This term paper was written in 2019 for a university course, so some of the issues noted in it may already be outdated, but it shows how the accreditation system worked at the time the paper was written.
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Comparing The Higher Learning Commission and Southern Association of Colleges and Schools Commission on Colleges and Recent Changes in Accreditation
by
Ipatia K. Apostolides, B.A., M.F.A.
October 15, 2019
CHAPTER 1
INTRODUCTION
The United States (U.S.) does not have a centralized governing body for higher education as do other nations, nor do higher education institutions' accrediting bodies (Eaton, 2005). Since the early 1900s, the task of overseeing the quality of higher education has been given to private, nonprofit accrediting agencies. Since 2005, these accrediting agencies have reviewed higher education institutions in 50 states and 95 other countries and carry out the following roles: Conduct external quality review, allow for access to federal and state funds by students, help engender private sector confidence, and help ensure transfers between higher education institutions (p. 3-4).
Accrediting agencies are part of the regulatory "triad" that oversees higher education quality, and this includes state authorizing agencies, which ensure compliance with state educational requirements, and the U.S. Department of Education (USDE), which oversees observance to rules of participation in Title IV programs (Rethinking Higher Education). However, during the Obama administration, more and more responsibilities have shifted over to the accrediting bodies, requiring more time and resources (Lederman, 2015).
In addition, accreditors, like SACSCOC, have a say in how a president is chosen in a higher education institution. An example of this is a 2019 letter from SACSCOC to the University of South Carolina, citing that politics may have influenced the choice of their new president Caslen from the governor and that there was "evidence of a significant accreditation-related issue" (Mallory, 2019); the evidence came from WIS 10 News obtaining emails and texts through the Freedom of Information Act (Mallory). The author believes that this action by SACSCOC did not follow their mission statement.
The Obama administration gave rise to stricter adherence to regulations by USDE (Lederman, 2015), whereas the Trump administration is currently turning it around to less regulation. Flores (2019) believes this will give the accrediting bodies less power, extend time frames, and allow higher education institutions more slack. Kreighbaum (2019), on the other hand, offers another viewpoint, noting these changes will enable colleges to receive faster approval for changes to their programs, obtain quicker federal recognition of new accreditors, and allow more targeted and less comprehensive federal reviews of accreditors; in addition, it will give accreditors discretion over when to take action against a college that is not complying with standards. Elisabeth DeVos, Secretary of USDE at the time of this writing, stated: "These changes will allow students to work at their own pace to earn a college degree, obtain credit for proving what they already know, and earn a credential aligned with employers' job requirements" (Kreighbaum, 2019).
This paper will first do a literature review and an overview of accreditation. Then it will discuss in detail the following two regional accreditation agencies: Higher Learning Commission (HLC) and Southern Association of Colleges and Schools Commission on Colleges (SACSCOC), and compare and contrast them in the analysis and also look at some issues that have arisen with accreditation over the years. Finally, it will conclude with a summary.
CHAPTER II
LITERATURE REVIEW
The Higher Education Act (HEA) of 1965 prohibits the USDE from overseeing the quality and academic competence of higher education institutions' instructional programs in the U.S. Instead, it has assigned this role to accreditors who are private, nongovernmental organizations (Rethinking Higher Education). Yet higher education institutions can choose to be or not be accredited since this is a voluntary process. Still, their accreditation is a way to ensure a level of quality in higher educational institutions and, according to Pfinister (1959), has been around since 1913 (cited in Young et al., 1983, p. 3). In addition, pressure to be accredited comes from Title IV of the HEA of 1965, which the USDE created to offer federal aid to students, and only higher education institutions that meet their requirements and are accredited are eligible for this aid; therefore, maintaining an accredited status is essential for the financial survival of many higher education institutions (Hegji, 2017).
Three types of accrediting agencies exist in the United States (U.S.): Regional, national, and programmatic; the regional accrediting agencies are responsible for operating in six regions of the U.S.; the national accrediting agencies, on the other hand, operate nationwide and review institutions with a common theme; and the programmatic accrediting agencies also operate nationwide and review programs and single-purpose institutions (Hegji, 2017).
The accrediting agencies are accountable to the Council of Higher Education Accreditation (CHEA), an organization of U.S. higher education institutions formed in 1996, which oversees and certifies the accreditation agencies by scrutinizing their "effectiveness in advancing academic quality and serving higher education, students and the public" ("Council for Higher Education Accreditation," 2015).
