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Going Public

January 26, 2010

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As the Council for Higher Education Accreditation gathers for its 2010 Annual Conference this week in Washington, I want to urge a change in the way we do accreditation in the United States to strengthen how it supports public accountability.

Let’s require that every institution of higher education prepare a "public learning audit" as part its accreditation materials. This would be a stand-alone statement disclosing the evidence that the institution has regarding student learning, and commenting on why the institution takes the approach to assessing learning that it does. The college or university would itself prepare the statement. The statement would be reviewed by the visiting team during periodic accreditation cycles, and approved by the relevant accrediting body. The learning audit would be publicly available to anyone, placed on the Web sites of the institution in question and of the accrediting body.

Earlham College’s public learning audit would highlight some aspects of our results from the National Survey of Student Engagement and the Collegiate Learning Assessment, and it would provide a link to our full scores on these instruments. It would also discuss the quite varied program by program assessments we do in each of our majors. It might discuss our growing interest in and experimentation with electronic portfolios of student work. And finally it would say something about what we have learned from assessment that is leading us to make changes to improve the education we offer. These elements are an honest reflection of what we are doing about assessment at Earlham, an approach we believe works well for our liberal arts mission. Another institution, one with a different mission or even a different perspective on how to carry through good assessment, would include other elements in their public learning audit.

Why do we need such public learning audits? An exchange between Peter Ewell (vice president of the National Center for Higher Education Management Systems) and the members of the Spellings Commission in the spring of 2006 was one of the more interesting but less constructive moments in the hearings that preceded the commission’s report. Ewell patiently reminded commission members that virtually every step toward better and more widely-conducted assessment of learning in higher education over the previous quarter century had happened because of accreditation. He showed that a good deal of progress had been made. Both at that session and in their final report, commission members, on the other hand, made it clear they had lost patience with accreditation.

“Accreditation, the large and complex public-private system of federal, state, and private regulators, has significant shortcomings,” (p. 14) concluded the Spellings Commission in its final report. No, not everyone would agree that the parenthetical phrase is an accurate, brief description of accreditation. Nevertheless, “significant shortcomings” is a blunt, clear conclusion. The report goes on to say “Accreditation reviews are typically kept private, and those that are made public still focus on process reviews more than bottom-line results for learning and costs” (p. 14). And later in the report, “Higher education institutions should make aggregate summary results of all postsecondary learning measures, e.g., test scores, certification and licensure attainment, time to degree, graduation rates, and other relevant measures, publicly available in a consumer-friendly form as a condition of accreditation” (p. 23).

There has been steadily rising agreement from all sides that we need to put more focus on learning outcomes in accreditation, but on the question of making accreditation more public we have been in a stalemate for years. Critics (such as those on the commission) have insisted that accreditation self-studies and visit reports be made public. Defenders of the current system argue that making these documents public would undermine the candor needed to make these documents useful for institutional improvement. Besides, note defenders, accreditation self-studies and visit reports are lengthy, complex documents; no one in the public would really want to read them.

Public learning audits would provide a middle ground and break the stalemate. Accrediting agencies would provide a rubric for preparing these statements. Colleges and universities would have considerable latitude within these rubrics about how to assess student learning. That latitude would allow an institution to shape its report around its mission(s), and to make its own choices regarding instruments or approaches for assessing learning. These statements would be prepared as stand-alone documents, with institutions knowing that these statements would become public.

Ten years (the normal length of time before an accreditation needs to be renewed) would be too long a shelf life for these learning audits, so the public learning audits would be revised every two years. At the time of re-accreditation, visiting teams would look back over the sequence of statements to assure that these were forthcoming and adequate.

We do not need to require that all the materials prepared for accreditation be made public. But we need to recognize, all of us, that the effectiveness of an institution of higher education with regard to student learning is a legitimate focus of public accountability. Any college or university enrolling students who receive federal financial aid should be subject to such accountability. Public learning audits would be a useful vehicle for providing such accountability. We do not need Congress or the Department of Education to act. Accrediting bodies could make the change themselves.

