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Accreditation Guide

Accreditation Guide

November 30, 1999



What Is GAAP?

Any school can claim that it is accredited; the use of that word is not regulated in any way. So, how can you tell if a school is on the level? The following simple guidelines delineate whether or not a school can be considered to be accredited by an agency recognized under GAAP, Generally Accepted Accrediting Principles. (The acronym is, of course, borrowed from the field of accounting. GAAP standards are the highest to which accountants can be held, and we feel that accreditation should be viewed as an equally serious matter.) In the U.S., there is near-unanimous agreement on GAAP (although not everyone calls it this, the concept is the same) by the relevant key decision-makers: university registrars and admissions officers, corporate human resources officers, and government agencies.

Note that in some countries, the word accredited is not used, although that country's evaluation process (e.g., the British Royal Charter) is accepted as "accredited" under GAAP. Note too that accreditors that do not meet the standards of GAAP are not necessarily bad, illegal, or fake. They simply would not be generally accepted as recognized accreditors.

GAAP Criteria

To offer recognized accreditation under GAAP, and accrediting agency must meet at least one of the following four criteria:

  • Recognized by the Council on Higher Education Accreditation in Washington, DC
  • Recognized by the U.S. Department of Education
  • Recognized by (or more commonly, a part of) their relevant national education agency
  • Schools they accredit are routinely listed in one or more of the following publications: the International Handbook of Universities (a UNESCO publication), the Commonwealth Universities Yearbook, the World Education Series, published by PIER, or the Countries Series, published by NOOSR in Australia.

Accreditation: The Whole Story

Accreditation is perhaps the most complex, confusing, and important issue in higher education. It is surely the most misunderstood and the most misused concept both intentionally and unintentionally. In selecting a school, there are four important things to know about accreditation:

What is it?

  • Why is it important in certain situations?
  • What are the many kinds of accreditors?
  • What are the controversies surrounding accreditation?
  • We will address these matters more or less in this order.

What Is Accreditation?

Quite simply, it is a validation a statement by a group of persons who are, theoretically, impartial experts in higher education, that a given school, or department within a school, has been thoroughly investigated and found worthy of approval.

Accreditation is a peculiarly American concept. In every other country in the world, all colleges and universities either are operated by the government, or gain the full right to grant degrees directly from the government, so there is no need for a separate, independent agency to say that a given school is OK.

In the United States, accreditation is an entirely voluntary process, done by private, nongovernmental agencies. As a result of this lack of central control or authority, there have evolved good accrediting agencies and bad ones, recognized ones and unrecognized ones, legitimate ones and phony ones.

So when a school says, "we are accredited," that statement alone means nothing. You must always ask, "Accredited by whom?" Unfortunately, many consumer-oriented articles and bulletins simply say that one is much safer dealing only with accredited schools, but they do not attempt to unravel the complex situation. We hear regularly from distressed people who say, about the degrees they have just learned are worthless, "But the school was accredited; I even checked with the accrediting agency." The agency, needless to say, turned out to be as phony as the school. The wrong kind of accreditation can be worse than none at all.

Normally, a school wishing to be accredited will make application to the appropriate accrediting agency. After a substantial preliminary investigation to determine that the school is probably operating legally and run legitimately, it may be granted correspondent or provisional status. Typically this step will take anywhere from several months to several years or more, and when completed does not imply any kind of endorsement or recommendation, but is merely an indication that the first steps on a long path have been taken.

Next, teams from the accrediting agency, often composed of faculty of already accredited institutions, will visit the school. These "visitations," conducted at regular intervals throughout the year, are to observe the school in action, and to study the copious amounts of information that the school must prepare, relating to its legal and academic structure, educational philosophy, curriculum, financial status, planning, and so forth.

After these investigations and, normally, following at least two years of successful operation (sometimes a great deal more), the school may be advanced to the status of "candidate for accreditation." Being a candidate means, in effect, "Yes, you are probably worthy of accreditation, but we want to watch your operation for a while longer."

This "while" can range from a year or two to six years or more. The great majority of schools that reach candidacy status eventually achieve full accreditation. Some accreditors do not have a candidacy status; with them it is an all-or-nothing situation. (The terms "accredited" and "fully accredited" are used interchangeably. There is no such thing as "partly accredited.")

