[House Hearing, 111 Congress]
[From the U.S. Government Publishing Office]
THE DEPARTMENT OF EDUCATION
INSPECTOR GENERAL'S REVIEW OF STANDARDS
FOR PROGRAM LENGTH IN HIGHER EDUCATION
=======================================================================
HEARING
before the
COMMITTEE ON
EDUCATION AND LABOR
U.S. House of Representatives
ONE HUNDRED ELEVENTH CONGRESS
SECOND SESSION
__________
HEARING HELD IN WASHINGTON, DC, JUNE 17, 2010
__________
Serial No. 111-67
__________
Printed for the use of the Committee on Education and Labor
Available on the Internet:
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COMMITTEE ON EDUCATION AND LABOR
GEORGE MILLER, California, Chairman
Dale E. Kildee, Michigan, Vice John Kline, Minnesota,
Chairman Senior Republican Member
Donald M. Payne, New Jersey Thomas E. Petri, Wisconsin
Robert E. Andrews, New Jersey Howard P. ``Buck'' McKeon,
Robert C. ``Bobby'' Scott, Virginia California
Lynn C. Woolsey, California Peter Hoekstra, Michigan
Ruben Hinojosa, Texas Michael N. Castle, Delaware
Carolyn McCarthy, New York Vernon J. Ehlers, Michigan
John F. Tierney, Massachusetts Judy Biggert, Illinois
Dennis J. Kucinich, Ohio Todd Russell Platts, Pennsylvania
David Wu, Oregon Joe Wilson, South Carolina
Rush D. Holt, New Jersey Cathy McMorris Rodgers, Washington
Susan A. Davis, California Tom Price, Georgia
Raul M. Grijalva, Arizona Rob Bishop, Utah
Timothy H. Bishop, New York Brett Guthrie, Kentucky
Joe Sestak, Pennsylvania Bill Cassidy, Louisiana
David Loebsack, Iowa Tom McClintock, California
Mazie Hirono, Hawaii Duncan Hunter, California
Jason Altmire, Pennsylvania David P. Roe, Tennessee
Phil Hare, Illinois Glenn Thompson, Pennsylvania
Yvette D. Clarke, New York [Vacant]
Joe Courtney, Connecticut
Carol Shea-Porter, New Hampshire
Marcia L. Fudge, Ohio
Jared Polis, Colorado
Paul Tonko, New York
Pedro R. Pierluisi, Puerto Rico
Gregorio Kilili Camacho Sablan,
Northern Mariana Islands
Dina Titus, Nevada
Judy Chu, California
Mark Zuckerman, Staff Director
Barrett Karr, Minority Staff Director
C O N T E N T S
----------
Page
Hearing held on June 17, 2010.................................... 1
Statement of Members:
Guthrie, Hon. Brett, a Representative in Congress from the
State of Kentucky.......................................... 4
Prepared statement of.................................... 5
Miller, Hon. George, Chairman, Committee on Education and
Labor...................................................... 1
Prepared statement of.................................... 3
Statement of Witnesses:
Manning, Sylvia, president, the Higher Learning Commission of
the North Central Association.............................. 12
Prepared statement of.................................... 14
McComis, Dr. Michale S., executive director, Accrediting
Commission of Career Schools and Colleges.................. 18
Prepared statement of.................................... 20
Tighe, Kathleen S., Inspector General, U.S. Department of
Education.................................................. 7
Prepared statement of.................................... 8
THE DEPARTMENT OF EDUCATION
INSPECTOR GENERAL'S REVIEW OF
STANDARDS FOR PROGRAM LENGTH
IN HIGHER EDUCATION
----------
Thursday, June 17, 2010
U.S. House of Representatives
Committee on Education and Labor
Washington, DC
----------
The committee met, pursuant to call, at 10:07 a.m., in room
2175, Rayburn House Office Building, Hon. George Miller
[chairman of the committee] presiding.
Present: Representatives Miller, Kildee, Andrews, Woolsey,
Hinojosa, McCarthy, Tierney, Kucinich, Holt, Bishop of New
York, Hirono, Altmire, Hare, Shea-Porter, Fudge, Polis, Titus,
Petri, Guthrie, and Roe.
Staff present: Jeff Appel, Senior Education Policy Advisor/
Investigator; Jody Calemine, General Counsel; Denise Forte,
Director of Education Policy; Jose Garza, Deputy General
Counsel; David Hartzler, Systems Administrator; Ryan Holden,
Senior Investigator; Sadie Marshall, Chief Clerk; Ricardo
Martinez, Policy Advisor, Subcommittee on Higher Education,
Lifelong Learning and Competitiveness; Bryce McKibbon, Staff
Assistant, Education; Alex Nock, Deputy Staff Director; Lillian
Pace, Policy Advisor, Subcommittee on Early Childhood,
Elementary and Secondary Education; Julie Peller, Senior
Education Policy Advisor; Alexandria Ruiz, Administrative
Assistant to Director of Education Policy; Melissa Salmanowitz,
Press Secretary; Ajita Talwalker, Education Policy Advisor;
Mark Zuckerman, Staff Director; Stephanie Arras, Minority
Legislative Assistant; Kirk Boyle, Minority General Counsel;
Amy Raaf Jones, Minority Higher Education Counsel and Senior
Advisor; Alexa Marrero, Minority Communications Director; Brian
Newell, Minority Press Secretary; Susan Ross, Minority Director
of Education and Human Services Policy; and Linda Stevens,
Minority Chief Clerk/Assistant to the General Counsel.
Chairman Miller [presiding]. The committee will come to
order. My apologies to the members and the witnesses; just some
last minute details that we had to take care of in preparation.
So then a quorum being present, the committee will come to
order, I am reminded by my staff. So a quorum is present, we
are in order. Here we go.
The Education and Labor Committee meets this morning to
examine reports from the Department of Education inspector
general looking at higher education accrediting agencies. The
inspector general's review focused on institution policies on
credit hours and program length.
As the cost of higher education and, subsequently, the
federal investment in student aid rise and more students go
into debt to finance their education it is critical that we ask
what students and taxpayers, as federal investors, are paying
for. This has been a priority of this committee for many years,
certainly intensely, I think, over the last 6 or 8 years as we
have seen dramatic increases in the cost of education, dramatic
increases in the rise of indebtedness of students who
participate in higher education.
And Mr. McKeon, on the Republican side of the aisle, has
been a hawk on this issue. Mr. Kline has taken up that call
also, Mr. Tierney and Mr. Hinojosa.
With the last reauthorization of the Higher Education Act
we tried to deal with issues like maintenance of effort to make
sure that we weren't putting federal money in at the top and
people were taking it out the bottom, although I think the
states are probably still doing that in a number of instances.
It is not bound by whether an institution is for-profit or
nonprofit, private or public; those haven't been the issues. It
has been a concern across the board and it has been echoed
across the country as commentators and others have worried
about the increased cost and the indebtedness of our students.
The I.G.'s report found that some accrediting agencies do
not have any established definitions of a credit hour, which
could result in inflated credit hours and misappropriation of
student aid. These are my conclusions, so I don't ask you to--
but I think the accrediting agency is sort of about the way it
should be, and we discover these problems and we fix them, and
we go back and forth on that.
I hope to be able to use this report and the responses back
and forth because I think they are representative of the
concerns and I think they are representative of what has been
the historical defense of the system that has worked, in many
instances, reasonably well, it appears.
But I must say that I am constantly inundated now from
members of Congress on both houses, on both sides of the aisle,
with the substantial increase in student aid that has been
appropriated and authorized over the last several years--about
how this aid is being used. I just want to impress upon people
that this is a concern that goes across the Congress at this
point.
And again, I think there is the tendency that people say,
``Well, you don't like for-profits,'' or, ``You like the old,
traditional way; you don't understand the future; you don't
understand inputs versus outcomes, seat time versus this.'' I
think this committee does.
But I think at the end of the day what we know is that the
system has to resolve itself in how we allocate federal
taxpayer dollars. And when students and families are borrowing
money, the system has to resolve itself in favor of
accountability and integrity, and that is our concern, and that
is why this is really an oversight hearing.
This isn't about a ``gotcha.'' This isn't about who is
right and who is wrong. I think that this particular episode--
when I read the report essentially by chance, it said to me,
``Here is a chance to look at this system and pull it apart a
little bit to make sure that we have some understanding of how
this is done.''
You know, we have worked to try to bring down the cost of
education for families by increasing the Pell Grant; we have
lowered the interest rates on student loans; we made it easier
for students and families to manage their debt with the income
based repayment system; we have allowed, under certain
circumstances, people to discharge their debt after 10 years,
or after 25 years, so that they can make career choices. But at
the end of the day we are still adding additional taxpayer
dollars to the system to provide that opportunity.
We see a system where certainly at the community college
level 1.5 million people showed up last year who hadn't been in
the system before because the economy dictated that they go and
try to acquire additional skills and talents and update their
skill sets. We see explosive growth in the for-profit system
that is meeting the demands and the requirements of many, many
students as they try to manage their obligations to work and
their ability to acquire additional skills and knowledge.
Much of this is new--relatively new, so to speak--and yet
we continue to have an accreditation system that appears to be
sort of the same as it was before, saying that we acknowledge
the newness and we are accommodating that. That is just my
impression; it is not a conclusion or to say that that is how
it is so.
And so I hope that we will be able to pull some of this
apart, or I hope that we will be able to continue this inquiry,
because I think we have to provide answers to taxpayers, to
families, to students, and to the institutions of what are the
rules. ``How do you do this?'' So this will continue.
Because of the kind of unusual nature of this--of laying
out this issue--I have asked and the minority has agreed that I
would have 15 minutes in my opening questions and that the
minority would have 15 minutes, and then we will open it up for
questions by the members.
And with that, I would like to recognize Congressman
Guthrie, the senior Republican this morning.
[The statement of Mr. Miller follows:]
Prepared Statement of Hon. George Miller, Chairman,
Committee on Education and Labor
Good morning.
The Education and Labor Committee meets this morning to examine
reports from the Department of Education Inspector General looking at
higher education accrediting agencies.
The Inspector General's reviews focus on institutions' policies on
credit hours and program length.
As the cost of higher education and, subsequently, the Federal
investment in student aid rise, and more students go into debt to
finance their educations, it is critical that we ask what students and
the taxpayers--as Federal investors- are paying for.
The IG's report found that some accrediting agencies do not have
any established definitions of a credit hour, which could result in
inflated credit hours and misappropriated student aid.
This is alarming and could result in serious implications both for
students and the future of this country.
Now more than ever, the strength of our economy rests on our
ability to produce a highly educated workforce.
A study this week by the Center on Education and the Workforce at
Georgetown University projected that in 2018, there will be more than
three million jobs that require at least an associate's degree and not
enough people available who are qualified to fill them.
The system we have today provides aid to students based on the
number of credit hours they take at an accredited institution. Each
institution sets those credit hours, and we rely on independent
accreditors to see to it that institutions do so properly.
However, the recent IG reports highlight a lack of clear standards
and policies on this issue, as well as a questionable decision by one
agency to accredit an institution which peer reviewers observed had
``egregious'' credit hour policies.
I am particularly concerned about institutions inflating credit
hours in order to garner more student aid than is justified.
This is increased revenue to the institution, but raises the cost
of higher education for their students, and for the taxpayer.
Students could be paying more money than they should be without
getting the product they had hoped for--a coursework or degree that is
worth something in the workforce.
This Committee and this Congress have worked diligently and in a
bipartisan way to help ensure students have access to the resources
they need to obtain a college degree.
We've helped bring down the cost of college for families by
increasing the Pell Grant. We've lowered the interest rates on need
based student loans and made it easier for the students and the
families to manage their debt.
We've created income based repayment programs that ensures a
borrower will only have to pay back fifteen percent of their
discretionary income and after 25 years, the debt will be completely
forgiven.
This is why we have a responsibility to ensure the students who are
eligible to receive federal student aid are receiving it and that the
institutions which serve these students are upholding the integrity of
the programs.
Accrediting agencies, in their role of overseeing educational
quality, are important gatekeepers to student financial aid.
Just like our federal student aid programs, they have to work in
the best interest of students.
The significant investments in Federal student aid this Committee
has made in recent years makes it all the more critical and timely that
we be assured accrediting agencies are providing the checks and
balances needed to keep institutions of higher education accountable.
I want to thank our witnesses for being here today. I look forward
to hearing your testimony.
______
Mr. Guthrie. Thank you, Mr. Chairman, and good morning.
The topic of today's hearing, broadly speaking, is
accreditation. It is a system of peer review and program
approval that has a long history in American higher education.
Accreditation is widely viewed as a seal of approval, a
sign of program quality. In our higher education system
accrediting agencies are entrusted with a great deal of
authority, determining which institutions are eligible to
participate in the multibillion-dollar federal aid student
programs.
It is not Congress or the Department of Education that sets
the standards or visits the colleges to measure and verify
their program quality. Instead, independent accrediting
agencies bear this vital responsibility.
This is not a fluke. Our nation has always tried to
maintain an appropriate balance between accountability to its
students and taxpayers, and the independence of our higher
education systems.
One of the benefits of this framework is that it allows
greater flexibility for maintaining program quality while
fostering constant innovation. For instance, if accreditation
were defined by Congress and measured in terms of, for example,
the number of books in the library, an institution that gives
its students access to electronic course materials could be
unfairly excluded from financial aid programs.
Understanding the basic purpose and process of
accreditation is necessary as we delve into the specific topic
of our hearing. Today we will look at a report from the U.S.
Department of Education's inspector general regarding one
specific accrediting agency and the process it used to grant
accreditation to a particular institution of higher education.
This is one of a series of reviews done by the I.G. examining
how accrediting bodies are operating within the parameters of
the law.
I will leave it to the inspector general to spell out the
details of her report. Let me simply say I appreciate the work
that has been done to ensure the intent of Congress that
accrediting bodies use the necessary tools to ensure the
program quality is being met.
As we examine the I.G.'s findings and the broader issues of
how accrediting bodies measure program quality, let me close by
urging a note of caution. American students and taxpayers must
have confidence in our accrediting system. On that we all
agree.
We need transparency and accountability to ensure these
independent bodies are fulfilling their mission. However, we
must be careful not to stray from the fundamental principle
that government does not--and indeed, it cannot--dictate what
constitutes a quality institution of higher education.
This is a point worth emphasizing, particularly in light of
the notice of proposed rulemaking released by the U.S.
Department of Education just last week. Efforts to create a
federal definition for a credit hour or to establish strict
federal parameters for program length have the potential to
place us on a slippery slope--one that will limit creativity
and innovation in the delivery of postsecondary education.
Americans take unique pride in our colleges and
universities--their independence, their quality, and their
potential for innovation. These virtues are rooted in our
unique system of peer-reviewed accountability.
I welcome the efforts to shine light on the accrediting
system and continue efforts to ensure accreditors are using the
right tools and measurements to hold institutions to high
standards. I believe we can maintain accountability without
relinquishing the flexibility and independence of academia.
Thank you, and I yield back.
[The statement of Mr. Guthrie follows:]
Prepared Statement of Hon. Brett Guthrie, a Representative in Congress
From the State of Kentucky
Thank you Mr. Chairman, and good morning. The topic of today's
hearing, broadly speaking, is accreditation. It is a system of peer
review and program approval that has a long history in American higher
education.
Accreditation is widely viewed as a seal of approval--a sign of
program quality. In our higher education system, accrediting agencies
are entrusted with a great deal of authority, determining which
institutions are eligible to participate in the multi-billion dollar
federal student aid programs.
It is not Congress or the U.S. Department of Education that sets
the standards or visits the colleges to measure and verify their
program quality. Instead, independent accrediting agencies bear this
vital responsibility.
This is not a fluke. Our nation has always tried to maintain an
appropriate balance between accountability to students and taxpayers
and the independence of our higher education system.
One of the benefits of this framework is that it allows greater
flexibility for maintaining program quality while fostering constant
innovation. For instance, if accreditation were defined by Congress and
measured in terms of--for example--the number of books in a library, an
institution that gives its students access to electronic course
materials could be unfairly excluded from the financial aid programs.
Understanding the basic purpose and process of accreditation is
necessary as we delve into the specific topic of our hearing. Today,
we'll look at a report from the U.S. Department of Education's
Inspector General regarding one specific accrediting agency and the
process it used to grant accreditation to a particular institution of
higher education. This is one of a series of reviews done by the IG
examining how accrediting bodies are operating within the parameters of
the law.
I will leave it to the Inspector General to spell out the details
of her report. Let me simply say I appreciate the work that has been
done to ensure the intent of Congress--that accrediting bodies use the
necessary tools to ensure program quality--is being met.
As we examine the IG's findings and the broader issues of how
accrediting bodies measure program quality, let me close by urging a
note of caution.