Douglas C. Bennett is president of Earlham College.

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Comments on Going Public

  • Why not address other transparency issues as well?
  • Posted by Glen S. McGhee , Dir., at Florida Higher Education Accountability Project on January 26, 2010 at 11:30am EST
  • Why not address the transparency issues for the other standards promulgated in the 1992 amendments of the HEA, not for just learning outcomes?

    According to House Conference Report (No. 102-630) on Sec. 496 of PL 102-325 (106 Stat. 448), "Both the Senate and House bills require the Secretary to establish minimum standards for accreditation associations ..." (523).

    These "minimum standards" include:
    (i) Success with respect to student achievement in relation to the institution's mission, including, as appropriate, consideration of course completion, State licensing examination, and job placement rates.
    (ii) Curricula.
    (iii) Faculty.
    (iv) Facilities, equipment, and supplies.
    (v) Fiscal and administrative capacity as appropriate to the specified scale of operations.
    (vi) Student support services.
    (vii) Recruiting and admissions practices, academic calendars, catalogs, publications, grading, and advertising.
    (viii) Measures of program length and the objectives of the degrees or credentials offered.
    (ix) Record of student complaints received by, or available to, the agency.
    (x) Record of compliance with the institution's program responsibilities under Title IV of the Act, based on the most recent student loan default rate data provided by the Secretary, the results of financial or compliance audits, program reviews, and any other information that the Secretary may provide to the agency ... (34 CFR 602.16)

    Yet, it is a mystery why statutory requirements for "State licensing examination and job placement rates" have been only met piecemeal. Why the big delay?

    Equally mystifying is why the Spellings Commission needs repeat requests for data already authorized by statute:
    “Higher education institutions should make aggregate summary results of all postsecondary learning measures, e.g., test scores, certification and licensure attainment, time to degree, graduation rates, and other relevant measures, publicly available in a consumer-friendly form as a condition of accreditation” (p. 23).

    The authority for all this has already been delegated to the accrediting associations (59 Fed Reg No. 82, April 29, 1994), why not just hold them to it?

    Since ten years is "too long a shelf life for these learning audits" (but apparently not long enough to guarantee compliance with outstanding recommendations), they would need to "be revised every two years" and "visiting teams would look back over the sequence of statements to assure" compliance.

    Good idea. In addition to shortening the review cycle, why not make Corrective Action Plans (CAP) a feature of accreditation processes, as they are in all other areas where the federal government has a material interest?

    In case you haven't noticed, the US Dept of Ed has already moved in this direction by now expecting that "past history" and "previous reviews" are included in current reviews to "ensure they review and analyze key data and indicators." (74 Fed Reg No. 206, Oct. 27, 2009).

    "We do not need to require that all the materials prepared for accreditation be made public."

    This may be a moot point, at least in Florida. Florida Courts have recently ruled that NCAA "confidential" documents are public records, especially where confidentiality is used to evade public accessibility. It may be that the current lack of transparency for accreditation documents invites similar challenges.

  • Posted by Math Prof on January 26, 2010 at 11:30pm EST
  • "The college or university would itself prepare the statement." Ha ha ha! All we would do is tell you what a great job we are doing. Or worse, we'd dumb down our programs so that various 'objective metrics' would look good, as the high schools are doing.

    Here is a better way. Survey the American people regularly on their educational experience, career satisfaction, reading habits, health and the like. Ask what high school the went to, what grades did they get, which colleges they attended, what their GPA was and what degrees if any did they earn. Of course self reporting has problems but over the years a data base of information would be built up and people couple see if a degree in Communications from Middle State U. means squat or if a C high school student is better learning a trade at a C.C. or trying to get an Engineering degree from a four-year-college that is desperate enough to take their money.

    Think of it this way. If you want to know what car to buy, you don't ask the dealers about the safety and reliability of the cars they sell, you go to Consumer Reports. We need somebody, maybe a non-profit group, to play this role in education.

  • Posted by jim on January 27, 2010 at 8:30am EST
  • "Math Prof" has gotten it exactly right!!!