Accreditors are also part of the regulatory "triad" that oversees higher education quality and includes state authorizing agencies, which ensure compliance with state educational requirements, and the U.S. Department of Education (USDE), which oversees adherence to rules of participation in Title IV programs (Rethinking Higher Education).
Institutional accreditation has been defined by Head & Johnson (2011) as the "process by which institutions of higher education are evaluated as a whole with an eye toward their unity of purpose and the extent to which the sum of the parts complements the whole." Another definition of accreditation is given by Eaton (2005) as "a process of external quality review created and used by higher education to scrutinize colleges, universities, and programs for quality assurance and quality improvement" (p.3).
Problems can arise when an accrediting agency accredits a higher educational institution that is going bankrupt; this was the case with the accrediting agency ACIS and Corinthian College. As a result of allowing Corinthian College to maintain accreditation even during bankruptcy, in 2016, the USDE terminated ACICS as a nationally recognized accrediting agency ("Reauthorizing the Higher Education Act," 2015, p.16). This is causing undue pressure on accrediting agencies to ensure that higher education institutions they are accrediting are financially solvent. This threat of termination by the USDE on the accrediting agency results in undue pressure also on the higher education institution. More recently, the USDE, under the Trump administration, is looking to lessen the regulatory burden by having accreditors "look only at academic outcomes and not at issues of governance or financial stability" (Kelderman, 2018).
HIGHER LEARNING COMMISSION (HLC)
The Higher Learning Commission (HLC) is the regional accrediting agency for over 1,000 degree-granting higher education institutions in the following 19 states: Arizona, Arkansas, Colorado, Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Missouri, Nebraska, New Mexico, North Dakota, Ohio, Oklahoma, South Dakota, West Virginia, Wisconsin, and Wyoming. Its jurisdiction includes tribal institutions and distance education and correspondence education ("Accreditation in the United States," 2019). According to the Higher Learning Commission website, prior to 2014, the HLC was part of the North Central Association of Colleges and Schools (NCA). However, as of 2014, the NCA was dissolved, and the HLC became the accrediting agency, having a Title IV federal recognition ("About the Higher Learning Commission," 2019).
The HLC is governed by a Board of Trustees elected by the membership and administered by the president who is selected by that Board; currently, the president is Dr. Barbara Gellman-Danley. The HLC relies on decision-making bodies comprised of institutional representatives and public members for its review process; it has a Peer Corps of about 1,600 faculty and administrators from its 19-state region of institutions ("Peer Corps Roster," 2019). Its mission is "Serving the common good by assuring and advancing the quality of higher learning" ("About the Higher Learning Commission," 2019).
The HLC also has a relationship with the federal government (USDE) and other organizations, such as the CHEA; the HLC was reaffirmed by CHEA in 2015 ("HLC Communication with Other Agencies," 2019).
When the higher education institution applies to HLC, it begins with an Eligibility Process which includes several steps, interviews, and reviews, and when it receives an Eligibility Letter, then it has up to 90 days to apply for Candidacy, and this includes the "self-study or documentation assembled in a self-evaluative process" ("HLC Policy," 2019).
When Candidacy and Initial Accreditation is granted, it is maintained between two to four years. During this time, the HLC makes regular evaluations while the institution progresses toward accredited status through its assessment process ("HLC Policy," 2019). Once a higher education institution receives accreditation, the reaffirmation of their accreditation by HLC is a 10-year cycle; they must decide which of two pathways to choose from Standard Pathway if it has been undergoing dynamic change, or Open Pathway ("HLC Policy," 2019). There used to be a third pathway titled AQIP, but it has been phased out.
HLC's STANDARD PATHWAY
· "It has been accredited for fewer than 10 years.
· It is in the process of a change of control, structure or organization or it has undergone a change of control, structure or organization within the last two years.
· It is under HLC Notice or related action or has been under HLC sanction or related action within the last five years.
· It has pending recommendations for a focused visit or extensive other monitoring, or it has a history of extensive HLC monitoring, including accreditation cycles shortened to seven or fewer years, multiple monitoring reports, and multiple focused visits extending across more than one accrediting cycle.