American students and taxpayers must have confidence in our
accreditation system--on that, we all agree. We need transparency and
accountability to ensure these independent bodies are fulfilling their
mission. However, we must be careful not to stray from the fundamental
principle that government does not, indeed it cannot, dictate what
constitutes a quality institution of higher education.
This is a point worth emphasizing, particularly in light of the
Notice of Proposed Rulemaking released by the U.S. Department of
Education just this week. Efforts to create a federal definition for a
``credit hour'' or to establish strict federal parameters for program
length have the potential to place us on a slippery slope--one that
will limit creativity and innovation in the delivery of postsecondary
education.
Americans take pride in our colleges and universities--their
independence, their quality, and their potential for innovation. These
virtues are rooted in our unique system of peer-reviewed
accountability.
I welcome efforts to shine a light on the accreditation system, and
continued efforts to ensure accreditors are using the right tools and
measurements to hold institutions to high standards. I believe we can
maintain accountability without relinquishing the flexibility and
independence of academia. Thank you, and I yield back.
______
Chairman Miller. Thank you, gentleman, for your statement.
And I would like now to welcome our panel to the committee.
Thank you for giving us your time and your expertise.
We will begin with Ms. Kathleen Tighe, who serves as
inspector general for the Department of Education, conducting
independent, objective audits, investigations, and inspections
to weed out fraud, waste, and abuse within the department.
During her distinguished career in public service Ms. Tighe has
served as deputy inspector general of the U.S. Department of
Agriculture, counsel to the inspector general of the General
Services Administration, and as assistant counsel to the Office
of Inspector General.
Dr. Sylvia Manning is the president of the Higher Learning
Commission of the North Central Association, a position she has
held since 2008. As president she is responsible for overseeing
the accreditation of degree-granting postsecondary educational
institutions in the north central region of the United States.
Previously Ms. Manning served as chancellor of the University
of Illinois at Chicago, elevating the university to its current
position as one of the top 50 universities in the country for
federal research funding.
Dr. Michale McComis currently serves as the executive
director of the Accrediting Commission of Career Schools and
Colleges, overseeing the accreditation process for over 100--
excuse me--for over 810 applicant institutions throughout the
United States. Specializing in measuring and evaluation of
student achievement outcomes, Dr. McComis has authored several
publications and conducted several research projects for the
commission in addition to participating in the International
Accreditation Activities in Saudi Arabia, Malaysia, Brazil,
Canada, and the Caribbean. Before joining ACCSC Mr. McComis
worked in trade work by serving as an electrician's apprentice
and HVAC technician throughout his service to the United States
Marine Corps.
Welcome to all of you. Our lighting system you may be
familiar with, but when you begin a green light will go on in
those small boxes in front of you; that will give you 5
minutes. And at 4 minutes an orange light will go on and then
you can start summing up your testimony. Your statement will be
placed in the record in its entirety so you proceed in the
manner in which you are most comfortable.
And I will begin with you.
STATEMENT OF KATHLEEN TIGHE, INSPECTOR GENERAL,
U.S. DEPARTMENT OF EDUCATION
Ms. Tighe. Chairman Miller, Representative Guthrie, and
members of the committee, thank you for inviting me here today
to discuss the Office of Inspector General's reviews of
accrediting agencies' standards for program length in higher
education. This is my first opportunity to testify before
Congress since my March confirmation as inspector general and I
look forward to working with this committee to help ensure that
federal education programs and operations meet the needs of
America's students and families.
As requested, I will discuss OIG work involving standards
for program length and the definition of a credit hour--
critically important issues in the federal student loan program
as the amount of federal aid a student can receive is based on
the number of credit hours that a student is enrolled in.
This issue has become even more significant as online
education has exploded in recent years, making credit hour
assignment difficult, its comparison to traditional classroom
delivery difficult and a challenge, and its value increasingly
important to ensure that students and taxpayers get what they
are paying for.
The OIG has conducted extensive work involving accrediting
agencies for over 2 decades because the role of these--these
agencies play is vital. Accreditation is one of the primary
requirements for an institution's participation in the federal
student aid programs and determines whether academic programs
merit taxpayer support.
The department is dependent on accrediting agencies to
ensure that institutions provide quality content and academic
rigor at the postsecondary level as it is prohibited from
determining the quality of education funded by federal
education dollars. All the department can do with regard to
evaluating the quality of postsecondary education is recognize
accrediting agencies as reliable authorities for the quality of
education funded by federal dollars. Thus, the recognition of
accrediting agencies by the secretary of education is the
primary tool available to the department for ensuring that
students receive value for the taxpayer investment of
postsecondary education.
We conducted our most recent work on accrediting agencies
last year in order to provide the department and Congress with
information regarding the definition of a credit hour for
recent negotiated rulemaking sessions. We examined three of the
seven regional accrediting agencies to determine what guidance
regarding program length and credit hours they provided to
those institutions--to institutions and peer reviewers. The
three accrediting agencies we reviewed represent one-third of
the institutions participating in federal student aid
programs--over 2,200 postsecondary institutions receiving more
than $60 billion in federal student aid funding.
We found varying levels of guidance related to the issues
we looked at. For example, the Southern Association of Colleges
and Schools provides guidance regarding program length and the
required number of credit hours; however, the other two
agencies did not set minimum requirements related to program
length.
Most significantly, we found that none of the agencies
established a definition of a credit hour. Their failure to do
so could result in inflated credit hours, the improper
designation of full-time student status, the over-awarding of
federal student aid funds, and excessive borrowing by students,
especially with distance, accelerated, and other programs not
delivered through the traditional classroom format.
At two of the accrediting agencies we were told that
student learning outcomes were more important than the
assignment of credit hours. However, these two accrediting
agencies provided no guidance to institutions or peer reviewers
on acceptable minimum student learning outcomes at the
postsecondary level.
Currently the student aid programs are primarily dependent
on the credit hour for making funding decisions, as are other
forms of aid including state student aid programs and certain
programs administered through the Department of Veterans
Affairs. To help address this issue the department just
released a proposed rule that contains the definition of a
credit hour. Once a final rule is adopted by the department we
will be closely watching its implementation and evaluating
whether the definition of a credit hour is effective in
protecting students.
This concludes my statement, and I am happy to answer any
questions.
[The statement of Ms. Tighe follows:]
Prepared Statement of Kathleen S. Tighe, Inspector General,
U.S. Department of Education
Chairman Miller, Ranking Member Kline, and members of the
Committee: Thank you for inviting me here today to discuss the U.S.
Department of Education (Department) Office of Inspector General's
(OIG) reviews of accrediting agencies' standards for program length in
higher education. This is my first opportunity to testify before
Congress since my March confirmation as the Inspector General. It is an
honor to lead this organization with its long history of accomplishment
and to have the opportunity to work with this Committee, which has led
the way in improving Federal education programs and operations so they
meet the needs of America's students and families.
As requested, I will provide information on our work involving
standards for program length and the definition of a credit hour--
critically important issues in the Federal student aid programs, as the
amount of Federal student aid a student can receive is based on the
number of credit hours for which a student is enrolled.
This issue has become even more significant as on-line education
has exploded in recent years, making credit hour assignment difficult,
its comparison to traditional classroom delivery a challenge, and its
value increasingly important in order to ensure that students and
taxpayers get what they are paying for.
Background on the OIG and Accrediting Agencies
For 30 years, the OIG has worked to promote the efficiency,
effectiveness, and integrity of Federal education programs and
operations. We conduct independent audits, inspections, investigations,
and other reviews, and based on our findings, make recommendations to
the Department to address systemic weaknesses and recommend to both the
Department and Congress needed changes in Federal laws.
As members of this Committee know, the Federal student aid programs
have long been a major focus of our audit, inspection, and
investigative work, as they have been considered the most susceptible
to fraud and abuse. The programs are large, complex, and inherently
risky due to their design, reliance on numerous entities, and the
nature of the student population. OIG has produced volumes of
significant work involving the Federal student aid programs, leading to
statutory changes to the Higher Education Act of 1965, as amended
(HEA), as well as regulatory and Departmental operational changes. This
includes extensive work involving accrediting agencies. Accrediting
agencies are private educational associations that develop evaluation
criteria and conduct peer reviews of institutions of higher education
to ensure that the instruction provided by those institutions meets
acceptable levels of quality. The role they play is vital, as
accreditation is one of the primary requirements for an institution's
participation in the Federal student aid programs and determines
whether academic programs merit taxpayer support.
Under the HEA, the Department is dependent on the accrediting
agencies recognized by the Secretary of Education (Secretary) to ensure
that institutions provide quality, content, and academic rigor at the
postsecondary level. The Higher Education Opportunity Act of 2008
included a provision that prohibits the Department from developing
minimum regulatory criteria for an accrediting agency's standards for
accreditation. The Department of Education Organization Act of 1980
prohibits the Department from making determinations on curriculum and
educational quality. Thus, the Department is prohibited from
determining the quality of education funded by Federal education
dollars. All it can do with regard to evaluating the quality of
postsecondary education is recognize accrediting agencies as reliable
authorities for the quality of education funded by Federal dollars. In
1992, Congress established the National Advisory Committee on
Institutional Quality and Integrity--an independent body charged with
doing what the Department cannot: evaluating the adequacy of
accrediting agencies' standards for accreditation and making
recommendations to the Secretary as to those agencies that should be
recognized. That input is vital, as the recognition of accrediting
agencies by the Secretary is the primary tool available to the
Department for ensuring that students receive value for the taxpayer
investment in postsecondary education.
OIG Work Involving Accrediting Agencies
In the late 1980s and early 1990s, OIG identified significant
problems with some accrediting agencies' oversight of program length at
some institutions. Our work contributed to significantly strengthening
the requirements accrediting agencies needed to meet for recognition by
the Secretary in the Higher Education Act Amendments of 1992. The
Amendments also mandated that an academic year, for undergraduate
programs, must be a minimum of 30 weeks of instructional time in which
a full-time student is expected to complete at least 24 credit hours.
The Department faced difficulty in applying this requirement to
programs measuring student progress in credit hours but not using a
semester, trimester, or quarter system, including non-traditional
educational delivery methods. Therefore, the Department established the
regulatory 12-Hour Rule. The 12-Hour Rule served as a surrogate for the
Carnegie formula, which provided the standard unit of measuring credit
in higher education, whereby one credit hour generally consisted of one
hour of classroom work and two hours of outside preparation over the
course of the academic year. ``One hour of classroom work'' is defined
as 50 to 60 minutes. Under this method, a full-time student in an
education program using a semester, trimester, or quarter system would
have a workload of 36 hours per week through the academic year (12
hours of classroom work and 24 hours of outside preparation per week).
At the time, there was an assumption that the traditional semester,
trimester, and quarter system provided a minimum level of instruction
and that these programs closely followed the Carnegie formula.
The 12-Hour Rule provided a tool for the Department to help ensure
that students received a given quantity of instruction. The Department
relied on accrediting agencies to ensure that the quantity and quality
of instruction was at the postsecondary level. The assumption was that
a full-time student attempting 12 credit hours in a semester would have
12 hours of scheduled instruction per week. In 2000, we performed an
audit where we found that an institution's programs offered much less
classroom education than programs provided by traditional term-based
institutions and that the institution was in violation of the 12-Hour
Rule. A series of audits over the next two years identified other
institutions that were in violation of the 12-Hour Rule.
In 2002, the Department eliminated the 12-Hour Rule in favor of the
One-Day Rule. Under this regulation, an institution is required to
provide one day of regularly scheduled instruction during each week in
an academic year. However, neither the HEA nor the implementing
regulations define what constitutes instruction or the minimum amount
of instruction that needs to be provided during the required one day of
instruction. At the time of the change, much like today, there were
many different delivery methods for instruction: the traditional
residential term-based programs; residential programs not offered on a
semester, trimester, or quarter system; correspondence courses;
telecommunications programs; and independent study. There was no
specificity in what could be included as instruction for determining an
institution's academic year and credit hours for the awarding of
Federal student aid funds.
We informed the Department about our concern with the elimination
of the 12-Hour Rule, as well as the need to address the definition of
instruction, the appropriate amount of Federal student aid to be
awarded in non-traditional programs, and accrediting agency oversight
of non-traditional programs. As a result of this concern, in 2002-2003,
we took another look at this issue and examined two regional
accrediting agencies and two national accrediting agencies, evaluating
their standards for program length and student achievement. The scope
of recognition for regional accrediting agencies is limited to specific
states for each accrediting agency, while the scope of national
accrediting agencies is not limited to specific states. We found:
Program Length
Neither regional agency had a definition of a credit hour
that it required its institutions to follow. The standards these
regional agencies applied to program length were vague and without
definition, effectively allowing institutions to establish their own
standards; and
The two national agencies both had a definition of a
credit hour in terms of the required hours of instruction needed to
equate to a credit hour.
Student Achievement
The regional agencies had not established minimum
graduation, placement, and licensure rates for any of their
institutions providing vocational education programs. For all education
programs, these regional agencies permitted institutions to establish
their own standards for student achievement, without any specified
minimum standard; and
The national agencies had established minimum graduation,
placement, and state licensure rates for the institutions they
accredited. However, at both agencies we identified problems in the
methodology by which the rates were calculated that caused the rates to
be overstated.
As a result of these findings and in anticipation of the scheduled
2004 reauthorization of the HEA, we made a recommendation that Congress
establish a statutory definition of a credit hour stating: ``For
programs that are not offered in clock-hours, credit hours are the
basis for determining the amount of aid students are eligible for.
Absent a definition of a credit hour, there are no measures in the
[Higher Education Act] or regulations to ensure comparable funding
across different types of educational programs.'' The recommendation
was not included in the reauthorization.
Recent OIG Reviews
As a follow-up to this work and in anticipation of the 2009-2010
higher education negotiated rulemaking sessions in which the definition
of a credit hour was to be discussed, OIG once again examined the issue
in order to provide the Department with facts on program length and the
definition of a credit hour in negotiated rulemaking and to provide
information to Congress on the state of the definition of a credit hour
at regional accrediting agencies. As regional accreditation has long
been considered the ``gold standard'' in accreditation and information
on what the regional accrediting agencies were doing with regard to
credit hours could greatly inform the regulatory process, we determined
that we would do reviews at the three largest of the seven regional
accrediting agencies. The three accrediting agencies were: the Southern
Association of Colleges and Schools Commission on Colleges (SACS); the
Middle States Association of Colleges and Schools (Middle States); and
the Higher Learning Commission of the North Central Association of
Colleges and Schools (HLC). These three accrediting agencies represent
one-third of the institutions participating in Federal student aid
programs: 2,222 postsecondary institutions with more than $60 billion
in Federal student aid funding.
Our objectives were to determine: (1) what guidance the accrediting
agencies provide to institutions regarding program length and credit
hours; (2) what guidance the accrediting agencies provide to peer
reviewers to assess program length and credit hours when evaluating
institutions; and (3) what documentation the accrediting agencies
maintain to demonstrate how they evaluate institutions' program length
and credit hours. We found that none of the accrediting agencies
defined a credit hour and none of the accrediting agencies provided
guidance on the minimum requirements for the assignment of credit
hours. At two of the accrediting agencies (HLC and Middle States), we
were told that student learning outcomes were more important than the
assignment of credit hours; however, these two accrediting agencies
provided no guidance to institutions or peer reviewers on acceptable
minimum student learning outcomes at the postsecondary level. The
following is a summary of our results at each accrediting agency:
Southern Association of Colleges and Schools Commission on
Colleges
SACS provides guidance to institutions regarding program
length and the required number of credit hours; however, it does not
provide guidance on the minimum requirements for the assignment of
credit hours or the definition of a credit hour;
SACS provides guidance to reviewers regarding the
assessment of program length, but does not provide reviewers guidance
regarding the assessment of credit hours; and
SACS maintains documentation to demonstrate that it
evaluates institutions' program length and credit hours.
Middle States Association of Colleges and Schools
Middle States does not have minimum requirements specific
to program length and does not have minimum requirements for the
assignment of credit hours; and
Middle States senior staff stated that their main focus
was on student learning outcomes; however, we did not find that Middle
States provided any guidance to institutions and peer reviewers on
minimum outcome measures to ensure that courses and programs are
sufficient in content and rigor.
Higher Learning Commission of the North Central Association
of Colleges and Schools
HLC's standards for accreditation do not establish the
definition of a credit hour or set minimum requirements for program
length and the assignment of credit hours;
HLC does not provide specific guidance to peer reviewers
on how to evaluate the appropriateness of an institution's processes
for determining program length and assigning credit hours or on the
minimum level of acceptability for accreditation when evaluating these
processes;
HLC maintains self-studies and team reports as
documentation of its evaluation of institutions' program lengths and
credit hours, but the amount of information related to program length
and credit hours that institutions and peer reviewers included in these
respective documents varied; and
HLC determines whether institutions assess student
learning outcomes; however, it does not define a minimum threshold for
when the measures of achievement for student learning outcomes indicate
poor educational or programmatic quality.