Once a school is accredited, it is visited by inspection teams at infrequent intervals (every five to ten years is common) to see if it is still worthy of its accreditation. The status is always subject to review at any time, should new programs be developed or should there be any significant new developments, positive or negative.

Note: Everything in the foregoing section applies to accreditation as done by recognized agencies. Many of the other agencies, even those that are not illegal, will typically accredit a new school within days, even minutes, of its coming into existence.

The Importance of Accreditation

Although accreditation is undeniably important to both schools and students (and would-be students), this importance is undermined and confused by these three factors:

There are no significant national standards for accreditation. What is accreditable in New York may not be accreditable in California, and vice versa. The demands and standards of the group that accredits schools of chemistry may be very different from the people who accredit schools of forestry. And so on. Some decent schools (or departments within schools) are not accredited, either by their own choice (since accreditation is a totally voluntary and often very expensive procedure), or because they are too new (all schools were unaccredited at one time in their lives) or too experimental (some would say too innovative) for the generally conservative accreditors. Many very bad schools claim to be accredited but it is always by unrecognized, sometimes nonexistent accrediting associations, often of their own creation. Still, accreditation is the only widespread system of school evaluation that we have. A school's accreditation status can be helpful to the potential student in this way: while some good schools are not accredited, it is very unlikely that any very bad or illegal school is authentically accredited. (There have been exceptions, but they are quite rare.)

In other words, authentic accreditation is a pretty good sign that a given school is legitimate. But it is important to remember that lack of accreditation need not mean that a school is either inferior or illegal. Authentic accreditation is based on performance, not proposed performance.

We stress the term authentic accreditation, since there are very few laws or regulations anywhere governing the establishment of an accrediting association. Anyone can start a degree mill, then turn around and open an accrediting agency next door, give his school its blessing, and begin advertising "fully accredited degrees." Indeed, this has happened many times.

The crucial question, then, is this: Who accredits the accreditors?

Who Accredits the Accreditors?

The situation is confusing, unsettled, and still undergoing change and redefinition for the third millennium. To get some sort of a handle on the situation, it will be helpful to have a bit of a historical perspective. In this instance, it makes some sense to begin in 1980, when the Republican party platform echoed Ronald Reagan's belief that the Department of Education should be closed down, since it was inappropriate for the federal government to meddle in matters better left to the states and to private enterprise.

At that time, there were two agencies, one private and one governmental, that had responsibility for evaluating and approving or recognizing accrediting agencies:

The U.S. Department of Education's Eligibility and Agency Evaluation Staff (EAES), which is required by law to "publish a list of nationally recognized accrediting agencies which [are determined] to be reliable . . . as to the quality of training offered." This is done as one measure of eligibility for federal financial aid programs for students. EAES also had the job of deciding whether unaccredited schools could qualify for federal aid programs, or their students for veterans' benefits. This was done primarily by what was called the "four-by-three" rule: Proof that credits from at least four students were accepted by at least three accredited schools (12 total acceptances). If they were, then the unaccredited school was recognized by the Department of Education for that purpose. Schools qualifying under the four-by-three rule had to submit evidence of continued acceptance of their credits by accredited schools in order to maintain their status. COPA, the Council on Postsecondary Accreditation. COPA was a nationwide nonprofit corporation, formed in 1975 to evaluate accrediting associations and award recognition to those found worthy. President Reagan was unable to dismantle the Department of Education during his administration, although key people in the department strongly suggested that they should get out of the business of recognizing accrediting agencies, and leave that to the states. "Education President" George Bush apparently did not share this view; at least no significant changes were made during his administration.

One of the frequent complaints levied against the recognized accrediting agencies (and not just by Republicans) is that they have, in general, been slow to acknowledge the major trend toward alternative or nontraditional education.

