It is a low bar to clear, but college accreditation has never been so hotly commented on as at present. Many in the higher-ed world fear for its future. Two recent columns in the Chronicle of Higher Education are typical.
In one, Robert Shireman, a Democratic appointee to the committee that advises the secretary of education on the recognition of accrediting agencies, warns of an “accreditation war” driven by “Christian nationalism.” Republican “Christian nationalists,” Shireman believes, “don’t want their own, separate, accrediting agency; they want to force the rest of higher education to accept their radical beliefs.” The implicit premise here is that higher education’s status quo is value-neutral and purely rational and that conservative would-be reformers—not, say, Shireman and his colleagues at the progressive Century Foundation—are the extremist radicals.
Anti-reformers’ implicit premise is that higher education’s status quo is value-neutral and purely rational.
In the second, Gardner-Webb University associate provost Greg Pillar and accreditation consultant Laurie Shanderson imagine the consequences of President Trump’s campaign promise to “fire the radical Left accreditors that have allowed our colleges to become dominated by Marxist maniacs.” They fear that new accrediting agencies created by Republican-controlled states and recognized by the Trump administration would not garner the respect of “employers and graduate programs,” thus “disadvantaging students in affected states.” In such a “politicized,” “bifurcated accreditation system, … institutions aligned with traditional accreditors [would] maintain credibility while those accredited by new, politically driven agencies [would] face skepticism.”
Pervading these articles are two presuppositions; one is half right, the other largely mistaken.
Pervading these articles are two presuppositions; one is half right, the other largely mistaken. First, both view a politically weaponized accreditation system with dread and cast the possible regulation of accrediting agencies by the Trump administration as lawless. For instance, Shireman writes that “President Trump is punitive toward those who do not pledge their loyalty to him” and anticipates recognition only of agencies “willing to carry out his wishes,” with loss of funding to any “college that … challenges him or his ideas.”
As examples of “conservative policymakers” arguing that accreditors currently “reinforce progressive ideologies, stifle innovation, and impose excessive oversight,” Pillar and Shanderson link to several right-leaning articles, including my recent column for the Martin Center on accreditation-reform hopes for the second Trump administration. In that article, I suggest that, while “anti-DEI bills aim at various laudable ends,” such as “non-discriminatory employment practices,” such actions could, under future Democratic presidents, “produce a regulatory regime more objectionable than the current status quo.” In other words, I share these authors’ concerns about the prospect of a political “accreditation war.”
My trepidation, however, is prudential rather than a question of legal right. Presidential administrations may not unilaterally dictate rules to independent accrediting agencies. The secretary of education’s standards for agencies recognized as “gatekeepers” of Title IV aid (i.e., Pell grants, direct loans, and federal work-study) are set by statute, which only Congress can amend. Moreover, the standards are expressly a minimal list that does not preclude agencies from adding such further standards as they desire. But the same statute prohibits the secretary from recognizing any agency that knowingly accredits an institution facing or under serious disciplinary action by its state government.
Needless to say, receipt of Title IV funds also requires adherence to all relevant federal laws. Thus, every accreditor expressly requires, in the words of the Higher Learning Commission’s (HLC’s) “Assumed Practices,” that each institution “remains in compliance at all times with all applicable laws.” The Trump administration’s recent “Dear Colleague” letter calls “race-based decision-making, no matter the form … impermissible” under “Title VI of the Civil Rights Act of 1964” and the 14th amendment as interpreted by the Supreme Court in Students for Fair Admissions v. Harvard (2023). The president views race-conscious administrative policies as per se violations of existing federal law.
Thus, Secretary of Education Linda McMahon may well direct recognized agencies to affirm that institutional recipients of federal funds adhere to the race-neutral letter of civil-rights law. Any such order will be challenged in court, but, if the administration prevails, institutions may face a choice between federal subsidies and the race-conscious policies that taxpayers disfavor.
The second fundamental supposition of the two Chronicle articles is that accreditation is an invaluable mark of quality in which the public does and should place confidence. As evidence, Pillar and Shanderson open by linking to an Inside Higher Ed claim that 161 institutions lost Title IV access during the 2023-24 academic year, “almost all related to challenges with their accreditation.”
Institutions seldom become insolvent because low academic quality leads to a loss of accreditation.
But this narrative almost surely inverts the typical causal sequence. Institutions seldom become insolvent because low academic quality (or political pressure) leads to a loss of accreditation and, consequently, Title IV funds. More often, existing fiscal and administrative deficiencies disqualify schools as Title IV recipients and lead to disciplinary action by their accreditor.
Disciplinary action by accreditors is rare. When it occurs, fiscal difficulty and administrative failures are the likeliest reasons.