While conducting our inspection at HLC, we identified a serious
issue that we brought to the Department's attention through an Alert
Memorandum, HLC evaluated American InterContinental University (AIU)--a
for-profit institution owned by Career Education Corporation (CEC)--for
initial accreditation and identified issues related to the school's
assignment of credit hours to certain undergraduate and graduate
programs. HLC found the school to have an ``egregious'' credit policy
that was not in the best interest of students, but nonetheless
accredited AIU. HLC's accreditation of AIU calls into question whether
it is a reliable authority regarding the quality of education or
training provided by the institution. Since HLC determined that the
practices at AIU meet its standards for quality, without limitation, we
believe that the Department should be concerned about the quality of
education or training at other institutions accredited by HLC. Based on
this finding, our Alert Memorandum recommended that the Department
determine whether HLC is in compliance with the regulatory requirements
for accrediting agencies and, if not, take appropriate action under the
regulations to limit, suspend, or terminate HLC's recognition by the
Secretary. The Department initiated a review of HLC and determined that
the issue identified was not an isolated incident. As a result, the
Department gave HLC two options for coming into compliance: (1) to
accept a set of corrective actions determined by the Department; or (2)
the Department would initiate a limitation, suspension, or termination
action. In May 2010, HLC accepted the Department's corrective action
plan.
Current Status
With the explosion of on-line postsecondary education and
accelerated programs, the value of a credit hour becomes increasingly
important to ensure that students and taxpayers get what they are
paying for. Currently, the Federal student aid programs are primarily
dependent on the credit hour for making funding decisions, as are other
forms of aid, including state student aid programs and certain programs
administered through the U.S. Department of Veterans Affairs. To help
address this, the Department will soon be issuing a definition of a
credit hour through a notice of proposed rulemaking that we understand
will be issued on June 18. Once a final rule is adopted by the
Department, we will be closely watching its implementation and
evaluating whether the definition of a credit hour is effective in
protecting students and taxpayers.
Closing Remarks
We view the recognition of accrediting agencies by the Secretary as
the primary tool available to the Department for ensuring that students
receive value for the taxpayer investment in postsecondary education.
As the Department is prohibited from developing minimum regulatory
criteria for an accrediting agency's standards for accreditation or
making determinations on curriculum and educational quality, it is not
unreasonable for the Department to expect an accrediting agency to have
developed its own minimum standards.
On behalf of the OIG, I want to thank you for the support Congress
has given to this office over the years. We look forward to working
with the 111th Congress in furthering our mutual goal of protecting
students and serving the taxpayers.
This concludes my written statement. I am happy to answer any of
your questions.
______
Chairman Miller. Thank you.
Ma'am?
STATEMENT OF SYLVIA MANNING, PH.D., PRESIDENT, THE HIGHER
LEARNING COMMISSION OF THE NORTH CENTRAL ASSOCIATION
Ms. Manning. There we go. Okay, thank you very much.
And good morning, Chairman Miller, Representative Guthrie.
Thank you very much for giving me this opportunity to speak
with you today on matters of great mutual concern.
You spoke about accountability and integrity; they are very
high on our list. And we are also very much concerned about the
issues of student debt and taxpayer costs.
I do want to make one brief point with regard to the case
that was the center point of the inspector general's review of
our work last summer and then move on to the body of my
testimony. The point I want to make is simply to remind people
that this was not a dispute about the value of the courses for
which we determined that there was too much credit being
ascribed. We found that fault and we found that based on our
own standards.
The disagreement with the Inspector General's Office was a
disagreement about having made that finding, what should we do
next? We took an approach that they did not agree with.
Subsequent events and further examination of the institution
have indicated that our approached worked. And of course, I
would be willing to answer more questions about this
institution in the question period.
I want to make two simple points about how we conduct
accreditation. Accreditation, for us, is an action that does
indeed rely more upon judgment than upon statements of minimum
thresholds. And secondly, I want to say--and I want to assert--
that this is a rigorous process and that it is rigorous not in
spite of the fact that it relies upon informed judgment but,
frankly, because of that fact.
Why do we use a process that relies so much upon judgment
and so much less upon minimum thresholds? Because we are
charged with assuring and advancing quality and we want real
quality, we don't want minimum quality; because the areas in
which our evaluators are judging are messy and complex; and
because we want to be in a posture of continuously requiring
that our institutions improve.
We don't believe quality stands still. An institution that
isn't assessing itself and constantly engaging in improvement
is losing quality, and that is what we are fighting against.
How do we achieve the rigor? We achieve the rigor by using
experienced professionals, people how have been in the field
for many, many years. We use a wide range of them.
But we don't simply rely on that expertise. We require our
evaluators to be trained, and in fact, we do refresher training
when policy changes. And the training they receive and the work
they do is within a framework of stated criteria. This varies
from accrediting agency to accrediting agency.
In our case we have five criteria and 21 core components,
and our institutions are required to demonstrate that they meet
every one of these core components, and our evaluators are
required to make a finding that they meet them. But the finding
must be based, as is the demonstration, on evidence.
This is an evidence-based process. The findings are
rendered in evidentiary statements, and that is a primary
consideration.
Let me turn for a minute more to the question of program
length and definition. The definition, so to speak, of a credit
hour is actually deeply understood in the higher education
community.
The fact that our standards don't happen to cite precisely
the so-called Carnegie Hour does not mean that our evaluators
are not capable of assessing whether a course is worth the
amount of credit that is being given to the course. And in
fact, in the particular case that came up in the course of our
review our assessors exactly looked at the courses and without
benefit of a written definition and a written standard
determined that in their view the courses carried too much
credit.
But what has happened over the many decades in which the
credit hour concept is used is that it has come to be
understood by the working professionals in the area not as a
function of a clock but as a body or a quantity of knowledge
and skill that is imparted. And that is why accreditors have
come to look so much at student outcomes, because the fact of
the matter is that the credit hour may be good for lots of
things but it won't tell you what a student learns--it won't
even tell you whether a student learned anything in the 3 hours
a week the student sat in the classroom or whether the student
even did the homework.
What we are looking for is assessment of outcomes as a very
important factor in accreditation because we want to be sure
that the students learned things and that the institutions
assessed that and paid attention to it.
If the regulations as proposed are promulgated can we work
with them? Yes, we can work with them. There may be some
challenges for the institutions. There will be costs to
demonstrate compliance, and there may be some deterrence to
innovation. We can work with it.
But I can assure you of this much: I don't believe that a
definition of a credit hour will solve our challenges with
regard to consistency, and I don't believe that that will lead
us to the kind of high quality and ever increasing quality this
nation needs in higher education.
Thank you. I will be happy to answer questions.
[The statement of Ms. Manning follows:]
Prepared Statement of Sylvia Manning, President, the Higher Learning
Commission of the North Central Association
I thank Chairman Miller, Ranking Member Kline, and members of the
Committee for this invitation to testify on standards for program
length in higher education.
I have served as President of the Higher Learning Commission of the
North Central Association since July 1, 2008. Prior to that I served as
Chancellor of the University of Illinois at Chicago; I have worked in
higher education my entire adult life.
The Higher Learning Commission is the regional accreditor for 19
states defined as North Central. Specialized and professional
accrediting agencies accredit specific programs, such as law,
engineering, or nursing. Regional accreditors accredit entire degree-
granting institutions of higher education; they are membership
organizations composed of the accredited colleges and universities,
committed to uphold shared standards and improve practices and
outcomes. The Higher Learning Commission has just over 1,000 members
representing the full spectrum of American higher education: public,
private and for-profit; community colleges, four-year schools,
professional schools, comprehensive universities, research
universities, faith-based colleges, tribal colleges; colleges with a
few hundred students and universities with tens of thousands of
students.
This diversity of colleges and the spirit of freedom and enterprise
that enabled its development are widely believed to constitute one of
the pillars that have made U.S. higher education still the strongest in
the world, despite continuing concerns about American global
competitiveness. In fact, those continuing concerns are part of an
unceasing drive to innovation that sustains quality.
It is my understanding that this hearing was prompted by the
recently reported review by the U.S. Department of Education Inspector
General of standards for credit hours and program length at three of
the regional accrediting agencies. The report on the Higher Learning
Commission was the last to be released and the most critical of the
three, culminating in a recommendation that the Department undertake a
review of the Commission's qualification as a recognized accreditor.
The report and in particular that recommendation focused intensively on
the case of a single institution and the Commission's decision to grant
it accreditation.
In preparing this testimony I have proceeded on the understanding
that the Committee's interest is not in a single institution or a
single decision, but in the general issue of credit hours and program
length and the broader issue of quality. I will refer briefly to the
specific case at the end of my testimony and am entirely willing to
discuss it further in oral questioning.
My testimony is in three parts: (1) The nature of accreditation and
how it addresses quality; (2) The strengths and limitations of the
credit hour as a measure to determine academic attainment; and (3) The
relationship of the credit hour and program length to the assurance of
quality.
Accreditation and Quality
Higher education institutions are regulated by state and local
governments and, to the extent that they accept federal monies, the
federal government. These regulations touch upon accounting standards,
probity in the use of public funds, fire and building codes,
discrimination in employment, athletics opportunities for students,
research with human or animal subjects, eligibility for Title IV
federal aid to students, and a variety of other matters.
Regional accreditation assesses the quality of a college or
university to ensure that its academic offerings are appropriate and
rigorous, that its practices have integrity, and that its business
operations are robust. It looks at the entirety of the institution,
necessarily taking a broad view. The issues it engages are complex and
messy and often don't lend themselves to strict rules, to questions
with yes-or-no answers and scores at the end.
Accreditation is an act of judgment based upon articulated
standards or criteria that expressly allow for, even require, judgment.
Because of that, it preserves the ability to adapt to varying
circumstances, contexts and environments, to deal with diversity, to
tolerate--even to encourage--innovation, and to apply constant pressure
for improvement. Accreditation, in other words, seeks to support the
innovative and adaptive spirit that has created the richness and range
of American higher education, the range that in turn enabled the United
States to democratize higher education long before other political
democracies attempted to do so.
Accreditation pursues a dual purpose of quality assurance and
quality improvement and must accomplish both rigorously. There are
standards of quality that must be met, and there is the need for
continuous quality improvement. Improvement is critical because quality
is not immutable and it does not stand still: an organization is either
improving its quality or losing it.
In regulations under Title IV of the Higher Education Act, minimum
thresholds are often key and must be clear, although even in Title IV
regulation there is a place for judgment by the staff of the U.S.
Department of Education where appropriate. Accreditation typically
shies away from defining minimum thresholds, and the Higher Learning
Commission in particular has tended to less specific language, with
phrases such as ``commonly accepted.'' But there is no basis for any
assumption that the absence of precise or quantified minimum thresholds
indicates or creates a lack of rigor.
The Higher Learning Commission, for example, has five Criteria
under which it arrays 21 Core Components. The Core Components are
findings that institutions must demonstrate and review teams must make,
such as ``The organization's learning resources support student
learning and effective teaching.'' To support this finding, multiple
forms of evidence will be required and the evidence will be concrete,
but that is different from a ``minimum threshold'' that might say
something like ``The organization must provide at least 1 public
computer station for every 20 students enrolled.'' In addition to the
Criteria and Core Components, the Commission has 12 specified
requirements for eligibility and supplements its Criteria with
Statements such as ``Principles of Good Practice in Adult Degree
Completion Programs.''
The importance of evidence is paramount. The Commission's guidance
documents provide about a half-dozen ``Examples of Evidence'' for each
of the 21 Core Components and reviewers are required to ground every
judgment in substantial evidence.
The Commission relies upon expert or professional judgment to
determine when standards are simply not met and to apply continuous
pressure, even upon the best, to improve. Because it has not depended
upon extensive definitions of minimum thresholds, there is no such
thing as a ``perfect score'' in an accreditation review. In its
commitment to quality improvement, the Commission eschews a pure regime
of minimum thresholds under which an institution seeking only to earn
its stamp of approval--its ticket, as it were, to Title IV funds--would
be able to meet those minima and no more.
Key to accreditation is the use of peer evaluation by professionals
who are qualified and trained to bring judgment to bear on questions of
quality. The American judicial system requires juries of peers to
assure a communal role in the execution of the law. Accreditation seeks
juries of peers for the purpose of expertise, the expertise that is
necessary where mission and outcomes are complex, rules cannot be
framed with mathematical precision, and judgment is essential.
Countering the risk of excessive subjectivity in judgment, the
Commission complements its extensive documented discussions with
required training for its peer reviewers and multiple levels of review
for critical decisions. Even a relatively small change for an
institution, such as a venture into establishing an off-campus
location, is reviewed for approval by more than one person. And, as
noted above, judgments need to be based on evidence.
Voluntary accreditation has been in place in the United States for
over a hundred years and has handled issues related to the evaluation
of quality for most of that time. Accreditation works well because it
ensures that institutions not only meet appropriate standards but are
continually working to exceed those standards, all the while
recognizing that institutions across the broad spectrum of American
higher education are not all the same: they have considerable
differences in how they approach the task of educating students. This
diversity of institutions that provides opportunities for students
across the United Status to participate in higher education is a key
strength of this country. I believe that voluntary accreditation is an
important factor in keeping this system strong.
At the same time the Higher Learning Commission believes that its
processes, like those of the institutions it accredits, can always
benefit from review and improvement. In fact, we have agreed, in
follow-up to the Inspector General's report, to address further
guidance for our review teams on the application of our standards. But
the principles remain: Minimum thresholds may be useful, but they do
not guarantee rigor and their absence does not create an absence of
rigor. Alone they cannot produce high quality, especially the quality
needed in a rapidly changing, competitive environment.
Credit Hours and Program Length
The concept of the credit hour was originally developed for K-12
education. It was adopted by higher education as a way to create a unit
smaller than the course, to define differences among types of courses.
Later it came to be used in a variety of other ways, such as to define
the workload of a faculty member or assess tuition charges. It is now
deeply embedded in so many facets of higher education practice that
efforts to dislodge it would be highly disruptive. Only very recently
in the last century did federal monies become attached to it for the
distribution of financial assistance to students.
The credit hour is based upon what is often referred to (usually
pejoratively) as seat-time, because it starts from the amount of time a
student spends in a classroom. One semester credit hour consists of 15
hours in a classroom plus an assumed two hours of homework for every
hour in the classroom, so that it represents a total of 45 hours. A
three-credit course at a college on a semester calendar therefore
normally meets three hours a week for 15 weeks and assumes that
students are doing 6 hours a week of homework. (Except that an ``hour''
in the classroom is usually 50 minutes, an understanding developed to
accommodate the need for students to have 10 minutes to get from one
class to another on a college campus.) In theory the definition still
makes sense. In practice it has always been mushy.
Anyone who has ever taught or taken a class knows the concept of
credit hours is mushy. No one can be sure how much time students spend
on homework, but we do know that in any given class there will be huge
variation. What's more, the seat-time and homework time, that is the
credit hour, has nothing to tell us about what a student learned. But
we do know that some students get A's and some students get D's and
that the students who got A's learned more than the students who got
D's--or at any rate knew more by the end of the course--even though
they all met the same credit-hour requirement. Furthermore, we know but
don't like to say that a student who earned an A in a course of a given
description with a given number of credits using the standard credit-
hour definition might take the same course with the same description
and the same number of credits using the same standard credit-hour
definition at another college and earn a C--because there are
differences in what is taught under the description and in the
performance expected of students.
So the credit hour by itself is not very good for telling us what a
student learned. It may be very good for other things, but not for
that. And that is why Undersecretary for Higher Education Martha Kanter
has chided accreditors for using input measures like seat-time to
assess quality. And that is why for the past 20 years higher education
has been developing ways to measure student learning outcomes. That is
still a developing art, because it is very difficult to do once you get
beyond factual knowledge and basic skills. But that is why some
accrediting agencies, like the Higher Learning Commission, have put
less emphasis on credit hours as minimum standards and more emphasis on
assuring that colleges figure out what their students actually learn
and use those assessments to improve their curriculum and teaching.
Program length is almost uniformly defined in American higher
education by a number of credit hours, usually referred to simply as
credits or units. It is a practical description, and just as the
concept of credit hours serves in a mushy way to define a quantity of
learning, or at least a quantity of teaching, program length in terms
of credit hours defines a degree level. For example, bachelor's degrees
are generally 120 or 124 credits, though in some fields, especially
technical and certain practice fields, they creep up to as much as 136;
associate's degrees are generally 60 credits.