Some years ago, the Carnegie Commission on Higher Education conducted research on the relationship between accreditation and nontraditional approaches. Their report, written by Alexander Mood, confirmed that a serious disadvantage of accreditation is "in the suppression of innovation. Schools cannot get far out of line without risking loss of their accreditation a penalty which they cannot afford." "Also," the report continued, "loss of accreditation implies that the curriculum is somewhat inferior and hence that the degree is inferior. Such a large penalty... tends to prevent colleges from striking out in new directions... As we look toward the future, it appears likely that accrediting organizations will lose their usefulness and slowly disappear. Colleges will be judged not by what some educational bureaucracy declares but by what they can do for their students. Of much greater relevance would be statistics on student satisfaction, career advancement of graduates, and other such data."

Faced with high-powered criticism of this sort, some accrediting agencies sponsored (with a major grant from the Kellogg Foundation) a large-scale study of how the agencies should deal with nontraditional education.

The four-volume report of the findings of this investigation said very much what the Carnegie report had to say. The accreditors were advised, in effect, not to look at the easy quantitative factors (percentage of Doctorate-holders on the faculty, Books in the library, student-faculty ratio, acres of campus, etc.), but rather to evaluate the far more elusive qualitative factors, of which student satisfaction and student performance are the most crucial.

In other words, if the students at a nontraditional, nonresident university regularly produce research and dissertations that are as good as those produced at traditional schools, or if graduates of nontraditional schools are as likely to gain admission to graduate school or high-level employment and perform satisfactorily there then the nontraditional school may be just as worthy of accreditation as the traditional school.

The response of the accrediting agencies was pretty much to say, "But we already are doing just those things. No changes are needed."

But, with the Carnegie and Kellogg reports, the handwriting was on the wall, if still in small and hard-to-read letters. Things would be changing, however.

In 1987, then Secretary of Education William Bennett (later to become "Drug Czar," and then a bestselling author-philosopher) voiced similar complaints about the failure of accrediting agencies to deal with matters such as student competency and satisfaction. "Historically," he said, "accrediting agencies have examined institutions in terms of the resources they have, such as the number of faculty with earned Doctorates and the number of books in the library. Now [we] are considering the ways agencies take account of student achievement and development."

In 1990, Bennett's successor, Lauro F. Cavazos, while splitting an infinitive or two, said almost exactly the same thing: "Despite increasing evidence that many of our schools are failing to adequately prepare our children, either for further study or for productive careers, the accreditation process still focuses on inputs, such as the number of volumes in libraries or percentage of faculty with appropriate training. It does not examine outcomes how much students learn."

Around the same time, John W. Harris, chairman of the National Advisory Committee on Accreditation, echoed these concerns: "It is not enough to know that teachers have certain degrees and that students have spent so much time in the classroom. The question is, can institutions document the achievement of students for the degrees awarded?"

The accrediting agencies continued to assure us that they do deal with such matters.

In 1992, Secretary of Education Lamar Alexander went further still, issuing an open invitation for new accrediting agencies to come forward and seek his department's blessing, strongly implying that the existing ones were not doing a satisfactory job. And around the same time, high administrators at at least three major universities seriously questioned whether accreditation was necessary for their school. "Why should we spend upwards of $100,000 in staff time and real money to prepare a self-study for the accreditors?" said one administrator. "It is quite likely that the University of Wisconsin would still be taken seriously even if it did not have accreditation."

In 1992, Secretary Alexander flung down an unignorable gauntlet by denying the usual "automatic" reapproval of the powerful Middle States Accrediting Association, because he maintained that their standards for accreditation did not meet the department's. (Middle States had previously denied reaccreditation to a major school because it did not meet certain standards of diversity, including "appropriate" numbers of minority students and faculty. Alexander suggested that Middle States was paying attention to the wrong things. Middle States finally backed down, and made its diversity standards optional.)

When Bill Clinton took office in 1993, the accreditation situation was no less murky, and his choice for Secretary of Education, Richard Riley of South Carolina, seemed more interested in primary and secondary education than in postsecondary. Into this already murky area came two bombshells.

Bombshell #1: First, in 1993, the six regional accrediting associations, claiming that "the concept of self-regulation as embodied in regional accreditation is being seriously questioned and potentially threatened," announced that they planned to drop out of the Council on Postsecondary Accreditation, and start their own new group to represent them in Washington. The Chronicle of Higher Education reported that "some higher-education observers said they questioned the significance of the action [while] others called it disturbing." The president of the American Council on Education said that "Their pulling out is tantamount to the destruction of COPA."