· It is or has been undergoing dynamic change (e.g., significant changes in enrollment or student body, opening or closing of multiple locations or campuses) or requiring frequent substantive change approvals since the last comprehensive evaluation.
· It is raising or has raised significant HLC concerns about circumstances or developments at the institution (e.g., ongoing leadership turnover, extensive review by a governmental agency, patterns identified in financial and non-financial indicators).
· It has failed to make a serious effort to conduct its Quality Initiative in the Open Pathway" ("Standard Pathway," 2019).
HLC's OPEN PATHWAY
"Regular Monitoring
Institutions submit an annual Institutional Update, which is reviewed by HLC to monitor organizational health, comply with certain federal requirements, and identify any changes that may require HLC follow up. HLC will also apply change processes as appropriate to planned institutional developments, and will monitor institutions through reports, visits and other means as it deems appropriate.
Year 4: Assurance Review
Institutions complete an Assurance Review to ensure they are continuing to meet HLC's Criteria for Accreditation. The institution provides documentation demonstrating how it fulfills each Criterion and Core Component. A peer review team evaluates these materials and recommends whether the institution should continue in the cycle or whether additional monitoring is required. HLC's Institutional Actions Council (IAC) reviews and takes official action on the recommendation.
See HLC's procedural document on the Open Pathway Year 4 Assurance Review for information on preparing the institutional narrative and evidence for this review. It also provides guidance for peer review teams on how to evaluate the institution's materials.
Years 5-9: Quality Initiative
Institutions design and undertake a Quality Initiative project. HLC peer reviewers approve an initial project proposal, as well as a report on the outcomes of the project.
Year 10: Comprehensive Evaluation for Reaffirmation
Institutions undergo a comprehensive evaluation to ensure they are meeting the Criteria for Accreditation, pursuing institutional improvement and complying with certain requirements set by the U.S. Department of Education. This review leads to an action regarding the reaffirmation of the institution's accreditation" ("HLC Policy," 2019).
There are five criteria for accreditation that the HLC evaluates higher education institutions with:
"1) Mission: Clear and publicly articulated
2) Integrity: Ethical and responsible conduct in its financial, academic, personnel and auxiliary functions; establishes policies for fair and ethical behavior on the part of governing board, faculty, administration, and staff.
3) Teaching and Learning: Provides quality education and quality faculty who are evaluated regularly, and articulates intended learning outcomes; provides resources such as infrastructure to support effective teaching (laboratories, libraries, performance spaces, etc.), and support
4) Teaching and Learning: Evaluation and assessment of student learning and achievement of learning outcomes; and education improvement through ongoing attention to retention and completion rates in its degree and certificate programs.
5) Resources, Planning, and Institutional Effectiveness: the institution has the fiscal and human resources and physical and technological infrastructure to support its operations wherever and however programs are delivered; the institution's governance and administrative structures promote effective leadership to enable institution to fulfill its mission" ("HLC Policy," 2019).
The 2015 fees of HLC are listed on the CHEA website ("Accreditation Fees Directory," 2015) and include institutional dues, commission visits, fees for the Academic Quality Improvement Program (AQIP), substantive change fees, and appeal and board hearing fees. The institutional dues are calculated by this formula: Base Dues ($2,600) + FTE Dues ($0.50 per FTE) + Additional Location Dues ($90 x W); where FTE = the number of full-time students + 1/3 part-time students and the W = number of locations (“Accreditation Fees Directory,” 2015).
For accredited institutions, HLC offers workshops in areas such as strategy, assessment, and student success ("HLC Workshops," 2019).
SOUTHERN ASSOCIATION OF COLLEGES AND SCHOOLS COMMISSION ON COLLEGES (SACSCOC)
The Southern Association of Colleges and Schools Commission on Colleges (SACSCOC) is the regional accrediting agency for degree-granting higher education institutions in the Southern states (SACSCOC), and it is located in Georgia. It was founded in 1895 and is comprised of the Council on Accreditation and School Improvement (CASI), which is the K-12 arm, and the Commission on Colleges (COC); the COC was founded in 1917 to develop standards and accreditation of higher education institutions in the Southern states ("Welcome from the President," 2019). Both commissions are autonomous ("Principles of Accreditation,").
SACSCOC recognizes the following 11 states: Alabama, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and Virginia, including international institutions and programs offered via distance and correspondence.