Credit hours and program lengths as developed in this way have come
under question not only for their mushiness but also out of the need to
adapt to a world in which a declining percentage of students are
traditional students who go away to college or commute to college on a
full-time basis. Alternative modes of delivery, most notably internet-
based distance delivery that permits a student to participate in
classroom activities at any time from anywhere, make nonsense of the
idea of seat-time. Furthermore, research in adult learning and the
effectiveness of compressed course formats suggests that equivalence
should not be measured by time.
Does this mean that higher education should do away with the
concept of credit hours? No; but we need to be thoughtful in how we
apply it. Over the decades during which the concept of the credit hour
has been used, it has come to be understood not as a multiple of hours
but as a unit for describing a quantity of information or skill
provided in a specific course. Professors of English share widespread
understanding of what a three-unit survey course in American literature
comprises, and professors of Chemistry know what they should cover in a
three-unit course in introductory Chemistry. Those two things are
enormously different, and there is no equating the three credits. They
began as two of five courses that a typical freshman or sophomore would
be expected to carry in one semester in a traditional, full-time
college, and that body of effort, for each of those courses, has come
to be well understood by the professionals who prepare and teach the
courses.
That is how those professionals were then able to transfer the
concept of credits to compressed or asynchronous formats where hours
can't be counted. What they transferred was not the hours, but the body
of work, the body of information and skill. It is symptomatic that the
phrase ``credit hour'' isn't used much: people speak of credits, or
units, or sometimes hours, though in that case they would likely be
surprised to be taken literally, as though ``hours'' had something to
do with a clock. That is why they accept the notion of giving degree
credit for work experience or military training.
If program length is measured in credits and credits are mushy,
then program length is necessarily a mushy standard too. But it has
come to be workable, just as the concept of credit hours has. That is
why we do not support the notion of creating three-year bachelor's
degrees. We support the notion of students' completing what has been
understood as a four-year program in three years, through advanced
placement, year-round course-taking and suchlike, but we believe that
it is useful that a bachelor's degree is generally understood to be
four years of work and an associate's two, and that calling a three-
year program by either of those names would just create confusion. We
can have a three-year degree, but let's call it something else.
Credit Hours and Assurance of Quality
The Inspector General's review of the Higher Learning Commission
and two other regional accrediting agencies took place in the context
of an upcoming session of negotiated rule-making called by the
Department of Education, for which one of the issues on the table was
the matter of definition of credit hours and program length. The
argument put forward as to why a definition was necessary was that the
Department of Education needs to assure that federal funds are going
towards quality education. That goal is incontrovertible. Ideally, such
assurance would be based not on the input of credit hours, but on the
outcome of learning. But in reality, federal funds need to be disbursed
to students at the beginning of a term, not at the end when it would be
at least theoretically possible to measure what they had learned. So
the Department needs an input measure.
Will defining that input measure, the credit hour, with more
specificity contribute to the assurance or improvement of quality in
American higher education? I do not think so. The apparent precision of
the credit hour as originally defined, based on the fact that it has
numbers, is an illusion: underneath the numbers lies the mush.
Will the Department's requirement of that input measure harm
American higher education? I do not think that either. But resources
will be spent in demonstrating compliance with the regulation,
resources spent by colleges and universities, not accreditors, and
diverted from helping students. And it is possible that the risk of
citation by an accreditor will deter some institutions from innovation
in developing programs for adults and other student populations.
What strikes us as curious is that the call for minimum thresholds
in matters such as the credit hour and program length runs counter to
the country's expressed interest in increasing, significantly and
rapidly, our nation's attainment in higher education. To meet our
national goals for educational attainment and a workforce for the 21st-
century economy, higher education is asked--by policy makers,
legislators, foundations, opinion leaders--to break out of old molds,
seek efficiencies, open doors, reach new populations. Strict
accreditation requirements based in 19th-century models don't seem
likely to get us there.
Can rigor in quality assurance be achieved without defining a
credit hour, or requiring institutions to define it or accreditors to
approve the definition? Yes. This point may be best demonstrated by
referring to the specific case at the center of the Inspector General's
report on the Higher Learning Commission. The core of that issue was
the fact that a visiting review team to a campus had identified some
courses which the team determined were being awarded about double the
amount of credit they were worth. Because the Commission nonetheless
granted accreditation to the institution, the Inspector General
asserted that the Commission either does not have standards or is
unwilling to enforce its standards.
But here is the record: (1) the Higher Learning Commission, not the
Office of the Inspector General, identified the issue of credits during
its review of the institution; (2) consistent with the recommendation
of two teams of experienced peer reviewers and based on their academic
judgment, we determined that the issue--given the general strength of
the institution under our standards--did not warrant denial of
accreditation and that a requirement to remedy the problem would be the
most effective approach; and (3) further review and a site visit to the
institution have since provided evidence that the approach worked. Our
standards and procedures identified the problem and corrected it,
benefitting students and the public in a way that denial of
accreditation could not (especially since the institution was already
accredited by another agency and its students were already receiving
Title IV monies).
The visiting team of expert reviewers identified the problem,
without benefit of a precise definition of the credit hour from either
the institution or the Commission. The members of that team, based on
years of professional experience, applied professional judgment,
pronounced the credit ascription out of line and recommended that the
Commission require this fault to be cured (which the Commission did).
When the team declared the credit values to be out of line, it did not
do so based on how many hours the students spent working on the course,
in a classroom or elsewhere. It did so based on the syllabus, on the
curriculum, on what and how the students were being taught.
Conclusions
We offer the following conclusions:
It is appropriate for the Department of Education to
assure that recognized accrediting agencies pay great attention to
quality and rigor, including the award of appropriate academic credit.
Accreditation can and does achieve rigor because it relies
on peer judgment based on clear evidence and demands improvement well
beyond minimum standards.
The absence of a definition of the credit hour or other
minimum thresholds has not impeded the Higher Learning Commission's
discernment of quality or making rigorous accreditation decisions.
A definition of the credit hour, if accompanied by
sufficient leeway to adapt to contemporary modes of delivery and adult
learning, is something higher education can work with, but it will not
assure or improve the quality of higher education in America.
There is room for improvement in accrediting agencies'
assessment and assurance of quality. The Higher Learning Commission is
committed to improving its practices and to demonstrating that
commitment in action, just as it expects its institutions to be.
Thank you again for the opportunity to testify before the
Committee. I look forward to responding to any comments or questions
you may have.
______
Chairman Miller. Thank you.
Mr. McComis?
STATEMENT OF MICHALE S. MCCOMIS, ED.D, EXECUTIVE DIRECTOR,
ACCREDITING COMMISSION OF CAREER SCHOOLS AND COLLEGES
Mr. McComis. Good morning, Chairman Miller, Representative
Guthrie, Committee. Thank you for the opportunity to testify.
My name is Michale McComis and I am the executive director
of the Accrediting Commission of Career Schools and Colleges,
or ACCSC. We currently accredit 789 career-oriented
institutions with over 250,000 students throughout the country.
Today the number of nontraditional, working, adult students
seeking higher education is steadily on the rise. While a
traditional liberal arts education continues to be an important
goal for many students, many other nontraditional students are
enrolling in career-oriented programs, often part-time or
online.
Given the growing demographic of career-focused adult
learners, the higher education community must continue to adapt
and innovate in order to accommodate the diversity in its
student body. Accordingly, there is not, nor should there be, a
one-size-fits-all means by which to define or analyze program
length or the credits provided by the institution.
Having said that, evaluating the continued value provided
by an institution program remains extremely important. As
independent entities that establish standards and assess
institutions on a peer review basis, accrediting agencies are
the best resource for making determinations related to
educational design, delivery, and quality.
The Higher Education Act is written in a manner that relies
on and respects an accrediting agency's independence and the
need for flexibility to shape standards and processes in a
manner that accounts for the types of schools and programs that
it accredits. It is important that the act's accompanying
regulations continue to also provide this flexibility in order
to meet the increasing demand for innovation and diversity in
higher education.
As I pointed out during the recent negotiated rulemaking,
flexibility and regulation regarding the issue of credit hour
is important because regulatory definitions, particularly
narrow ones, have the tendency to become entrenched rules that
stifle innovation.
The current flexibility in the act has enabled my agency to
write standards and create processes that make the best sense
for the types of institutions that the agency accredits.
The current NPRM's definition of a credit hour would
relegate our rather rigorous requirements to an ``other''
category in the regulations, potentially exacerbating the
difficulty that students attending our schools already have in
the area of transfer of credit.
ACCSC's standards are focused on institutional operations
and how those operations contribute to student achievement
outcomes. Because our goal is to assess an entire institution
we do not apply standards one in isolation from another.
Our agency has more than 20 standards that address program
length and objectives directly. Our primary standards in this
area require institutions to demonstrate that the length of
each program enables students to achieve the necessary skills,
knowledge, and competencies.
If the school's program is not comparable to others our
standards require an institution to justify that variant
length. As a standard measure, ACCSC uses a straight clock hour
to credit hour conversion which does not take into account
outside preparation. Additional standards on program length
require the use of independent program advisory committees,
specific credit hour lengths for degree programs, and specific
considerations for distance education.
Our standards are only as good as the process by which we
measure our institutions against them. To prepare for the
accreditation process institutions are required to prepare a
self-evaluation report, or SER.
ACCSC's staff and on-site evaluators review the
institutions SER and evaluate program length against our
standards, such as the clock hour to credit hour conversion
formula. If there is an issue presented on program length or on
other outcomes measures, such as graduation or employment rates
for example, we might require the institution to prepare a
program viability study, which requires a showing that the
program is appropriately designed to meet the needs of the
employment market. If an institution is not able to make this
showing ACCSC has several institutional and programmatic
actions available to remediate or correct poor performance or
to deny or revoke accreditation.
ACCSC believes there is a direct link between the
evaluation of program and length and student learning and
achievement outcomes at an institution. We therefore tightly
align our student achievement standards to the program
objective standards. We view our graduation and employment
rates benchmarks as tools to identify issues such as an
appropriate program length and to then develop institutional
improvement mechanisms as a means to enhance institutional and
student success.
In conclusion, ACCSC believes that its standards represent
exemplary practices in the areas of program length, program
objectives, and student achievement measures for the kinds of
institutions it accredits. We do not intend to suggest that our
standards could or should be applied to every institution of
higher education. Our standards work because they have been
developed in a peer review environment that is committed to
institutional and student success.
Accreditors should continue to be relied upon to establish
these standards in conjunction with their institutions, keeping
in mind the best interests of students. Thus, federal law and
regulation should also continue to rely with confidence on
professional accreditors and refrain from overly-prescriptive
requirements that may, albeit unintentionally, stifle
flexibility and innovation.
Thank you. I will be happy to answer any questions.
[The statement of Mr. McComis follows:]
Prepared Statement of Dr. Michale S. McComis, Executive Director,
Accrediting Commission of Career Schools and Colleges
Thank you for the opportunity to testify. My name is Michale
McComis and I am the Executive Director of the Accrediting Commission
of Career Schools and Colleges (ACCSC). I am honored to appear before
the Committee this morning to discuss the important issue of program
length in higher education. I hope to provide the Committee information
about ACCSC's standards and accreditation process in this area, but
also to provide you our perspective on the role of accreditation in
higher education more generally.
ACCSC is a private, non-profit independent accrediting agency
recognized by the Secretary of Education continually since 1967. It is
a national agency in scope that currently accredits 789 institutions
with over 250,000 students throughout the country. These institutions
are predominantly private sector, career-oriented institutions,
offering programs at the non-degree, Associates Degree, Bachelors
Degree, and Masters Degree levels. They prepare students for trade and
technical careers in many areas including allied health, nursing,
information technology, automotive technology, commercial art, and
unique areas such as horology, luthiery, and yacht building and
restoration.
ACCSC's primary mission is to serve as a reliable authority on
educational quality and to promote enhanced opportunities for students.
To meet its mission, the Commission has a values-based framework for
accrediting focused on integrity, accountability, continuous
improvement, open communication and teamwork. My tenure with ACCSC
began in 1994, becoming its Executive Director in 2008. I have recently
served on two of the Department of Education's negotiated rulemaking
panels--the 2009 Accreditation Panel and the 2010 Program Integrity
Panel--to help establish regulations pursuant to the legislative
provisions of the Higher Education Act (HEA).
Summary of Testimony
My testimony is divided into two primary parts. First, I will spend
a few minutes placing the issue of program length in the broader
context of our higher education system and regulatory structure. It is
important to provide a bit of background regarding the need for
continued reliance on the regulatory ``triad'' that provides the
student funding and quality-assurance mechanisms for our institutions
of higher education. I will speak briefly on how the flexibility of
this regulatory structure has helped to support and encourage
innovation and diversity in our institutions and their programs and
teaching methods. In the context of program length specifically, I will
discuss the relationship between the importance of determining the
appropriate length of a program, the value of credits provided, and the
assessment of student achievement.
The second and most important part of my testimony will provide the
Committee with a summary of ACCSC's standards on program length and its
process for reviewing institutions generally, and with regard to
program length in particular. ACCSC takes pride in the manner by which
it has adapted its standards and process to account for the types of
institutions and programs that it accredits. I also would like to
discuss with the Committee how our standards on program length and
credit hour directly relate to our assessments of student achievement
at our institutions.
The Broader Context of Higher Education Policy, Accreditation and the
Evaluation of Program Length
It is important to take a minute to put the narrow issue of
accreditation standards on program length into the broader context of
today's higher education system. Today, the number of ``non-
traditional'' students seeking higher education is steadily on the
rise, the majority of whom are working adults. While a traditional
liberal arts education at an on-ground institution continues to be an
important goal for many students graduating from high school, many
other non-traditional students are enrolling in career-oriented
programs. Moreover, students are increasingly enrolling on a part-time
basis or online to accommodate their work schedules or other family
commitments.
Given the growing demographic of career-focused, adult learners,
the higher education community must continue to adapt and innovate in
order to accommodate the diversity represented in its student body. The
higher education community itself is also diverse and is defined by a
broad selection of institutions and programs that range from short-
term, non-degree programs to four-year liberal arts programs, to
graduate level programs in hundreds of different academic areas, taught
at institutions both on-ground and on-line. With this rich variety,
there is not, and should not be, a one-size, fits all means by which to
define or analyze program length or the credits provided by an
institution; however, evaluating the continued value provided by an
institution's programs remains extremely important.
As higher education takes a more diverse shape, ensuring the
quality and integrity of these institutions and their programs
continues to be a paramount concern and historically the primary
responsibility of accrediting agencies and the schools they accredit.
Unlike federal and state governments, accrediting agencies are private,
independent entities, focused on establishing standards and assessing
their member institutions in relation to those standards on a peer-
review basis and as such are the best resource for making
determinations related to educational quality.
Despite the independent, private nature of accreditation,
accrediting agencies have been linked to the federal government since
the Congress established the Higher Education Act 45 years ago. In this
regard, accreditation has played an essential role in institutional and
programmatic quality assurance and has served as an essential component
of the regulatory ``triad'' in partnership with federal and state
governments for the regulatory oversight of higher education
institutions. Institutions eligible for Title IV funds must be
accredited by an accrediting agency recognized by the U.S. Secretary of
Education and the Higher Education Act created a structure for this
recognition process. Included in the Act and regulations are criteria
which all accrediting agencies must include in their accreditation
standards. One of these criteria requires standards that assess an
institution's measures of program length and the objectives of the
degrees or credentials offered.
The Act is written in a manner that respects an accrediting
agency's independence and the need for flexibility to shape standards
and processes in a manner that accounts for the types of schools and
programs that it accredits. Concordantly, it is important that the
Act's accompanying regulations continue to also provide this
flexibility. With regard to the issue of program length in particular,
the above overview of the diversity of the higher education community
demonstrates the importance of avoiding prescriptive federal
regulations that might prevent institutions from meeting the increasing
demand for innovation and diversity in the academic programs offered.
Moreover, as I pointed out during the Program Integrity Negotiated
Rulemaking session, the need for flexibility in regulatory language
regarding the definition of a credit hour is important because
regulatory definitions, particularly narrow definitions, have the
tendency to become entrenched rules such that creative yet equally
effective approaches or even more rigorous approaches are not
considered or are seen as suspect. As I demonstrate in the next section
of my testimony, the current flexibility in the Higher Education Act
has enabled my agency, ACCSC, to write standards and create processes
that measure program length and credit hours, and that seek to define
program objectives in a manner that makes the best sense for the types
of programs and institutions that the agency accredits. The current
NPRM regarding the definition of a credit hour would relegate our
rather rigorous requirements to an ``other'' category in the
regulations potentially exacerbating the difficulty that students
attending our schools already have in the area of transfer of credit.