Bombshell #2: He was right. In April 1993, at their annual meeting in San Francisco, COPA voted itself out of existence as of year-end, by a vote of 14 to two, one abstention. One board member, C. Peter Magrath, president of the National Association of State Universities and Land-Grant Colleges, said that he thought COPA "focused too much on the minutiae of accreditation and not enough on the big issues of improving the quality of undergraduate education."

And so, in April 1993, things were indeed unsettled. The six regional associations were apparently planning to start a new organization to govern themselves, without the participation of the dozens of professional accreditors who were part of COPA. COPA was going about its business, but planning to turn off the lights and shut the door by the end of 1993. And the Clinton Department of Education was busily drawing up proposals that would turn the world of accreditation and school licensing on its ear.

The early thrust of the Clinton/Riley thinking echoed much that had been discussed during the Bush/Bennett/Cavazos/Alexander era: giving increased power to the states to decide what can and cannot be done in the way of higher education within their borders. The big stick wielded by the federal folks, of course, was student aid: loans and grants. The prospect of each state having different standards by which a student could get a Pell Grant, for instance, was daunting.

Around this time, Ralph A. Wolff, an executive with one of the regional accrediting associations, wrote an important 'think piece' for the influential Chronicle of Higher Education: "Restoring the Credibility of Accreditation." (June 9, 1993, page B1) Wolff wrote that, "We have constructed a Potemkin Village in which there is less behind the fa?ade of accreditation than we might like to acknowledge. . . . The accreditation process has not held colleges and universities accountable for issues such as the writing ability of graduates or the effectiveness of general-education requirements. . . If accreditation is to regain some of its lost credibility, everyone involved in the process needs to refocus on standards and criteria for demonstrating educational effectiveness. Even the most prestigious institutions will need to address how much students are learning and the quality of student life at the institution."

Right around the time Wolff was writing, the Department of Education was sending out a limited number of "secret" (not for publication or circulation) drafts of its proposed new regulations. And the six regional accreditors apparently rose up as one to say, in effect, "Hey, wait a minute. You, the feds, are telling us how to run our agencies, and we don't like that."

For instance, the draft regulations would have required accreditors to look at the length of various programs, and their cost vis-a-vis the subject being taught.

A response by James T. Rogers, head of the college division of the Southern Association (a regional accreditor) was typical:

If final regulations follow the pattern in this latest draft, the Department of Education will have co-opted, in very profound ways, members of the private, voluntary accrediting community to serve as enforcement for the department. . . . This is an extremely disturbing abdication of the department's responsibility to police its own operation.

The Chronicle reported (August 4, 1993) that "many of the accrediting groups have sent notices to their member colleges urging them to be prepared to battle the department if the draft is not significantly altered."

And David Longanecker, Assistant Secretary for postsecondary education, was quoted in the Chronicle as saying "Many people in higher education say 'You can't measure what it is that we do, it's too valuable.' I don't buy that, and I don't think most people in America buy that today, either."

The battle lines were drawn or, as the more polite Chronicle put it on August 11, 1993, "Accreditors and the Education Department [are] locked in a philosophical disagreement over the role of accreditation." At this point, the six regional accreditors announced they would be joining with seven higher-education groups to form an organization to represent their interests in Washington. This lobbying group was to be called the National Policy Board on Higher Education Institutional Accreditation, or NPBHEIA. And various subsets of the by-now lame duck COPA were making plans to start as many as three replacement organizations to take over some or most or all of COPA's functions.

During the rest of 1993, the Department of Education was busily rewriting its accreditation guidelines, taking into account the unexpectedly fierce "leave us alone" response from the regional and professional accreditors. Meanwhile, Congress, not wishing to be left out of the mix entirely, passed, on November 23, 1993, the Higher Education Technical Amendments of 1993, which, among much, much else, decreed that the Department of Education was to cause each of the 50 states to establish a new State postsecondary review "entity" (SPRE) to evaluate schools within each state, both for compliance with various federal aid programs and, unexpectedly, to evaluate those colleges and universities that have "been subject to a pattern of complaints from students, faculty, or others, including...misleading or inappropriate advertising and promotion of the institution's educational programs...." If that wasn't an invitation for the states to go into the accreditation business, it was certainly in that direction.