Data on this question are incomplete but suggestive. In the largest published study, researchers at the Postsecondary Commission (PSC) analyzed nearly 32,000 accreditor actions recorded in the U.S. Department of Education’s Database of Accredited Postsecondary Institutions and Programs. Looking at all actions broadly defined as “disciplinary” (i.e., those contrary to the institution’s desired outcome), PSC found that in “only 2.7%” of those instances did “an accreditor discipline or sanction a college for inadequate student outcomes or low-quality academic programming.” The vast majority of formal accreditor activity was either “supportive of colleges or focused on non-academic matters (governance, finances, general compliance, etc.).”
I used the same database to replicate this study with narrower parameters. The dataset goes back only to 2012, and, unfortunately, most entries don’t specify a reason for the action taken. I filtered specifically for so-called “adverse actions,” such as an institution being placed on probation or losing its accredited status, and limited the field to institutional rather than program-specific accreditors. From the total set of 65,000 actions, this reduced the number to almost exactly 4,000. Of these, adverse actions related to either Title IV or other fiscal/administrative concerns occurred in 523 entries, while student-achievement or other academic-quality concerns numbered 508. The remaining 2,971 are unhelpfully labeled either “other” or “multiple reasons.” More precise data would support firmer conclusions, but there are suggestive patterns here that match accreditors’ own published reports.
With good reason, agencies don’t publish peer reviewers’ reports on accredited institutions. They do announce all formal actions taken, such as granting, renewing, or removing accredited status from institutions. Several also release data on how reviewers cite and use the accreditor’s criteria. In HLC’s parlance, for example, reviewers may find each criterion either “met,” “met with concerns” (requiring further reporting), or “not met” (requiring remediation and possibly resulting in disciplinary action). In the three most recent years for which data have been published, HLC reviewed 368 institutions and took disciplinary action in only nine instances. No institutions lost accredited status. Only 18 reviews found one or more criteria not met. Of the 18 applicable criteria, only eight were cited even once as not met. Those eight are sub-grouped into standards for ethical governance (cited twice), academic quality and student outcomes (cited five times), and financial resources and administration (cited eight times). Though this is a small sample size, the pattern of these data matches that suggested by my replication of PSC’s study of the larger federal dataset. Disciplinary action by accreditors is rare. When it occurs, fiscal difficulty and administrative failures are the likeliest reasons.
Why does this matter? The premise of Pillar and Shanderson’s argument is that accreditation serves as a mark of academic quality, legitimating institutions. Indeed, the regional agencies were created to do just that. But, since passage of the Higher Education Act in 1965, accreditors have been (if you will pardon the pun) progressively co-opted as fiduciaries of the federal state. Agencies are now required both to facilitate peer-review of member institutions’ academic and other operations and police those same members’ eligibility for federal funds. These functions are somewhat contradictory.
The premise of Pillar and Shanderson’s argument is that accreditation serves as a mark of academic quality, legitimating institutions.
Accreditation personnel readily acknowledge the tension caused by vesting these roles in the same body, though few seem willing to imagine alternatives. As Shireman puts it, “Far from being a cartel, federal recognition of accreditors is more like the Wild West.” Excellent! More, please.
Betsy DeVos’s 2019 reforms permitting Title IV recipients to be accredited by agencies in any geographic region introduced some competition and flexibility into the system. But what could achieve a truly competitive marketplace more than separating accreditors’ original “quality-improvement” purposes from their federally mandated “quality-assurance” police functions? Federal law requires Title IV recipients to submit financial audits and related reports to the secretary of education, “the appropriate guaranty agency,” and their accreditor. President Trump has suggested the Small Business Bureau as a possible overseer of the federal student-loan portfolio. He may have the power to effect that without further legislation.
Congress itself must remove the requirement for Title IV recipients to report to accrediting agencies, and it should do so.
Congress itself must remove the requirement for Title IV recipients to report to accrediting agencies, and it should do so. If it ever does, agencies will return to their original state of true independence. They might, if they choose, increase the rigor of their academic oversight. New accreditors would emerge, serving smaller groups of institutions that share closer mission alignment. The largest formerly regional accreditor currently serves nearly 600 members, which vary greatly in size and mission. How much do liberal-arts colleges with triple-digit student bodies really have in common with multi-campus, state-flagship research universities?
This is not a recipe for a hostile takeover of accreditation, through which “Christian nationalists” can “force [institutions] to accept their radical beliefs.” Precisely the opposite. Let accreditors accredit, find the appropriate audit-masters to audit, and let freedom reign.
Samuel Negus is director of program review and accreditation at Hillsdale College.
This article was originally published at jamesgmartin.center