ACCSC's Standards and Processes to Evaluate Program Length and Credit
Hour
The ACCSC Standards of Accreditation and accreditation process
emphasize educational quality by focusing on outcomes. What actually
happens as a consequence of the teaching-learning processes in a school
and what is the evidence of these results? Given the stated purposes of
the school and its documented outcomes, can the school be judged as
meeting standards of quality compared with similar institutions? Does
the accreditation process help the school to evaluate and improve its
student achievement outcomes and hence its quality? Such questions are
the primary focus of ACCSC as the Commission conducts its work.
Our Standards
In addition to having standards and processes to examine
institutional inputs, ACCSC has outcomes-based standards, including
graduation and employment rates, which the agency uses in its
assessment process. In short, the Commission is concerned about
institutional operations and how those contribute to student
achievement outcomes related to the attainment and application in the
workplace of skills, knowledge, and competencies.
Our standards on program length are necessarily linked to our
standards on student achievement; none of our standards is utilized in
isolation. ACCSC strives for a ``whole school'' assessment process
whereby the appropriateness of an institution's operational and
education inputs can be evaluated in the context of student achievement
outcomes. Each component of the school (e.g., admissions requirement
and recruiting, program design and curriculum, student services, the
quality of the administration and faculty, the inclusion of the
employment community in curriculum development and assessment, etc.)
has a role to play and an impact on the overall success of an
institution and the success of students. In the area of program length
and objectives, ACCSC has more than 20 standards that address these
areas directly (see Appendices I and II) and several more that do so
tangentially.
Our primary standards in this area require our institutions to
demonstrate that the length of each of their programs enable students
to achieve their learning objectives. In the event a school has
programs that vary from comparable programs, our standards require an
institution to justify that variant length. As a standard measure for
program length, ACCSC uses a straight clock hour to credit our
conversion shown below:
Semester Credit Hours:
One semester credit hour for at least 15 hours of
classroom contact; or
One semester credit hour for at least 30 hours of
supervised laboratory/shop instruction; or
One semester credit hour for at least 30 hours of
documented independent study activities; or
One semester credit hour for not fewer than 45 hours of
externship/internship or work-related experience.
Quarter Credit Hours:
One quarter credit hour for at least ten hours of
classroom contact; or
One quarter credit hour for at least 20 hours of
supervised laboratory/shop instruction; or
One quarter credit hour for at least 20 hours of
documented independent study activities; or
One quarter credit hour for not fewer than 30 hours of
externship/internship or work-related experience.
Outside preparation is not considered in the conversion of clock
hours to credit hours. In addition to ACCSC's formula for conversion,
institutions are required to comply with applicable state and federal
regulations related to clock-to-credit hour conversions.
In addition to these standards, additional standards on program
length require:
Institutions to have an independent program advisory
committee review and comment on program length;
Minimum and maximum credit hour length for degree
programs;
Comparability of distance education to residential
programs; and
A justification and validation for any deviation from
established clock-to-credit hour conversions in distance education
programs.
Our Processes
Our standards are only as good as the process by which we measure
our institutions against them. We, therefore, have a multistep process
by which we look at an institution's program length. To prepare for the
re-accreditation process, institutions are required to prepare a Self-
Evaluation Report (SER). ACCSC's SER instructions requires institutions
to demonstrate how their programs meet our standards, i.e., we require
an explanation of how the school has determined that the length of each
program offered is appropriate to enable students to achieve the
program objectives. Institutions that do not meet our standards, i.e.,
their program length is not comparable to similar programs, are
required to justify their program's length.
Even before our evaluators visit an institution for re-
accreditation, ACCSC staff will review the institution's SER and
evaluate program lengths against our standards, such as the clock to
credit hour conversion formula. When our evaluators visit an
institution, they review the institution's response to the SER and make
assessments regarding a school's compliance with those standards. Each
on-site evaluation team is comprised of an education specialist and
occupation specialist who work together to make assessments regarding
the appropriateness of a program taking into account the institution's
assertions, the review by an independent Program Advisory Committee,
student feedback, and student achievement outcomes. If there is an
issue presented on program length or on other outcomes measures, such
as graduation or employment rates, for example, ACCSC might require the
institution to prepare a Program Validation Study, which would require
an institution to show that the program is appropriately designed
(e.g., program length) to meet the needs of the employment market. If
an institution is not able to make this showing, ACCSC has several
institutional and programmatic actions available to remediate or
correct poor performance.
For institutions seeking initial accreditation, we likewise require
them to complete a detailed SER, provide a demonstration of compliance
with our program length standards, and undergo an on-site evaluation.
If a school is unable to demonstrate programmatic success via student
achievement outcomes, the Commission will likely defer granting initial
accrediting until a showing of compliance is made or if the institution
is unable to demonstrate compliance after given an sufficient
opportunity to do so, the Commission will deny the school's
application.
Between accreditation cycles, ACCSC has a robust program approval
process. Every program offered by an institution must be approved by
the Commission before the program can be offered. The program
applications require an institution to justify the implementation of a
new program, show that the curriculum and length has been reviewed by
an external employment community Program Advisory Committee, and show
that the program meets ACCSC's clock hour to credit hour conversions.
Connection to Student Achievement
As I have stated, we believe that the evaluation of program length
is linked to our evaluation of student learning and outcomes at an
institutions. We therefore tightly align our student achievement
standards to the program objective standards, including program length,
at our institutions. We view our graduation rate and employment rate
benchmarks as tools to identify issues, such as inappropriate program
length or objectives, and to then develop institutional improvement
objectives as a means to enhance institutional and student success. I
include Appendix II for further detail of our student learning and
achievement outcomes standards.
In the area of student learning and achievement outcomes, ACCSC
requires that:
Student learning outcomes for each program are consistent
with the program objectives and meet any relevant academic,
occupational, or regulatory requirements;
Student learning outcomes for each program are aligned
with the program's objectives, the occupational area of study, and with
the level of education intended (e.g., non-degree, degree, degree
level);
Student learning outcomes for each program reflect the
necessary occupational and academic knowledge, skills, and competencies
as applicable;
The school has a developed and structured process to
assess and evaluate the defined student learning outcomes;
The school must demonstrate successful student achievement
by documenting through its assessment practices that students are
acquiring the knowledge, skills, and competencies intended by the
program objectives; and
The school must demonstrate successful student achievement
by maintaining acceptable rates of student graduation and employment in
the career field for which the school provided education.
Conclusion
ACCSC believes that its standards represent exemplary practices in
the areas of program length, program objectives, and student
achievement measures for the kinds of institutions it accredits. ACCSC
does not intend to suggest that its standards could or should be
applied to every institution of higher education, but instead to show
that rigorous standards can be and have been developed in the areas
being addressed by this hearing. ACCSC's standards work because they
have been developed in a peer review environment that is committed to
institutional and student success. Accreditors can and should continue
to be relied upon to establish these standards in conjunction with
their institutions keeping in mind the best interest of students. Thus,
federal law and regulation should also continue its historical reliance
on professional accreditors to make the appropriate assessments with
its institutions and to refrain from overly prescriptive requirements
that may, albeit unintentionally, stifle flexibility and innovation.
APPENDIX I.--ACCSC PROGRAM LENGTH AND OBJECTIVES STANDARDS
The length of each program offered by the school is appropriate to
enable students to achieve the program objectives and to acquire the
knowledge, skills, and competencies necessary for initial employment in
the field for which training is provided. Schools that have or apply
for programs that appear to be significantly shorter or longer in clock
or credit hours than comparable programs (i.e., within the same field
of study) will be required to justify the appropriateness of the
program length (Section II (A)(2)(a), Substantive Standards, Standards
of Accreditation).
For every program, there are detailed and organized instructional
outlines and course syllabi showing a scope and sequence of subject
matter sufficient to achieve the program objectives and to acquire the
necessary knowledge, skills, and competencies. Programs include the
appropriate number of lecture hours and, as applicable, the appropriate
number of laboratory/shop and/or externship hours necessary to achieve
the program objectives (Section II (A)(2)(b), Substantive Standards,
Standards of Accreditation).
Each school must have an independent Program Advisory Committee for
each program area, and the committee reviews and comments at least
annually on the established curriculum of the program and comments as
to the appropriateness and adequacy of the program objectives, program
length, curriculum content, learning resources, and the adequacy of
facilities and equipment (Section II (A)(5)(e)(i), Substantive
Standards, Standards of Accreditation).
Degree programs are measured in semester credit hours or the
equivalent quarter hours (refer to the Profile of Clock Hour to Credit
Hour Conversion form), include the appropriate number of lecture hours
and, as applicable, the appropriate number of laboratory and/or
externship hours necessary to achieve the program objectives. Degree
programs must be comprised of courses with content that is appropriate
to the level and type of degree awarded (Section II (B)(1)(b),
Substantive Standards, Standards of Accreditation).
An associate degree program must be a minimum of 60 semester hours
or 90 quarter hours and a minimum of two academic years. Associate
degree programs may not exceed by more than 50% the minimum number of
credit hours required to confer the degree by the appropriate
regulatory agency in the state(s) in which the school operates. If such
minimums have not been established, then generally accepted practices
in higher education shall apply. (Section II (B)(2)(b), Substantive
Standards, Standards of Accreditation).
A baccalaureate degree program must be designed and offered in a
way that appropriately balances distinct types of education and
training (i.e., technical and occupationally related courses and
general education courses) and distinct levels of education and
training (i.e., lower level and upper level courses), and must include
a comprehensive curriculum with appropriate coursework to achieve the
program objectives. (Section II (B)(3)(a), Substantive Standards,
Standards of Accreditation).
A baccalaureate degree program must be a minimum of 120 semester
hours or 180 quarter hours and a minimum of four academic years.
Baccalaureate degree programs may not exceed by more than 50% the
minimum number of credit hours required to confer the degree by the
appropriate regulatory agency in the state(s) in which the school
operates. If such minimums have not been established, then generally
accepted practices in higher education shall apply (Section II
(B)(3)(b), Substantive Standards, Standards of Accreditation).
The length of a master's degree must be appropriate to enable
students to achieve the required competencies and skills for employment
or advancement in the field for which training is provided (Section II
(B)(4)(b)(i), Substantive Standards, Standards of Accreditation).
A master's degree program must be designed and offered in a way
that provides for a distinct level of education and fosters independent
learning and an understanding of research methods appropriate to the
academic discipline. Graduate level courses must be based on
appropriate pre-requisites and learning outcomes and expectations must
be clearly stated to students (Section II (B)(4)(b)(ii), Substantive
Standards, Standards of Accreditation).
Master's degree programs must include a minimum of 30 semester
hours or 45 quarter hours. At least 24 semester hours or 36 quarter
hours must be in the technical field for which the degree is awarded
(Section II (B)(4)(b)(iii), Substantive Standards, Standards of
Accreditation).
ESL program length must be between 600 and 900 clock hours or the
equivalent credit hours (Section II (C)(2)(f), Substantive Standards,
Standards of Accreditation).
The length of the distance education programs and courses of study
must meet all necessary requirements outlined in Section II (A)(1),
Substantive Standards, Standards of Accreditation (Section IX (C)(1),
Substantive Standards, Standards of Accreditation).
The school must demonstrate that the content and length of a
distance education program or course of study are comparable to
residential programs. The school must justify and provide validation
for any deviation from established clock-to-credit hour conversions, if
applicable (Section IX (C)(2), Substantive Standards, Standards of
Accreditation).
APPENDIX II.--ACCSC STUDENT LEARNING AND ACHIEVEMENT STANDARDS
Student learning outcomes for each program are consistent with the
program objectives defined by the institution's program design and
development process and meet any relevant academic, occupational, or
regulatory requirements (Section VII (A)(1)(a), Substantive Standards,
Standards of Accreditation).
Student learning outcomes for each program are aligned with the
program's objectives, the occupational area of study, and with the
level of education intended (e.g., non-degree, degree, degree level)
(Section VII (A)(1)(b), Substantive Standards, Standards of
Accreditation).
Student learning outcomes for each program reflect the necessary
occupational and academic knowledge, skills, and competencies as
applicable (Section VII (A)(1)(c), Substantive Standards, Standards of
Accreditation).
The school has a developed and structured process to assess and
evaluate the defined student learning outcomes of the education and
training and established competencies (e.g., the application of
knowledge and skills to the standard of performance articulated in the
program objectives and as expected in the workplace). This process may
include a variety and combination of methods such as grading, portfolio
assessment, and criterion referenced testing based on developed and
appropriate rubrics (Section VII (A)(2)(a), Substantive Standards,
Standards of Accreditation).
The school demonstrates successful student achievement by
documenting through its assessment practices that students are
acquiring the knowledge, skills, and competencies intended by the
program objectives (Section VII (B)(1)(a), Substantive Standards,
Standards of Accreditation).
The school demonstrates successful student achievement by
maintaining acceptable rates of student graduation and employment in
the career field for which the school provided education. The school
supports these rates through student transcripts, the school's
verifiable records of initial employment of its graduates, or other
verifiable documentation (Section VII (B)(1)(b), Substantive Standards,
Standards of Accreditation).
ACCSC Student Achievement Benchmarks
ESTABLISHED BENCHMARK GRADUATION RATES
----------------------------------------------------------------------------------------------------------------
Average Rates of
Graduation Demonstrates Standard Established Benchmark
Program Length in Months Acceptable Student Deviation Graduation Rates*
Achievement
----------------------------------------------------------------------------------------------------------------
1-3....................................... 92% 8% 84%
4-6....................................... 82% 13% 69%
7-9....................................... 69% 14% 55%
10-12..................................... 69% 15% 54%
13-15..................................... 61% 16% 45%
16-18..................................... 59% 17% 42%
19-24..................................... 56% 20% 36%
25-35..................................... 55% 22% 33%
36+....................................... 47% 15% 32%
----------------------------------------------------------------------------------------------------------------
*If a school reports a lower graduation rate for a program, that program will be subject to additional
monitoring or reporting as deemed appropriate.
ESTABLISHED BENCHMARK EMPLOYMENT RATE
----------------------------------------------------------------------------------------------------------------
Average Rate of Employment
Demonstrates Acceptable Standard Established Benchmark
Student Achievement Deviation Employment Rate*
----------------------------------------------------------------------------------------------------------------
All Programs.............................. 82% 12% 70%
----------------------------------------------------------------------------------------------------------------
*If a school reports a lower employment rate for a program, that program will be subject to additional
monitoring or reporting as deemed appropriate.
______
Chairman Miller. Thank you very much to all three of you
for your testimony.
This is an attempt to set the stage, not so much an attempt
to inflame the debate. As I understand it, when--Ms. Manning,
when your--is it Dr. Manning or Ms. Manning?
Ms. Manning. It is both. I am quite happy with Mrs., which
is the hardest one to get. [Laughter.]
Chairman Miller. Now I am stumped. [Laughter.]
Ms. Manning. I am sorry.
Chairman Miller. You stump the chump and you win every
time.
Okay. Ms. Manning--where am I?--as I understand it, when
your accrediting team went out and looked at AIU, which is
American Intercontinental University, when they looked through
the courses I think both at the master's level and at the
undergraduate level, if you will, during that process they came
away with the conclusion that there was inflation of course
credit unit hours being awarded to some of those courses.
There was a setup by which you would take nine units over a
10-week period, and when they looked, apparently, both at the
content and at what would be required for a full-time working
student, which many at the university or most at the university
were, to do that it just didn't add up that you could get all
of that in in that period of time. Is that a fair summation,
not on every detail, but----
Ms. Manning. Yes, I think it was. This was a subset of the
courses----
Chairman Miller. And they made a finding, I think, that
caught the inspector general's--which, in fact, said that they
felt that this was egregious when they compared it to common
practices in other institutions from which they may have come
from or they had experience in the accrediting process. Is that
fair?
Ms. Manning. That is exactly the word they used.
Chairman Miller. Okay. But I mean, is they were comparing
it to their experience as accreditors and as, in some cases,
professors, or--I don't know what the team is made up of--their
experience in higher education, if you will, both in the for-
profit and nonprofit world?
Ms. Manning. Yes.
Chairman Miller. Okay.
And the inspector general, as I understand, your concern
was after making this finding the accreditation went forward--
you say, I believe--without limitations put on it. But your
review came after this fact pattern took place because you were
doing a greater review of various different types of
accrediting agencies to get a picture?
Ms. Tighe. Yes, that is correct.
Chairman Miller. Okay.
And Ms. Manning, you said during your testimony that this
problem was raised, you went back, you had a second visit, you
had meetings, and you think it was addressed. Is that fair to
say?
Ms. Manning. Correct.
Chairman Miller. Okay. So that is sort of the fact pattern.