Good-bye COPA, Hello CORPA

And while this was going on, the COPA-ending clock was ticking away. Ten days before COPA was to disappear forever, the formation of a single new entity to replace it was announced. COPA was to be replaced with (small fanfare, please) CORPA, the Commission on Recognition of Postsecondary Accreditation. All members of COPA were automatically recognized by CORPA. All COPA provisions for recognition of schools were adopted by CORPA, with the understanding that they might be refined and modified over time. And CORPA's initial Committee on Recognition was composed of the members of COPA's Committee on Recognition. All of this appears to be the academic equivalent of saying that The Odyssey was not written by Homer, but by another Greek with the same name. The only apparent difference between COPA and CORPA is the addition of the "R" and the fact that the six regionals were no longer members.

The Department of Education's guidelines were finally published in the Federal Register on January 24, 1994: 24 small-type pages on accreditors, and 20 more on the establishing SPREs, the State Postsecondary Review Entities. Once the regulations were published, the public and the higher education establishment had 45 days in which to respond. And respond they did. The headline in the next week's Chronicle of Higher Education read: "Accreditors Fight Back."

It turned out that the six regional accreditors, the American Council on Education, and other groups had been meeting privately in Arizona to formulate a battle plan. They considered abandoning the regional approach entirely, in favor of a single national accreditor, but scrapped that in favor of four still-quite-radical ideas (among others):

Establishment of minimum uniform national standards for accreditation;
Setting of higher standards for schools, focusing on teaching and learning (what a novel concept!);
Making public their reports on individual colleges and schools;
and Moving toward ceasing to cooperate with the federal government in certifying the eligibility of colleges for federal financial aid.

During the 45-day response period following publishing of the draft guidelines, hundreds of long and serious responses were received from college and university presidents opposing some, most, or all of the regulations that had been proposed by the Department of Education.

The issue of diversity and political correctness in accreditation remained just as controversial as before. While the Western Association (a regional accreditor) for instance, believes that academic quality and ethnic diversity are "profoundly connected," many colleges, large and small, apparently agree with Stanford president Gerhard Casper, who said, "No institution should be required to demonstrate its commitment to diversity to the satisfaction of an external review panel. The [Western Association] is attempting to insert itself in an area in which it has no legitimate standing." Other schools, including the University of California at Berkeley, defended the diversity policy.

By early May, 1994, the Department of Education backed away from some of the more controversial rules, both in terms of telling the accreditors what to look for, and in the powers given to the SPREs. They did this by continuing to say what things an accrediting agency must evaluate, but only suggesting, not demanding, the ways and means by which they might do it. In addition, SPREs would now be limited to dealing with matters of fraud and abuse, and could not initiate an inquiry for other reasons.

Under the then-final guidelines, accrediting agencies were required to evaluate these twelve matters, but the way they do it can be individually determined:

  • Curricula
  • Faculty
  • Facilities, equipment, and supplies
  • Fiscal and administrative capacity
  • Student support services
  • Program length, tuition, and fees in relation to academic objectives
  • Program length, tuition, and fees in relation to credit received
  • Student achievement (job placement, state licensing exams, etc.)
  • Student loan repayments
  • Student complaints received by or available to the accreditor
  • Compliance with student aid rules and regulations


Everything else, including recruiting, admissions practices, calendars, catalogues and other publications, grading practices, advertising and publicity, and so on.
And that is where we had gotten to by 1996. Then, just when it seemed as things were calming down a bit, two more bombshells (shall we call them #3 and #4?) were dropped.

Bombshell #3: Good-bye CORPA, Hello CHEA

In late 1996, CORPA announced that it was closing down, in favor of a new organization, CHEA, the Council on Higher Education Accreditation, same address, but a new telephone number.

Bombshell #4: Good-bye AACSB, Hello Confusion

For years, the main guideline for determining the validity of an accrediting agency has been whether it is recognized by the U.S. Department of Education (with additional recognition by COPA, CORPA, or CHEA as an added niceness).