The mission of the SACSCOC is "to assure the educational quality and improve the effectiveness of its member institutions," and its six core values are accountability, continuous quality improvement, integrity, peer review/self-regulation, student learning, and transparency ("Southern Association of Colleges," 2019).
The organizational structure of the SACSCOC includes the College Delegate Assembly (CDA), which has a voting representative from each accredited higher education institution with seventy-seven members elected to the Board of Trustees, and thirteen Executive Council members elected by the Board of Trustees; they are responsible for interpreting SACSCOC policy and procedure ("Commission Organization," 2019). The current president of SACSCOC is Belle S. Wheelan. There are also vice-presidents, directors, coordinators, specialists, and financial/administrative services ("Southern Association of Colleges," 2019).
Prior to a higher education institution applying for membership to SACSCOC, it must attend a mandatory two-day Pre-Applicant Workshop and Pre-Applicant Institutional Effectiveness Workshop at the SACSCOC offices in Georgia ("Southern Association of Colleges," 2019).
Once a higher education institution applies to SACSCOC, it will receive a Candidacy visit by the Candidacy Committee, which consists of five members who will affirm the compliance of the institution to the standards of SACSCOC and will provide a report to the institution in two weeks ("Southern Association of Colleges," 2019). The Accreditation Committee then pays a visit to determine whether to award membership or continue Candidacy or discontinue Candidacy. Once an institution is awarded Candidacy status, it will be authorized to receive an Accreditation Committee visit ("Southern Association of Colleges," 2019). An institution can remain in Candidacy status for up to four years ("Southern Association of Colleges," 2019).
The SACSCOC's Committee on Compliance and Reports would make recommendations concerning the institution's status to the Executive Council of SACSCOC, which, in turn, makes its recommendation to the SACSCOC Board of Trustees, which takes final action on the institution's status ("Southern Association of Colleges," 2019) and rewards its accreditation. This review process could take twelve to eighteen months.
The accreditation standards of SACSCOC include four categories of documents: Policies, guidelines, good practices, and position statements ("Southern Association of Colleges," 2019). For an institution to obtain accreditation, they first complete the SACSCOC application documenting their compliance with the following Core Requirements and Standards ("Southern Association of Colleges," 2019):
Core Requirements | Standards |
1.1 (Integrity) | 4.2.c (CEO evaluation/selection) |
2.1 (Institutional mission) | 4.2.d (Conflict of interest) |
3.1 a (Degree-granting authority) | 5.4 (Qualified administrative/academic officers) |
3.1.b (Coursework for degree | 6.2.a (Faculty qualifications) |
3.1.c (Continuous operation) | 6.2.b (Program faculty) |
4.1 (Governing board characteristics) | 7.3 (Administrative effectiveness) |
5.1 (Chief executive officer) | 8.2.a (Student outcomes: educational programs) |
6.1 (Full-time faculty) | 8.2.b (Student outcomes: general education) |
7.1 (Institutional planning) | 8.2.c (Student outcomes: academic and student services) |
8.1 (Student achievement) | 10.2 (Public information) |
9.1 (Program content) | 10.5 (Admissions policies and practices) |
9.2 (Program length) | 10.6 (Distance and correspondence education) |
9.3 (General education requirements) | 10.7 (Policies for awarding credit) |
11.1 (Library and learning/information resources) | 11.2 (Library and learning/information staff) |
12.1 (Student support services) | 11.3 (Library and learning/information access) |
13.1 (Financial resources) | 12.4 (Student complaints) |
13.2 (Financial documents)* (see note below) | 13.6 (Federal and state responsibilities) |
13.7 (Physical resources) | |
14.1 (Publication of accreditation status) | |
14.3 (Comprehensive institutional reviews) | |
14.4 (Representation to other agencies) | |
14.5 (Policy compliance) |
In addition to these core requirements, required Financial Information for Applicant and Candidate Institutions (Core Requirement 13.2) is listed below:
"(1) separate institutional audits and management letters (audits opinioned on the institution) for its three most recent fiscal years, including the audit for the most recent fiscal year ending prior to the date of the application. Should the end of another fiscal year occur during initial review of the application by SACSCOC staff, that audit must be submitted before review of the application can be completed. In addition, the audit for the most recently completed fiscal year must be provided when seeking authorization by the SACSCOC Board of Trustees to receive a Candidacy Committee visit.