So what caught my attention in this is that in this
discussion of back and forth was the inspector general raising
the point that Title IV resources are released to students--
loans, Pell Grants--are released to students based upon whether
they are in full-time status or part-time status, and that is
measured by credit hours. And that is based upon an old system
which we call the Carnegie system, which was based upon sort of
seat-time--you had three hours for three units, which said that
you were an hour a week in the class or 2 hours a week in
class, and that corresponded to time outside the class, whether
it is 2 hours or an hour and a half for each hour that you were
in the classroom. Is that close?
Ms. Manning. Yes.
Chairman Miller. This is the best I have ever done with a
professor. [Laughter.]
And is that fair, Ms. Tighe?
Ms. Tighe. Our concern was that the team made certain
estimations of the credit policy at AIU, and as you stated
earlier, that the Higher Learning Commission did not take
really any action other than proceed to accreditation,
notwithstanding the estimation of the team that the certain
classes were over-inflated in credit----
Chairman Miller. Do you think they had it kind of
backwards--they should have not provided accreditation, fix the
problem, and then decided whether or not to accredit?
Ms. Tighe. Or at least while reviewing or before deciding
on accreditation, yes, take certain actions to fix those
qualms.
Chairman Miller. Okay.
Let me, if I might--and correct me where I am wrong--but my
understanding is that regarding this nine-unit course over a
10-week period of time, both the accreditors and the Inspector
General's Office looked at this and said, ``This is too many
units''--I think I am correct saying--``This really corresponds
to what a three-unit class would be under common
circumstances.''
Ms. Tighe. That is what the team concluded.
Chairman Miller. That is what the team concluded. Did you
conclude differently, or did you have the ability to conclude,
Inspector General?
Ms. Tighe. We did not make--we did not review the courses
ourselves----
Chairman Miller. Okay. You just reviewed what they were
finding----
Ms. Tighe [continuing]. Reviewed the team report, yes.
Chairman Miller. So, Ms. Manning?
Ms. Manning. That was the point I wanted to make. The
inflation, also, even in the initial team report, was not that
great. They were looking at a subset of courses, and these are
quarter units, and they said instead of nine it probably should
have been somewhere around four-and-a-half, but they were never
that precise.
And let me just add one more point, if I may, which is that
our reports are divided into two sections, and one is assurance
or compliance, and the other is improvement. That detail is in
the improvement section, and it is in the improvement section
in large part because it is really not crystal clear whether a
course should be nine credits, or eight credits, or six-and-a-
half credits. What they were trying to point to was that there
is something wrong here and it needs to be looked at and fixed.
Chairman Miller. Here is my concern: I know it is not
crystal clear and I respect the tradition of accreditation. And
so you could say, reasonable people could differ whether this
is worth three units, four units, or nine units--apparently not
nine units, but if you get to six; there was a little bit of
discussion of six to three.
But as a student, when I sign up for a nine-unit course at
this university at the master's level, those nine units cost me
$5,517. Some of that is grants directly from the taxpayer; some
of that is loans.
If that course is worth three units it costs me $1,839. All
of a sudden that unit becomes very important, and I think it
becomes very important because we are now dealing with
education for profit, and that extra unit, repeated 500 times
throughout the year for 500 students taking that class, is
worth a lot of money, and repeated 1,000 times, and 10,000
times is worth a lot of money, this was sort of the structure,
I think, of AIU, you take these nine-unit courses and, as we
heard on another discussion, if you could get this rotation 10
times a year it was worth real money.
I am not saying that is why it is done, but I am saying all
of a sudden this discussion between you and the I.G. about
minimum----
And, Mr. McComis, I set you aside a little bit because you
have a more specific question about outcomes that you measure
your schools on. I am not leaving you out of this discussion,
but----
Mr. McComis. Thank you. [Laughter.]
Chairman Miller. So you start to see the problem for a
member of Congress is, and this is a very touchy situation. I
understand that. I am not sure George Miller should be deciding
what is the value here, but that question somebody has to think
about because this turns out to be billions of dollars if we
are wrong that are being expended, and this is a program that
we struggle every year to meet the appropriations for in this
Congress.
So that $3,600 difference for that course regime--if your
accreditors were right and it was worth three as opposed to
nine--that $3,600 is valuable to the student, to the taxpayer.
So I don't have the answer on how you deal with this, but I
think when you understand that for an institution that is in
some cases publicly-held, some cases closely-held, privately-
held institutions--this question of how you assign credit units
now becomes part not so much of an academic plan, necessarily,
but also of a business plan.
And I would just raise the question--and I just raise it as
a question; I am sure there will be lots of different answers--
what is the impact of accreditors going up and thinking about
unit hours and the rest of this--or outcomes, however you want
to measure it--in light of aggressive business plans, which is
somewhat different?
Now, you can argue that the traditional universities are
sitting on their haunches awarding three hours because they
have always awarded three hours--it makes no difference to them
because the taxpayers are footing a big chunk of the bill to
keep the institutions going--maybe they should be awarding four
hours, maybe they should be recognizing other components of
this. You know, we know this catfight back and forth about
traditionals versus new, and online, and innovative, and the
rest of it.
So I am not trying to cast it, but all of a sudden when--
what caught my attention here was that difference in six units
is huge across the nation. Now again, this practice was found
by your accreditors not to be conforming either to what they
experienced in traditional or online or for-profit
institutions, however they deliver their course material, or
the hybrid, both seat time and online time.
So it jumps out, but I think in some cases they are still
doing this. Now maybe because of the accreditation the nine
units is all of a sudden worth nine units, but this is, to me,
a very difficult question that is now--that has been raised by
this series of events for the Congress of the United States.
We have about $100 billion out there on the street. The
schools under your accreditation are about $24 billion a year.
The schools that you reviewed, Inspector General, were about
$60 billion a year in combinations of student loans, you know,
underwritten by the taxpayers, and Pell Grants, and other
assistance that is available.
So the consequence, I mean, the outcome of this
discussion--I don't want to turn this into a debate; I don't
want to turn this into finger-pointing, but I just want to put
it in this context, which I think is something we have to
recognize.
You know, I try to think that I have sort of embraced the
policies on education of disruptive innovators. I mean, I think
that is healthy for the whole system and I think we have such
great opportunities now with technology to deliver education to
people where they need it, how they want it, how they can
understand--you know, all of the things that we know about
that.
But this question of how you assign value--and I have a
couple of minutes left, and I would just like you, if you
might, both of you--or all three of you, Mr. McComis, if you
want to--is just how you respond to is this something that is
now just accounted for and I am out of sequence for, or what
are we doing here?
Ms. Tighe. Well, can I just interject a moment, is that I
think you have certainly hit on the range of our concerns, is
that ultimately it is about what the student is paying for and
what, then, the taxpayer is covering for that student. And I
think our particular concern in this case was that there wasn't
an effort to immediately mitigate the harm in that students
were allowed to continue to enroll in these courses, thus
incurring, you know--the problem continuing.
Chairman Miller. Sure.
Ms. Manning?
Ms. Manning. I don't want to spend too much time dealing
with the technicalities, but because this is on the record and
because it refers to a specific institution I do want to
clarify one point. It also is a point that shows how messy this
issue of credit values is.
There is talk about nine units and there is talk about
three units. The problem is that the nine units is measured in
what are called quarter units, and the three units in semester
units. And so if you put them in the same matrix it is six
versus three or it is nine versus four-and-a-half. And I say
that, again, only for the benefit of the institution where this
is being publicly recorded.
Let me say, though, that this demonstrates how messy and
complex the issue is. And I want to go back to your point,
Chairman Miller, also, about the--there is an academic plan and
an academic purpose, but there is also a business plan, and how
these perhaps come into conflict with each other, and how an
academic plan can be manipulated to the benefit of a business
plan.
I want to tell you that we share these concerns profoundly,
that these are concerns that have appeared on the scene of
higher education in less than 10 years, have been significant
in perhaps 5 years, and so that one of the challenges for
accreditation has been to develop the tools for us in order to
be able to understand this, to manage it, and to apply
appropriate standards. And I believe that we have worked very
hard in the last 2 years precisely to develop those tools and
that we have done a good job. The proof will be in the pudding,
and the pudding is yet to come.
We are very concerned about what students are paying for.
When we took that action we knew that we were looking at a
subset of course, and we knew something, and I think this is
really important: There are two ways in which credit value can
be wrong. One of them is that a student is in class for 45
hours and does 90 hours of homework and gets three credits and
it is junk; the other way is that a student is in class and
gets three credits and should only have gotten two credits. I
think there is a huge difference there.
In this case we knew that it wasn't junk. The question was,
can students learn this within the timeframe?
What actually was happening was that they were taking these
nine units in 5 weeks, and what our teams discovered is that
students couldn't possibly be learning all this in 5 weeks. It
is acceptable stuff; it meets industry standards. You can't do
it in 5 weeks.
The way the institution has remediated the program--the
problem--is they have split it in two. These are now two four-
and-a-half-credit courses but they are over a 10-week period.
So it is not that we didn't take any action. We actually
demanded this immediate remediation. And when we got up there
to look at it the institution was ahead of us. They had
actually gone further than we had required. And I think that is
testimony to the effectiveness of a warning or threat from an
accrediting agency.
And at the end of the day if we had not accredited this
institution they would have walked away. They were already
accredited. They would have gone on getting Title IV funds. But
it is not--it is certain that at the rate that we got it the
problem would not have been identified and corrected.
And instead of putting a bunch of students in the midst of
their programs in the situation of being at an unaccredited
institution and having a degree of significantly less value,
what we did was that we took the situation that was there and
we remedied it, and we took it very seriously, and we continue
to take these instances very seriously.
Chairman Miller. Thank you.
Mr. McComis?
For the members, I am using Mr. Guthrie's time at this
time.
You have been very generous with your time.
Mr. McComis, if you have a comment?
Mr. McComis. So I can't speak to the specific----
Chairman Miller. No, no. I understand that.
Mr. McComis [continuing]. But we, too, find what the--
Chairman Miller, what you are describing is course or program
stretching, and our board has long felt very strongly about
that particular issue, and it is one of the leading reasons why
they have created this multilayered approach to assessment that
includes with it a very straight clock hour to credit hour
conversion for the development of that, but also a
demonstration by institutions through student learning and
student achievement outcomes, and external review and comment
by employment community program advisory committees to really
look at the design of a program and that it is appropriate for
that student in terms of the length. We have particular cases
where we have taken action against institutions that we felt
like the program was too long, or in some instances too short.
Chairman Miller. Thank you.
Ms. Tighe, did you have anything else that you wanted to
add, because I am going to turn it over to Mr. Guthrie? Did you
have--or are you fine? Okay. Thank you.
Thank you, Mr. Guthrie.
Mr. Guthrie. Thank you, Mr. Chairman. And I agree in line
with a lot of your comments, just what you made previously. We
have to figure out--there is a lot of money involved and it is
our responsibility, as I said in my opening statement, for the
taxpayers and what is happening with their money. It is our
job, so we appreciate that.
And I appreciate the I.G.'s report. I appreciate what you
have presented for us.
And first, to Mr.--Dr. McComis--you know, in your written
testimony--because we are trying to figure out how to handle
this, I guess, and one thing that we are seeing is the
department is coming out with a proposed rule on defining
credit hour in the federal regulations. And can you talk a
little bit more about--I think, you know, your--my
understanding in your written testimony there could be some
harms that could come about by a federal definition of credit
hour. Could you elaborate on that?
Mr. McComis. So, as I indicated in my oral testimony as
well, during negotiated rulemaking one of the points that I
tried to make relative to the definition that was first
presented by the department was simply that the use of the
Carnegie Unit as the primary definition would relegate our
straight clock hour to credit hour conversion formula into the
other category that they provide--I think the language is
somewhere along the lines of other comparable methods for
determining the length of a program or the definition of a
credit hour.
The issue with that is once you begin looking at transfer
of credit issues it is, ``Well, your institutions don't offer
units that are defined by this Carnegie Unit and so therefore
they can't be transferrable,'' when I think that actually our
credits are more rigorous because they don't allow for outside
preparation. It is, again, largely our institutions are career-
oriented and much of that work has to be done in the classroom,
and in the lab, and on externship.
So the narrow definition, I think, could, you know, maybe
unintentionally, stifle the opportunity for students to be able
to transfer those credits. That was the point that I was trying
to make.
Mr. Guthrie. And one of the concerns would be--is that if
we are paying just for credit hour--I understand that that
could be manipulated--but if you are paying for credit hour you
are not necessarily paying for the outcome, and you measure the
outcomes. And how, in your accreditation process, when you look
at outcomes, can you go back and see that maybe credits were
misallocated or misawarded, so--by checking--not just looking
at the credit hours, you look at the outcomes, and from the
outcomes or the quality you say you can go back and say that
credit has been--credit hours have not been allocated properly,
which is a way of catching a problem, too.
Mr. McComis. Sure. So the way that we utilize our student
achievement outcome benchmarks is to identify potential
problems, and when a particular program--because we do it by
program, not by institution--when a particular program begins
to demonstrate either lower graduation rates or employment
rates that fall below those benchmarks we begin to do a--
require the institution to start talking to us about the
viability of their program, or efficacy of their efforts to
improve retention, or graduation, or employment, and try to
identify the root cause of those lower outcomes.
Traditionally what we would see is that if a program, you
know, was too long in length that graduation rates might
suffer; if it was too short in length employment rates might
suffer because the students are not attaining the necessary
competencies. So we are looking to really identify that optimal
balance between the program design and content with student
achievement outcomes.
Mr. Guthrie. Okay. Thank you.
And then, Ms. Manning--or Dr. Manning--can you describe
what processes you have in place to ensure that your peer
review teams--and how you evaluate institutions to ensure that
they are assigning proper credit hours? I mean, what process do
you use to see if your peer review teams have--what processes
do your peer review teams use to ensure the institution is
assigning proper credit hours?
Ms. Manning. In the normal course of a review, not when
there has been a problem identified like this one that we were
talking about earlier, this is part of the review that is
conducted on the adequacy of the student learning. It is also
true that in areas where we are required by regulation on
behalf of the federal government to look into specific issues
we ensure that every team addresses the issues, and with the
knowledge that the team will address it the institution is
required to address it.
The normal procedure is that you have a team on the campus;
it is made up of a number of people with different disciplinary
backgrounds. They will sample--from the institution's point of
view it is an arbitrary or random sample--courses. They will
look at syllabi, they will talk to faculty, they will talk to
students, they will look at the program outcomes that have been
identified.
We require all our institutions to be engaged in
assessment. You can't assess unless you have goals and stated
outcomes. We require those for every program on the
institution.
We test with a random sample, and that is random, not
randomized.
Mr. Guthrie. Could you check against--if you say this
course in other institutions is typically a three-hour course,
this one they are giving a four-hour course? I mean, do you
compare across institutions or just within the institution
itself?
Ms. Manning. No, we tend to look at--well, it is looking at
the institution itself against a background of the knowledge of
the evaluator who is looking at it. The distinction between a
three-unit course and a four-unit course is something that I
would be very hard put to argue is actually a valid distinction
that you can really make. There would be, I think, much greater
variation between many three-unit courses at different
institutions, or even in different classrooms in the same
institution.
Mr. Guthrie. Okay. Because I can see a lot of English 101
at one school is three hours, at the next school it is three
hours, at the next school it is three hours, but a lot of the
issues we are concerned about are nontraditional students and
probably nontraditional courses, and that, I mean, that is one
of the questions I guess we have to grapple with as we are
going.
But before I run out of time I do have one more for Dr.
McComis. You said that you look at the outcomes and then you
make actions based on the outcomes. What actions can you take?
I mean, what point do you leave--if you find that you have a
program you say is of low quality or not meeting the quality,
what actions do you take as an accrediting agency?
Mr. McComis. So there are several programmatic and
institutional actions that are available to the commission to
remediate poor performance in any given program. At the
programmatic level, an institution might be placed on
reporting, where they will have to continually go back to the
commission and talk to them about their improvement efforts,
what have they identified as being some of the root causes for
the lower outcomes, whether those are internal or external,
whether they are market forces or whether they are internal
program content issues.
They will need to work to identify those and then to assess
and remediate. When an institution is placed on some form of
outcomes reporting there are limitations that are associated
with that as well.
From there the actions can certainly escalate to other
kinds of programmatic actions if improvement is not made to
require an institution to suspend enrollment while an
investigation continues, to cease enrollment, or to revoke
programmatic approval or distance education approval.
Institutional actions would include show-cause orders or
probation orders.
And probation orders are important because of the
transparency that is associated with them. Our board requires
that once you place an institution on probation they have an
obligation to tell current and prospective students about that
action. It becomes public on our Web site and we also identify
that for all federal, state, and other accrediting bodies as
well.
Mr. Guthrie. What kind of frequency for that final--the one
you just described, what kind of frequency--you have, what,
700--over 700 schools you----
Mr. McComis. We do, yes.