Then the U.S. Department of Education determined that the Higher Education Amendments to the laws required it only to recognize those accreditors who help to enable the schools or programs they accredit to establish eligibility to participate in certain federal aid and other federal programs. As a result of this determination, more than a dozen respectable, well regarded, and formerly recognized accrediting agencies lost their Department of Education recognition, including the very prestigious AACSB, the American Assembly of Collegiate Schools of Business, which accredits Harvard, Yale, Stanford, and suchlike.

Does this mean that the accreditation of those nine agencies is no longer as useful? It is too soon to know, but unlikely, since the various professional fields still support that accreditation. The foresters, the social workers, the veterinarians, and so on, still regard accreditation by their professional associations as valuable and so, clearly, do the hundreds of schools that have or seek this accreditation. Finally, it seems more than likely that these nine agencies will retain their recognition by CHEA.

In any event, after decades of minimal interest and attention, the always fascinating world of accreditation is clearly getting more than its fifteen minutes of fame.

Words That Do Not Mean "Accredited"

Some unaccredited schools use terminology in their catalogs or advertising that might have the effect of misleading unknowledgeable readers. Here are six common phrases:

  • Pursuing accreditation. A school may state that it is "pursuing accreditation," or that it "intends to pursue accreditation." But that says nothing whatever about its chances for achieving same. It's like saying that you are practicing your tennis game, with the intention of playing in the finals at Wimbledon. Don't hold your breath.

 

  • Chartered. In some places, a charter is the necessary document that a school needs to grant degrees. A common ploy by diploma mill operators is to form a corporation, and state in the articles of incorporation that one of the purposes of the corporation is to grant degrees. This is like forming a corporation whose charter says that it has the right to appoint the Pope. You can say it, but that doesn't make it so.

 

  • Licensed or registered. This usually refers to nothing more than a business license, granted by the city or county in which the school is located, but which has nothing to do with the legality of the school, or the usefulness of its degrees.

 

  • Recognized. This can have many possible meanings, ranging from some level of genuine official recognition at the state level, to having been listed in some directory often unrelated to education, perhaps published by the school itself. Two ambitious degree mills (Columbia State University and American International University) have published entire books that look at first glance like this one, solely for the purpose of being able to devote lengthy sections in them to describing their phony schools as "the best in America."

 

  • Authorized. In California, this has had a specific meaning (see chapter 7). Elsewhere, the term can be used to mean almost anything the school wants it to sometimes legitimate, sometimes not. A Canadian degree mill once claimed to be "authorized to grant degrees." It turned out that the owner had authorized his wife to go ahead and print the diplomas.

 

  • Approved. In California, this has a specific meaning (see chapter 7). In other locations, it is important to know who is doing the approving. Some not-for-profit schools call themselves "approved by the U.S. Government," which means only that the Internal Revenue Service has approved their nonprofit status for income taxes and nothing more. At one time, some British schools called themselves "Government Approved," when the approval related only to the school-lunch program.

The Second-to-Last Word on Accreditation

There have been quite an extraordinary number of new accrediting associations started in the last few years, and they are getting harder and harder to check out, either because they seem to exist only on the Internet, or because they exist in so many places: an address in Hawaii, another in Switzerland, a third in Germany, a fourth in Hong Kong, and so on. Some new ones have adopted the clever idea of bestowing their accreditation on some major universities, quite possibly unbeknownst to those schools. Then they can say truthfully, but misleadingly, that they accredit such well-known schools. This is the accreditation equivalent of those degree mills that send their diplomas to some famous people, and then list those people as graduates.

The Last Word on Accreditation

Don't believe everything anyone says. It seems extraordinary that any school would lie about something so easily checked as accreditation, but it is done. Degree mills have unabashedly claimed accreditation by a recognized agency. Such claims are totally untrue. They are counting on the fact that many people won't check up on these claims.

Salespeople trying to recruit students sometimes make accreditation claims that are patently false. Quite a few schools ballyhoo their "fully accredited" status but never mention that the accrediting agency is unrecognized, and so the accreditation is of little or (in most cases) no value.

One accrediting agency (the unrecognized International Accrediting Commission for Schools, Colleges and Theological Seminaries) boasted that two copies of every accreditation report they issue are "deposited in the Library of Congress." That sounds impressive, until you learn that for $20, anyone can copyright anything and be able to make the identical claim.

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