(2) an annual budget that is preceded by sound planning, is subject to sound fiscal procedures, and is approved by the governing board.
(3) a statement of financial position of unrestricted net assets, exclusive of plant assets and plant-related debt (short- and long-term debt attached to physical assets) which represents the change in unrestricted net assets attributable to operations for the most recent year.
Further, throughout the remainder of the process, the institution must provide a separate audit and management letter for the most recently completed fiscal year ending prior to any committee visit or Board of Trustees review for Candidacy, Candidacy renewal, or initial Membership" ("Southern Association of Colleges," 2019).
After being rewarded initial membership, the institution is reaffirmed in five years, which requires completion of the Compliance Certification, a Quality Enhancement Plan, and both Off-Site and On-Site Reaffirmation Committee reviews; thereafter, the institution is reaffirmed every ten years ("Southern Association of Colleges," 2019). At the University of Texas at San Antonio (UTSA), for example, they recently submitted a self-study, called the Compliance Certification Report, to the SACSCOC for review completing a major milestone in the university's 10-year reaccreditation process (Neece-Fielder, 2019). The report took two years to compile, describing UTSA's programs, services, and processes, as well as documentation and data (Neece-Fielder).
All expenses are paid by the institution, including site visits by SACSCOC. The 2018 dues, fees, and expenses of SACSCOC are located on their website, and their formula for dues is the following: Their Dues = Fixed Cost + FTE Equivalent Variable + Educational & General Expenditure Variable ("Dues, Fees, Expenses," 2018).
SACSCOC's power is quite overreaching; it is even having a say on how a president is chosen in a higher education institution. An example of this is a 2019 letter from SACSCOC to the University of South Carolina, citing that the choice of their new president Caslen may have been influenced by external political forces such as from Governor Henry McMaster and that there was "evidence of a significant accreditation-related issue" (Mallory, 2019); the evidence came from WIS 10 News obtaining emails and texts through the Freedom of Information Act (Mallory).
CHAPTER III
ANALYSIS
Both regional accreditation bodies (HLC, SACSCOC) are private, nongovernment organizations and are members of the CHEA who oversees them, along with 58 other accrediting agencies ("Council for Higher Education Accreditation," 2015). The two agencies operate in different regions of the United States and appear to be transparent, as they both have websites with their mission statements and other important information on the accreditation process (SACSCOC; "HLC Policy," 2019). HLC accredits higher education institutions in 19 states as compared to SACSCOC, which accredits 11 states. They both have a Board of Trustees and a president; however, SACSCOC also has an Executive Council that is elected by their Board of Trustees. Both of these accrediting agencies are also part of the triad, which includes the federal government and the state government.
HLC requires several steps to accreditation, which may take up to five years, including the Eligibility Process, followed by the Candidacy Process and Initial Accreditation. Once an institution receives initial accreditation, then they choose either the Standard Pathway if they have dynamic change or the Open Pathway. SACSCOC does not offer these pathways. Once an institution has received accreditation status, it is reaffirmed no later than ten years ("HLC Policy" 2019; "Southern Association of Colleges," 2019).
SACSCOC also has several steps to accreditation; first, they require that the higher education institution attend mandatory workshops ("Southern Association of Colleges," 2019) prior to their application for accreditation, at their headquarters in Georgia, whereas the workshops HLC offers are not mandatory ("HLC Policy," 2019). Once the institution applies to SACSCOC, it will receive a Candidacy visit by the Candidacy Committee. Then, the Accreditation Committee pays a visit to the institution to determine whether to award membership or continue Candidacy or discontinue Candidacy. Once an institution is awarded Candidacy status, it will be authorized to receive an Accreditation Committee visit ("Southern Association of Colleges," 2019). An institution can remain in Candidacy status for up to four years ("Southern Association of Colleges," 2019). Throughout this whole process, there is much that is being done behind the scenes at the institution to obtain documents and compliance.
The SACSCOC's Committee on Compliance and Reports would make recommendations concerning the institution's status to the Executive Council of SACSCOC, which, in turn, makes its recommendation to the SACSCOC Board of Trustees, which takes final action on the institution's status ("Southern Association of Colleges," 2019) and rewards its accreditation. This review process could take twelve to eighteen months. Like HLC, they run in a 10-year cycle for reaffirmation of accreditation ("Southern Association of Colleges," 2019).