Mr. Guthrie. Okay, how many would be on this----
Mr. McComis. On probation at any given time?
Mr. Guthrie. Just public--I don't want you to say it if it
is not public.
Mr. McComis. Maybe 10--five to 10 institutions, for a
variety of different reasons.
Mr. Guthrie. Okay.
Thank you. That is my question----
Chairman Miller. Would the gentleman yield for 1 second?
Mr. Guthrie. I will yield.
Chairman Miller. Ms. Manning, you said--and I think you
correctly say--it would be very difficult to tell the
difference between a three-unit course and a four-unit course--
hard for accreditors to do. But this particular institution,
that is $613--1,000 students. That is a lot of money.
This is a problem. I am not making this out that we
disagree on this. This is a problem.
Before, for all of the reasons we know, when you are trying
to look at common practices across institutions of higher
education, and content, and value, and the rest of that, but we
now are confronted with this issue that each of those
determinations carries a cost to the taxpayer. And yet, I want
institutions to be able to set, you know, to set the content
and the course and the time that makes sense in terms of what
the student is hoping to get out of that course if they enroll
in that.
But what we could dismiss in another setting today we have
to contemplate how we thing about it before we make that
determination that it is just a distinction we can't make,
because, you know, one of the things we have learned about
fees--people learn from the telecommunications industry, they
like to assess a little tiny, tiny fee a billion times a day.
And one unit here and one unit there doesn't sound like much,
but across this country at these prices, you know--geez, if
they did it at Harvard it is worth $1,600. Think of that.
Mr. Andrews?
Mr. Andrews. Sounds a lot like----
Chairman Miller. Thank you.
Mr. Andrews [continuing]. Sounds a lot like 401K fees, Mr.
Chairman.
Chairman Miller. It does seem like it.
Mr. Andrews. I would like to thank the chairman for calling
this hearing because I think it is part of a broader effort
this committee is embarking upon to try to find quality
measurements for higher education in the country. A lot of our
laws come from an era where there was a consensus about
quality, correct or incorrect, and there was a debate about
quantity.
I think that the dramatic technological and pedagogical
changes that we have undergone have rendered that consensus
about quality to be obsolete, and I think that our committee is
going to be involved and we need the help with each of you, as
witnesses, in conducting an assessment of what quality really
means in this new world. And I think this morning's hearing is
a great step in that direction.
Ms. Tighe, thank you for the good work that you have done.
I want to be clear that your report did not draw any
conclusions or distinctions with respect to differences with
respect to the ownership of schools involved, right? You didn't
find any pattern that would discriminate or distinguish
traditional not-for-profits, from publics, from for-profits. Is
that right?
Ms. Tighe. Well, we covered a sample of each kind of school
when we looked at each accrediting agency.
Mr. Andrews. But there isn't any pattern that would
distinguish the results among the three?
Ms. Tighe. No.
Mr. Andrews. Okay.
The second thing I wanted to ask was, in the review of the
work that Dr. Manning's agency did you highlighted one
particular instance, which we want to talk about in a minute.
Were there any other instances of accreditation that you found
that called for special highlighting? I understand the basic
conclusion was that there was not a definition of the credit
hour nor guidance, but were there any other situations of
specific school review that you felt the need to call attention
to?
Ms. Tighe. No. In our review of the three accrediting
agencies we did not see any other instance like that one.
Mr. Andrews. And in the case of Dr. Manning's organization
how many accreditations did you look at that they had
performed?
Ms. Tighe. We looked at, for her organization, I think
roughly eight different institutions.
Mr. Andrews. Okay. So it is one that we are focusing on
here out of that eight.
Now, Dr. Manning, I wanted to get the timeline straight on
the one that is controversial here. Am I correct that your team
visited this school in March of 2009?
Ms. Manning. Yes.
Mr. Andrews. And your team did find this--they did use the
word ``egregious''?
Ms. Manning. They did.
Mr. Andrews. And the fact pattern that was egregious was
that in their judgment coursework that should have been
awarded, say, four-and-a-half credits was awarded nine. Is that
right?
Ms. Manning. That is right.
Mr. Andrews. Okay. Now, when they discovered that what
remedial action--you testified that now what the institution
has done is to break that course into two 5-week, four-and-a-
half-unit courses, and in your judgment that satisfies the
problem. When did the institution do that?
Ms. Manning. They did that in the course of the fall of
2009.
Mr. Andrews. In the fall of 2009. So were there students
between the March 2009 review and the fall of 2009 that
continued on in this nine-credit course that should have been
four-and-a-half?
Ms. Manning. Yes.
Mr. Andrews. Okay. And I don't mean this as a rhetorical
question, but why did your organization choose--as I
understand, the remedial measure that you chose was to sort of
point this out to the school and encourage them to do something
about it. Is that a fair characterization?
Ms. Manning. I think ``encourage'' is a soft word.
Mr. Andrews. But you didn't----
Ms. Manning. We threatened.
Mr. Andrews. Okay. But you didn't withhold their
accreditation.
Ms. Manning. We did not withhold their accreditation.
Mr. Andrews. Okay. What was the basis of that--if it is not
proprietary or subject to litigation--what was the basis of
that remedial judgment? Why didn't you recommend a suspension
or at least an--here is our concern: The records would then
show that between the spring of 2009 and sometime in the fall
of 2009 students were paying more than they should, taxpayers
were paying more than they should. It was evidently corrected
by the fall, but why the interim? Why did we permit that
interim to occur at all?
Ms. Manning. You know, I think the--part of this is to see
whether it is a question of were they being overcharged or was
there a deficit in academic quality in what they were getting.
I think that is really the difference. We were saying, ``You
can't have learned this much.'' It would have been lovely to
correct this instantly, but we do not believe that it could
have--you can't correct these things overnight; you have
agreements with students.
Mr. Andrews. My time is up, so I have this final question:
Why didn't you decide to make their accreditation conditional
upon fixing this by some date certain?
Ms. Manning. Well, in effect we did that. We accredited
them, and we told them----
Mr. Andrews. But if they had not made this decision
voluntarily they would still be accredited, wouldn't they?
Ms. Manning. No. If they had not made this decision we
would by now have been moving to withdraw their accreditation.
We would have----
Mr. Andrews. Was it a condition of their accreditation?
Ms. Manning. We have not had a practice of expressing it as
a condition, but we do have a practice of saying, ``This must
be remediated and you must come back by this date and show us
that you have remediated it.''
Mr. Andrews. So you are saying it is the functional
equivalent thereof?
Ms. Manning. Yes.
Mr. Andrews. Okay.
Thank you, Mr. Chairman.
Ms. Tighe. Well, I was just going to point out that at the
time we did our field work, which was late in the summer of
2009 the remedial measures being instigated by Higher Learning
Commission were a requirement of a self-study by AIU and then a
focused visit that was scheduled for, actually, this coming
school year. Now, I obviously can't speak to what measures were
taken since that time.
Mr. Andrews. I understand.
Chairman Miller. Mr. Hinojosa?
Mr. Hinojosa. Chairman Miller, thank you for having this
critically important hearing on the inspector general's review
of standards and programs linked in higher education. As
subcommittee chairman on higher education I am committed to
ensuring that our institutions of higher learning and career
and technical colleges provide high-quality educational and
training programs to all students. The inspector general's
findings are of great concern to me.
At this time I have a question for Inspector General
Kathleen Tighe: In your testimony you indicate that the
explosion of online education in recent years has made it even
more difficult to assign credit hours and assess student
achievement. I strongly support the Department of Education's
proposed regulations pertaining the definition of a credit
hour.
Tell me, what types of minimum standards should accrediting
agencies develop to ensure that students and taxpayers receive
what they are paying for?
Ms. Tighe. Well, I think the most critical standard is the
one we have been sort of talking about today, which is the
definition of a credit hour. I think that it is not only the
vehicle that--you know, the unit that most, you know,
institutions use to define--you know, to have students pay for
classes, it is how federal student aid gets dispensed, which is
ultimately our concern.
And I think it is that definition, which I think in truth
we are not looking at it from the perspective of it has to be
the Carnegie Unit; I think it can be a flexible definition, and
I think that it can take into account student outcomes and the
other things. But I think it ultimately is up to accrediting
agencies to develop a definition.
Mr. Hinojosa. Since we see some colleges with quarterly
semesters and then others that are the regular semester--and I
am not sure about the for-profit colleges--couldn't we just
make everybody be standard on the same length of time?
Ms. Tighe. Well, I think you could do that, but I think it
is probably not necessary to do that. I think that you can have
a credit hour mean something and have different program lengths
even with that.
Mr. Hinojosa. Okay.
My next question is to Dr. Manning with the Higher Learning
Commission. In your testimony you have underscored the need for
accrediting agencies to focus on student learning outcomes. Do
you agree with the inspector general that it is necessary for
accrediting agencies to have a precise definition of a credit
hour and establish minimum requirements for program length in
addition to considering learning outcomes?
Ms. Manning. I think that we can work with a definition of
credit hour as has been proposed. Where I think we are
skeptical is whether that definition will, in fact, ensure the
quality of what a student learns in those hours. And the
understanding of what a student should learn not in so many
credit hours but in introductory chemistry is something that is
well held by the professors of chemistry.
And our argument has simply been that we have not had lax
standards because we haven't told them what that is. We have
worked on a system where we have brought in people who
understand that and who hold institutions to those standards.
And let me just say also, with reference, as well, to
Chairman Miller's earlier point: Because this is always a
slightly fuzzy area that is another reason why it is so
important for us to say, ``Minimum standards don't do it.'' You
have got to significantly exceed. We want high quality.
Mr. Hinojosa. My last question is to Dr. McComis: What are
accrediting agencies doing now to ensure that there are minimum
graduation rates, placement rates, and licensure rates for the
vocational education programs? Address my question for the
public colleges versus the for-profit college or university.
Mr. McComis. So, I can speak most specifically about our
agency. We have, since 1998, had quantitative standards for
graduation rates and employment rates for each program offered
within an institution.
Those rates are calculated--the required benchmarks,
thresholds that we use--are calculated through collecting
annual data from each program offered by our institutions and
aggregating those and coming up with an average and then a
standard deviation. The standard deviation represents the
benchmark because it represents those--the lowest-performing
group within the set of data that we are using.
As I said earlier, we then require each institution to
demonstrate that their programs exceed those benchmarks, and if
they don't they move into some kind of monitoring mechanism,
anywhere from heightened monitoring that, over time, could lead
ultimately to some other kind of institutional action, all the
way up to revocation of accreditation.
Mr. Hinojosa. My time has run out. I yield back.
Chairman Miller. Mr. Petri?
Mr. Petri. Mr. Chairman, thank you very much. And thank you
for scheduling and holding this important hearing.
And, Ms. Tighe, welcome to your new assignment. You have--
--
Ms. Tighe. Thank you very much.
Mr. Petri [continuing]. You have a very big and important
job, and I--probably it is basically almost impossible.
I have a lot of concerns about the whole accrediting
process. I thought it worked very well when it was voluntary
and groups of--on one basis or another--of schools,
institutions, would get together for mutual evaluation, and
self-help, and setting standards, and helping the public then
choose based on that approach.
We built on that when we got into the student loan
business, and G.I Bill of Rights, and all of this after World
War II thinking that that was a pretty good proxy for quality
in one thing and another, and it didn't work very well so we
put in a whole new process to look after student loan repayment
rates. But anything that we do seems to create a system where
people start gaming it.
And as long as we focus on inputs--trying to define an hour
or something like what are a credit hour--we are avoiding the
fact that we could just give a test to people before they went
and after they went and see if they made reasonable progress
and fine the school if they didn't, or some simple sort of a
thing where you actually--because different classes are going
to have different requirements, and as you said, distance
learning, and the 101 different ways around this. It is
basically never going to happen.
And even in accrediting, when I meet with the accreditors
with the schools in my district what they say is, ``We are so
different. We are accreditors. We define what our objective is
and they try to measure us on basically how we achieve the
objectives we have defined.'' And so that is kind of a circular
thing, and what it has to do with quality or anything else is
beyond me. So I don't know if you have any observation on that.
And the other area we are wrestling with as a committee is
the 90-10 rule, and what if people are gaming it. And it turns
out, evidently that applies over a very short period of the
repayment of loans, meaning we should have a longer period and
we should look at if these proprietary or other schools are
giving other aid to students and then they are using it to come
within the 90-10 rule--is that really what we are talking
about? It is a huge problem, and we are going to have to get a
handle on it or we are going to have another big mess on our
hands.
Ms. Tighe. We would agree. I mean, we are obviously always
looking to--I mean, that is part of our job is looking to
people who game the system.
I think as far as your first point, I think, you know--yes,
I think one theoretically could just give a test at the
beginning and then measure, you know, academic engagement and
student, you know, learning on that basis. The problem is, I
think that is a difficult way to dispense, you know, federal
student aid.
And for better or for worse the way we do that is by credit
hour, and I think it ought to have some meaning to the student
and to the taxpayer that is somewhat--that both allows for
innovation in learning, but yet gives some minimum requirement.
And, you know, that is sort of, you know, why we went in and
did our review.
The 90-10 rule obviously concerns us. We have had a number
of cases--investigations--based on schools who are gaming that
issue. It is something we are also concerned about.
Mr. Petri. Thank you.
Chairman Miller. Mr. Bishop?
Mr. Bishop of New York. Thank you, Mr. Chairman, and thank
you for holding this hearing.
And thanks very much to the panel.
I used to administer a college in New York State, and so my
experience--New York State is very prescriptive; if you want to
have an academic program in New York State you have to register
with the State Education Department even if you are a private
college, and the State Education Department uses the Carnegie
Unit as a measure of an academic credit. I have to say, we
found that to be very helpful to have some minimum threshold
level that defined a credit, that defined a course, that
defined the length of the semester, and so on.
Dr. Manning, you had said in your comments this morning
that the definition of the credit hour is deeply understood.
You also said that this issue is messy and complex.
So I have two sort of related questions: one, if it is
deeply understood what is the harm in citing some minimum level
that reflects that deep understanding? And if, in fact, this is
messy and complex wouldn't we deal with some of the messiness
and complexity if we had some clear minimum definition of what
constitutes a credit hour?
So I guess my question is, what is so unhelpful about
having a minimum definition, and what about a minimum
definition would preclude innovation, would preclude the kinds
of new molds of educational delivery we are working towards?
And what about a minimum definition would make it more
difficult to measure outcomes, which we all agree is where we
want to be?
I had a lot of questions. I am sorry.
Ms. Manning. Yes. Let me try at least to get at most of
them.
First of all, I want to just say that in my written
testimony I said--I may not have made it clear in the oral
testimony--that we do not believe having a definition will
cause harm. I think that is the first thing.
When I say it is deeply embedded, we all have lived with
the credit hour for all of our working lives. We do find it
very useful. It is so deeply embedded in so many different
things that higher education does that it is actually hard to
conceive how we would manage if we took it out.
So there is no question that it is there and it is
understood, and there is no harm in writing it down. There will
be costs involved in demonstrating compliance, and I think that
is something that is always a question with regard to
regulation. And these are tight times, as you know, for
everything, including higher education.
Mr. Bishop of New York. May I interrupt you?
Ms. Manning. Sure.
Mr. Bishop of New York. Would the costs that are involved
in demonstrating compliance--would they outstrip the cost that
would be involved in demonstrating outcomes?
Ms. Manning. I don't think they would. Not at all. I think
that the--there is a serious cost to demonstrating outcomes,
but our belief is that if you don't demonstrate outcomes you
don't know what you are doing. That is, it is the Yogi Berra
thing, right, if you don't know where you are going you will
never know if you got there.
So we require institutions to define objectives for every
program. We don't second guess those objectives. We are not
program accreditors. We accredit an entire institution.
So the question is, would the messiness and complexity be
helped by a definition? The definition gives you a way, gives
you a metric. Every institution uses it.
I was really referring to the fact, frankly, that if you go
on most campuses--and perhaps the campus that you were on had
this same thing--and you ask the scientists about the credits
in the humanities they will tell you they are soft because
there is no math. And exactly how you distinguish between three
credits of chemistry, or how you compare three credits in
chemistry and three credits in English is frankly beyond me.
So that is the kind of thing that I meant by messy. You are
accrediting a, you know, medical school, you are accrediting
fine arts majors--it is a whole wide area.
But again, let me repeat: I do not think the definition of
a credit hour will do harm. I just feel that if our primary
shared goal is a quality of what is being delivered to students
in this country then the credit hour--it won't impede it, but
it won't contribute to quality.
