation of an agency's on-site evaluations and decision meetings by staff is a critical component of the review of the agency's application, it is imperative that an agency seeking initial recognition submit a list of scheduled evaluations and decision meetings with its application for recognition. If an agency does not provide AG staff with an opportunity to observe an adequate number of on-site evaluations, decision meetings (typically 2-3 of each), and file reviews before the NACIQI meeting at which the agency requests consideration of its application, AG staff will not finalize the agency's application for initial recognition.
Agencies seeking initial recognition are reminded that recognition by the Secretary is not a prerequisite for an accrediting agency to function as an accrediting body, i.e., an agency does not have to obtain federal recognition before it begins to accredit institutions or programs. An agency seeking recognition must demonstrate that its accreditation is a required element in enabling at least one of the institutions or programs it accredits to establish eligibility to participate in one or more federal programs. Beyond that basic eligibility requirement, a new agency will need to have had at least two years' experience functioning as an agency - establishing standards, evaluating institutions or programs for compliance with those standards, and making accrediting decisions based on those standards - before it submits its application for recognition. Staff will also consider whether the new agency has been organized under conditions that reasonably ensure its stability and permanence.
Application for Continued Recognition
Accrediting agencies that have been granted recognition by the Secretary are officially notified of the expiration date of their recognition period in a letter each time recognition is granted or renewed. They should plan to submit their applications for renewal of recognition approximately two years (new regulatory requirement) in advance of the summer or winter meeting of the NACIQI that precedes that expiration date. As with the initial application, Accreditation Group observation of accrediting activities (e.g., decision meetings, on-site evaluations, file reviews, etc.) is an important component of the renewal process.
Staff Analysis of an Agency's Application
The application review process conducted by the Department includes analysis of the application and observation of some of the agency's on-site evaluations, decision-making activities by AG staff. AG Staff members will conduct file reviews. AG staff may hold meetings with agency staff. AG staff may also conduct interviews with other persons and organizations concerning the agency's approval process in order to obtain further information relating to the agency's compliance with the Criteria for Recognition. Department staff then prepares a written analysis of the agency's application for recognition, which includes a recommendation on recognition.
Hearing Before the Advisory Committee
When Department staff completes its evaluation of an agency's application for recognition, the agency's application is placed on the meeting agenda of the NACIQI. NACIQI is a federal advisory committee that operates according to the requirements of the Federal Advisory Committee Act. Its 18 members are appointed equally by the Secretary, House of Representatives, and the Senate. In preparation for the meeting, NACIQI is provided with the agency's application and supporting documentation; the final AG staff analysis of the application; the AG staff's recommendation on recognition; all information relied upon by AG staff in developing the analysis. Any response by the agency to the draft staff analysis, and any written third-party comments the Department timely received about the agency and agency response to the third-party comments.
NACIQI meets at least twice a year to review applications for recognition submitted by accreditors. The usual times for NACIQI meetings are summer (July) and winter (February). Each member of NACIQI receives every AG staff analysis of an application for recognition and all the other materials mentioned in the preceding paragraph. The Executive Director of NACIQI usually assigns two or more individuals to serve as principal readers for each application.
An agency that applies for recognition is invited to make an oral presentation before the NACIQI. NACIQI also hears oral presentations from third parties who request to be heard. Department staff is available throughout NACIQI meetings to respond to questions. NACIQI conducts its business in public, and a transcript of the proceedings is made.
Determination by the Senior Department Official
After each meeting, NACIQI's and Department staff's recommendations concerning recognition are forwarded to the Senior Department Official, who makes the decision regarding recognition. An agency that disagrees with the decision of the Senior Department Official may appeal to the Secretary. The Secretary's decision can also be contested in the Federal court. Agencies may be granted initial recognition or renewal of recognition for a period of up to five years (four years for state approval agencies).
Application for an Expansion of Scope
An application for expansion of an agency's scope of recognition may be included as an integral part of an application for renewal of recognition or it may be submitted separately. If an expansion of scope is sought prior to the agency's next regularly scheduled review, accrediting agency personnel should consult with the Accreditation Group staff concerning the application format.
The State Liaison team within the Accreditation
The State Liaison team within the Accreditation Group is composed of four currently assigned Accreditation Group analysts, and have the following responsibilities:
- Provide technical guidance to state officials on the Higher Education Act of 1965 as amended (HEA) and Department regulations in 34 CFR §§ 602 and 603.
- Participate in meetings and conferences designed to promote and advance dialogue with state higher educational organizations regarding state and federal statutory and regulatory. requirements governing authorization, licensure, and accreditation of Title IV institutions.
- Respond to routine controlled correspondence, and phone inquiries from state officials, and coordinate with the appropriate staff analyst or ED office.
- Identify higher education issues that needed to be brought to the attention of the Assistant Secretary for Postsecondary Education and initiating public forums for discussion and dialogue among members of the higher education community.
- Build and/or update a directory which would list each state's key higher education staff (including SHEEOS), and state licensure officers along with their contact information.
- Work closely with state officials and accrediting agencies on school closures regarding the following:
- Adequacy of teach-out plans and teach-out agreements.
- Confer with state officials and accrediting agencies regarding the status of institutions included in teach-out plans and agreements.
As a courtesy obtain information from state officials regarding student records and where student records are stored for the closed institution.