The role of accreditation has become more and more complex as distance learning is expanding, for-profit institutions are converting to nonprofit status, as well as institutions having classes in other states ("Rethinking Higher Education," 2018). The Obama administration gave rise to stricter adherence to regulations by USDE (Lederman, 2015), whereas the Trump administration is currently turning it around to less regulation.
Recent changes by the USDE under Trump's administration will affect both agencies on their accreditation process. In April 2019, USDE Secretary Betsy DeVos proposed a new set of rules to deregulate higher education, and a committee was formed to reach a consensus (Flores, 2019). A panel of 15 negotiators, assembled by USDE, participated in negotiated rulemaking that ended in consensus on the changes and included representatives from college groups, regional accreditors, national accreditors, financial aid administrators, and student representatives (Kreighbaum, 2019).
These changes will allow colleges to receive faster approval for changes to their programs, obtain quicker federal recognition of new accreditors, and allow more targeted and less comprehensive federal reviews of accreditors; in addition, it will give accreditors discretion over when to take action against a college that is out of compliance with standards (Kreighbaum, 2019). In addition, Secretary DeVos stated, "These changes will allow students to work at their own pace to earn a college degree, obtain credit for proving what they already know and earn a credential aligned with employers' job requirements" (Kreighbaum).
However, some hidden dangers in these changes were spelled out by Flores (2019): The rules would offer a fast track to outsourcing programs by having them being reviewed by accreditation staff rather than the accreditor's commission; the rules would make it easier for companies to purchase closed campuses and revive failing colleges, and the USDE would extend taxpayer money to closing or failing institutions for up to 120 days after federal aid programs end; the rules would allow new sets of standards to judge new programs and may be less rigorous if the program is tailored to recommendations of employers, and new rules would allow higher education institutions to change their programs and add locations without approval from their accreditor.
CHAPTER IV
SUMMARY
Both the HLC and SACSCOC are regional accreditors of higher education institutions in the U.S.and are similar in many aspects of their accreditation process with a few differences. They both have a Board of Trustees and a president, whereas the SACSCOC also has an Elective Council. They have missions and procedures for higher education institutions to follow in order to be accredited. The SACSCOC has an added step in the accreditation process where they require institutions to attend mandatory workshops before applying for accreditation ("Southern Association of Colleges," 2019).
They both have a 10-year reaffirmation of accreditation cycle, where once a higher education institution is accredited, it is reaffirmed every 10 years ("Southern Association of Colleges," 2019; "HLC Policy," 2019). Their differences are in the number of states they accredit. Even though they've been part of the 'triad' along with the state and federal government, over time, more and more responsibility has shifted to HLC, SACSCOC, and other regional accreditors, and this has forced them to devote their time and resources to issues outside their mission and expertise("Rethinking Higher Education," 2018). For example, in 2019, SACSCOC sent a letter to the University of South Carolina showing concern about their new president Caslen being influenced by external forces (Mallory, 2019). The author believes that SACSCOC had overreached its authority in this case because its mission is "to assure the educational quality and improve the effectiveness of its member institutions," and its six core values are accountability, continuous quality improvement, integrity, peer review/self-regulation, student learning, and transparency ("Southern Association of Colleges," 2019). Therefore, the duty of choosing a new president at a higher education institution that they oversee should not be their responsibility.
Obama's administration added more responsibility to the accrediting bodies (Lederman, 2015), which utilized much of their time and resources. In April 2019, recent accreditation changes were proposed by the USDE that will affect them (Flores, 2019). Since they are part of the triad, which includes the state and federal government (USDE), their accreditation process is influenced by rules handed down by USDE. According to Flores (2019), "Loosening these rules raises the risk that colleges will again abuse loopholes to quickly scale up or fundamentally change operations without meeting quality standards." Yet, Secretary of USDE, Elisabeth DeVos, believes that "These changes will allow students to work at their own pace to earn a college degree, obtain credit for proving what they already know and earn a credential aligned with employers' job requirements" (Kreighbaum, 2019).
In addition to the complex nature of the accreditation bodies and the institutions they are accrediting (long-distance, for-profit institutions, closing institutions, etc.), the author believes that just like Flores (2019), the new deregulation rules by the Trump administration will offer opportunities for higher education institutions to abuse loopholes without concern for quality; thus the ultimate consumer, the student, is affected negatively.
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