Let me add one more thing about why we get so nervous about
these kinds of definitions. If you think about 15, 20 years
ago, if we had had--at that time if there had been a definition
it would not, as the proposed regulations that were published
yesterday do, take into account the idea of you making
equivalencies based on learning objectives and student
outcomes; it would have simply been the Carnegie Hour--3 hours
in the class is three units plus 6 hours of homework.
And you know, I don't know how, under those circumstances,
we would have developed online learning and taken advantage of
the immense opportunity the Internet offers. And I think,
frankly, one of our problems right now, though it is not our
major problem, is that people tend to conflate online learning
with for-profit delivery. Eighty percent of the institutions in
this country do a significant amount of online learning; it
presents enormous opportunities to people who are place-bound,
people who have full-time jobs, and so forth.
And so that is an example, if you do a what if
historically, that says to you, ``Does having tight minimum
standards always work for the greater good?'' It wouldn't have.
The regulations that have been proposed have more flexibility,
and we recognize that.
Mr. Bishop of New York. Okay.
Thank you.
Chairman Miller. Mr. Polis?
Mr. Polis. Thank you, Mr. Chair.
Dr. McComis, thank you for sharing with us the policies and
practices of the Accrediting Commission of Career Schools and
Colleges. In your testimony you expressed concern about federal
regulations potentially exacerbating the difficulty that
students attending our schools--your schools--already have in
the area of transfer of credit. I found this to already be a
big problem for many students in my state who thought they
could transfer to a public or nonprofit college or university
after attending a for-profit school but then later found out
that the credits that they had earned were not recognized or
accepted.
On your Web site of your organization you describe how the
need for greater portability of educational credits has reached
a critical point and that your efforts continue to increase the
options that are made available to students and graduates, from
your institutions who are interested in continuing their
education. So really, it seems to me that defining a credit
hour and establishing procedures for accrediting agencies to
determine whether an institution's assignment of credit hours
is acceptable would help expand credit portability. What are
your thoughts on that?
Mr. McComis. Well, as I indicated earlier, I think that
once you have the definition there it becomes the definition,
and we don't currently use the Carnegie method; we use the
clock hour to credit hour conversion method. And so it does not
take into account outside preparation.
So once the federal government defines what a credit hour
is as the Carnegie Unit, if you are not using that that is
another opportunity and excuse for an institution to say,
``Your credits are not transferrable,'' even though the content
is--can be completely comparable, maybe even more rigorous.
There is just that opportunity for that to occur.
So, as Ms. Manning has indicated, we don't object to,
necessarily, a regulation, but that a great flexibility within
that regulation that maybe provides criteria for what a credit
hour is as opposed to 1 hour and 2 hours, as the Carnegie Unit
puts forth--or maybe some other option that would allow for
comparable credit hour conversions.
Mr. Polis. You know, there is a recent article in the
Chronicle of the Higher Education, May 27th, and the president
of the Career College Association, which represents most of the
schools that you accredit, was quoted saying that the inspector
general's report was ``silly.'' I would like to solicit your
opinion with regard to whether you agree with that
characterization of the report that our committee is holding a
hearing on today.
Mr. McComis. Well, I don't agree with that
characterization. I think that all the work that the I.G. has
done in this area has been extremely important, and our agency
has benefited from it as well. We underwent an I.G.
investigation in 2002 relative to program length; they made
some excellent recommendations and we followed up on many of
them, and I think strengthened our process.
Mr. Polis. Do you find it troublesome that the president of
the association representing most of the schools you accredit
would consider this report, which you believe is a serious
component contributing to quality--do you find that troublesome
that the president found that to be silly?
Mr. McComis. I don't know the context within which that
statement was made, so I really couldn't comment as to it.
Mr. Polis. You say you also want the department to refrain
from overly-prescriptive requirements so they don't stifle
flexibility and innovation, and I think we all share that same
concern. But I also think we agree that protecting the
integrity of federal financial aid programs from inflated
credit hours, improper designation of full-time student status,
et cetera, are also of paramount importance not only to
taxpayers but to the kids themselves. How do you recommend that
the proposed rules can balance those two goals?
Mr. McComis. So, I think one of the things that the I.G.'s
report did was certainly to bring to light that there may be
some competence issues with the way in which accreditation
might evaluate program length and credit hour definitions. I
think, largely, that accreditors do that very well, and the one
case that has been cited, I think, may not be representative
across the board.
So, you know, looking at opportunities, again, multilayered
reliance upon accreditation to work with their institutions to
define the best opportunities for their students is really
important--again, not against a regulation, but looking for
that regulation to be stated in such a way that provides for
potentially even the unknowns in program design and development
as they will occur over the coming years, as Ms. Manning has
already testified.
Mr. Polis. Well, thank you.
And I yield back.
Chairman Miller. Mrs. McCarthy?
Mrs. McCarthy. Thank you, Mr. Chairman, and I appreciate
the hearing. I think it has probably been very educational for
all of us. But I think one of the things that we are looking
at--not only looking at the credit, but I think that the larger
amount is, how do we measure the quality of the education that
we are looking at when the students graduate?
So I guess that I will ask Mr. McComis on what improvements
do you think should be made to the accreditation process for
proposing that they are carrying over a reliable measure of
institutional quality for the purpose of awarding of Title IV
funding?
And, Dr. Manning, you know, in your testimony several times
you had mentioned that you do think that the department
proposal rule on a credit hour will lead us to the higher
quality which we all seek in higher education, so what I am
looking for is what is the recommendation of how do we get to
finding out how we get the higher quality of education and how
do we find that with the students that are graduating?
Mr. McComis. Yes, ma'am. I will go first.
So, recently our agency has sought to work on that
question, and we have developed a number of student learning
assessment and outcome standards that we have put into place as
of last year that really focus on a process of assessment, that
really look to the institution being able to demonstrate--not
necessarily through quantitative measures--but being able to
demonstrate what is the process that they use to determine that
a student has acquired the necessary skills and competencies
and knowledge at a level that would provide the institution
with an opportunity to award that student with a credential.
How did that student, in the vocational and career-oriented
areas--how did you make a determination that that student is
competent to go out and be a nurse, or a truck driver, or a
technician? What were the tools that you used? What were the
rubrics that you used? What were the tests that you used? What
determinations did you come to through that process?
That, coupled with our graduation and employment rates,
make for this--and also the use of external program advisory
committees made up of the employment community--provide us with
this multilayered approach, and those are the approaches that I
think will lead us down to a path of greater confidence in the
quality of those programs.
Mrs. McCarthy. Just quickly, too, don't the states,
especially with the courses that we are talking about, whether
it is nursing, truck driving, they either get certified or they
have to take a state license test? I mean, isn't that also a
quantity of proof?
Mr. McComis. Yes, ma'am, it could be. It is one of several
indices that an institution could use to demonstrate student
learning.
Mrs. McCarthy. Dr. Manning?
Ms. Manning. Thank you. I think that to get at the
quality--and again, I want to make sure we have said this--we
actually do use credit hours, but what we don't use is a strict
definition, and part of this has to do with the fact that we
believe people know what credit hours are, at least the
evaluators that we use.
But to get at what I believe is your question about how are
we going to improve and how are we going to assure that we get
higher quality, I think assessment is the key to it, and I
think that the assessment is best carried on at the
institutional level because it needs to be relative to what the
institution is teaching. And remember that the institutions we
accredit are often very complicated; they will often have a
couple of hundred programs, not a program, and programs that
are very different from each other.
What we need to do--and we have been working on doing this
for about 20 years--is to hold the institutions accountable for
having assessment measures appropriate to each and every one of
their programs based on program objectives. And then--and this
is the part that is the next challenge--we have actually gotten
institutions to be pretty good about assessment.
There is something in the businesses called ``closing the
loop,'' and that means when you assess and you discover that
you are not getting the results you want what do you do about
it and what changes do you make in how you teach, how you run
your program, what your curriculum is, to improve those
results?
And we encourage the use of multiple indicators so that in
professional fields, for example, when there are licensures
exams, that is something that should be taken into account.
When these are undergraduate programs and students are seeking
to go on to graduate work the success rate should be taken into
account.
And so I think that pressure for more assessment and for
more transparency about the outcomes of student learning is
something that should be sustained.
Mrs. McCarthy. Thank you.
I yield back.
Chairman Miller. Ms. Hirono?
Ms. Hirono. This is pretty interesting. You know, I think
that when we talk about accrediting I am looking for objective
measures because how can you measure what the value of a
liberal arts education is versus all those other professions,
such as law, medicine, engineering, nursing, where licensure is
one way that you can objectively determine whether or not the
quality has been there. So at the least I would--I think it
makes sense that we have some sort of minimal national
objective definition.
And I don't think, Ms. Manning, you are objecting to that.
How we are going to get to the quality issues where--on things
like English, literature, I don't know, and I kind of go with
what you just described, that the institutions should be
encouraged to develop those kinds of assessment tools.
Let's face it, by the time we get to higher education I
think that so many of our colleges and universities--the
quality issue is one that is based on their reputation and any
number of factors that are very difficult to measure. So based
on what I am--I am sorry I was late for this hearing, but it
seems to me that we are going in the right direction with what
the inspector general is proposing.
If anybody has any further comments?
Ms. Manning. I could respond to that a bit with
particularly your concern about how do you measure liberal arts
education, for example, also because I am a liberal arts
educator so it hits right home to what I do. And I just wanted
to offer you something that might give you a little optimism
about how we can be working on this.
It is not coming out of the accrediting community. The
leadership on this project is coming out of the American
Association of Colleges and Universities where they have been
working to create rubrics in which--under which it is possible
to assess the outcomes not of English versus history, but the
outcomes of a liberal arts education, and not just a liberal
arts education, but liberal education for all students, because
we believe that the outcomes, the goals of liberal education
are important for engineers and doctors just as they are for
people who go on to become English professors.
And so that work is progressing and it is something that is
being--the outcome, the results of that work are being adapted
by more and more colleges and universities across the country.
And so I think you will see a kind of more articulated
consensus, and therefore a basis on which to benchmark what
students learn even in the liberal learning part of their
education.
Ms. Hirono. Well, could you give me an example of what
would be a measurable outcome for the value of a liberal arts
education? I am not quite understanding----
Ms. Manning. Oh, you look at the large questions about what
is it--you know, why is it a good thing to major in English, or
major in history, or in philosophy? And what we say is, it is
not because the country needs a whole number of people who have
read Shakespeare; it needs a number of people who can think
critically, who can read at a high level, who can solve
problems, who can work together in teams, who can have a global
perspective, which is something we need in our----
Chairman Miller. Keep going. I love this definition of a
liberal arts graduate.
Ms. Manning. No, I am going to stop. [Laughter.]
Chairman Miller. Makes me feel so good.
Excuse me, Ms. Hirono.
Ms. Hirono. Okay. Thank you very much.
Thank you, Mr. Chairman.
Mr. McComis. I would just add, if I could, I think your
question actually goes to the issue of the difference amongst
accreditors and the difference amongst the institutions that
they accredit and the importance of those agencies being able
to work with their institutions. My agency doesn't deal with
liberal arts; we are very career-oriented, so it is--we can
have different kinds of standards because of that, and we do.
And so I wouldn't suggest that every institution would be
able to meet our standards that offer those liberal arts
educations. I think that would be very difficult for some of
them to do. So again, just an important distinction about the
importance of accreditors being able to work with their
institution to define those outcomes.
Ms. Hirono. I agree, because some institutions, as you say,
you know, graduates of your institutions, there are
measurable--objectively measurable--standards that you can
apply. Not so much in the liberal arts side, although I am glad
to know that there are developing measures there, too. But I
think that that should be--I tend to go with what Ms. Manning
is saying, that it is the institutions that should develop
those and not some federal requirement or standard.
Thank you.
Chairman Miller. Thank you.
We are almost done here. Earlier, in my opening questions,
I raised the question, what is the impact of an invested
business plan and the needs of some for-profit institutions.
And in reading from the alert memorandum, when the discussion
was that the difference between AIU's credit policy at that
time--not today, at that time--and the common practice of
higher education, the difference was--where they stated it was
egregious. I go on to read to say that it essentially permits
an undergraduate degree completion student to get a bachelor's
degree or an associate degree plus 1 year of full-time
equivalent study, not 2. This calls into question the integrity
of AIU degree and must therefore rectify quickly if AIU is to
retain an accredited status.
And reading from the memorandum in the next paragraph,
``The implication of this analysis is far-reaching for AIU,
affecting degree requirements, faculty requirements, and
financial aid policies. The current policy of awarding a
bachelor's degree for an associate plus 10 nine-credit courses
seems actually the equivalent of an associate plus 30 semester
hours, so the current degree is the equivalent of an associate
plus 1year of full-time study, not 2. The team viewed this as a
matter affecting the integrity of AIU. If the credits were to
be properly calibrated, students who evaluate AIU's value
proposition in terms of cost of degree, time to degree, may see
that the cost and time double. If AIU cannot raise the cost of
degree without losing too many students and if 90 quarter units
requires 20 courses, not 10, then the number of faculty needed
to serve the existing level of student enrollment would double,
increasing the instructional cost above the current 12 percent
of revenues.''
Next paragraph: ``Unless students are willing to pay more
for their degrees the net effect would be to raise the
percentage of revenue spent on instruction toward a figure that
is more typical of the online universities represented on this
team.''
Next paragraph: ``The recalibration of credit awards might
also affect the meaning of a full-time student eligibility for
federal student loan aid. AIU has been requiring all upper-
division students to be full-time, meaning that they take nine
credit units per 5-week session. This policy may need to be
reconsidered, permitting students to study part-time.''
And then it says, ``The team provided further support of
detail support of its finding.'' This paragraph starts, ``The
current practice of AIU students to take nine credit courses
every 5 weeks thus, in a 15-week period comparable to a
semester in other universities, the AIU student would take 27
credits, comparable to 18 semester hours or six three-semester
hour courses.''
This would be an overload for a full-time student at a
university on the semester system, given that the typical AIU
student is also working full-time and may be--and have family
obligations, or want to ``have a life,'' in addition to their
studies. It is doubtful that the AIU student could hold down
the equivalent of six semester courses on top of this.
The footnote that refers back to the question of unless
students are willing to pay more for their degrees the net
effect would be to raise the percentage of revenue spent on
instruction more typical of the online universities
represented--I assume that means the members of the team, that
some of them were from online universities.
The footnote says, ``The team found that according to CEC's
2007 financial statements that the profit of the Career College
Corporation attributed to AIU was in excess of $40 million. The
team stated that AIU's expenditures on instruction, as a
percentage of revenue, is low by comparison to other
proprietary institutions familiar with--familiar to the team
and that it is likely to be related to the issue of credit
equivalency.''
There you see how this is woven in and out, how these
determinations are made. I don't pretend to know the answer to
this, but I don't think that we can ignore that this is an
overlay on what--as much as we talk about the Carnegie Hours
changing, and looking at outcomes and equivalencies, as even
the department has just done with this proposed rule, what has
also changed is that now institutions have requirements to
shareholders, to profit margins, to the stock market, and to
others. And I think you heard from the range of questions here
that this is a matter of serious concern.
We have votes--I wanted to get back to Mr. McComis on how
they sort of accredited, and I recognize the different
institutions--you do not do liberal arts, but you do have
certain minimums, and I was sort of interested in whether
that--but I am not going to ask you to answer whether you sense
that that is a race to the bottom, as perhaps was suggested if
you did it across the board, that that might be the case.
But I am also concerned about the discussion that went back
and forth between Ms. Manning and the inspector general. And I
think it is a very legitimate discussion, this question of if
you are not going to have input requirements--seat hours, I
guess that is what that was--and minimums, and we are
transitioning to outcomes as another measurement but we don't
have any minimums in outcomes. How is Congress to know whether
or not we, as stewards of the taxpayers' money, are in fact
purchasing value for people who are hungry for the education,
the knowledge, the skills that it brings to them?
But I think maybe--I don't know know whether we will do
that in the hearing or whether we will do that in the committee
briefing where we might ask you to come back, and some others
from the community, to have that discussion, because I think it
is important because we see even again, from the proposed rule,
that a transition is taking place here, but we have this huge
overlay of this $100 billion that is out there on the street.
I want to thank you very, very much for your time. I didn't
want this to go into a back and forth about this. I think that
this particular case raises a whole series of issues that we
have had a very difficult time trying to even articulate in the
congressional setting.
I don't think any of you were set out to do that, but I
think that is how I view both the work of the accrediting
agency, of the I.G., of the institution's response, and I just
want to thank you for your participation and your expertise.
And we will be following up with you again, if you don't mind.
Thank you very much.
And with that, the committee will stand adjourned and Ms.
Hirono and I will see if we can beat--well, we only have to
beat 100 of our colleagues to the floor.
Thank you very much.
[Whereupon, at 11:49 a.m., the committee was adjourned.]