Who is responsible for accreditation? Is it the seven regional accrediting commissions across the United States? The U.S. Department of Education, which provides official sanction for the commissions? The faculty and senior leaders of the institution, including the president and the board of trustees? The simple answer is that all play a role, but in today’s turbulent higher education market, governing board members must recognize that their fiduciary duties make them significant players in what is among the most critical evaluative processes an institution undertakes, and one that is increasingly fraught with complexity.
Let’s begin with an example, which exemplifies the critical role of the president and the board. Imagine this scenario:
A group of college representatives, including a new president and the board chair, waits to be called into the accreditation hearing in a designated room. On another floor, a committee of trained reviewers is preparing for the hearing with the institution, previously recommended for a serious sanction. The first task is to discuss the “selfstudy” report of the college and the subsequent visiting team’s report. Several findings demonstrate an institution at risk and out of compliance with required standards. The financial and reputational stakes are high: if accreditation is withdrawn, the institution will lose access to federal financial aid. The review committee plays a key role; its advice will be sent to the regional accrediting commission for a final decision.
Institutional representatives are invited into the room to make their case after the reviewers have completed their analysis. As with many colleges and universities in America today, the president reports several challenges his institution faces, including enrollment declines, increased competition, state disinvestment, the need to close some outdated programs, and an awareness that assessment and program review may be weak. The institutional representatives explain their aspirations and plans to move forward toward resolution, but several cannot be supported by evidence of implementation at the time of the hearing. Accreditors require evidence.
The college’s board chair attends this hearing, as is often the case with institutions facing (or being removed from) sanctions. She graciously informs the committee that she is serving her 29th year as a board member. Her volunteerism is commendable; clearly the chair is very loyal to the institution. She offers accolades about the new president, who holds a deep portfolio of experience and a passionate commitment to the college’s mission. He is indeed impressive. The chair also explains repeatedly that until this president came into office, no one really knew about the many challenges facing the institution. The new CEO is positioned to make all things right, and the trustees realize measurable changes are needed.
Ultimately, the review committee decides that the quality assurance of a sustainable future is simply not there, and recommends the institution for probation. The accrediting commission board affirms the sanction.
Regional accreditation is a voluntary process of self-regulation. For all trustees, the most important quality assurance relationship is with their regional accreditor, the body that accredits the institution as a whole and, through its recognition by the U.S. Department of Education, provides eligible students with access to federal financial aid.
All seven regional accreditors have criteria and standards on governance. They work collaboratively across all regions through the Council of Regional Accrediting Commissions (C-RAC).
Decision-making bodies of regional accreditors comprise representatives of accredited institutions (presidents, chancellors, faculty members, and others) and public members who, along with members of their immediate families, have no relationship to the college or university being reviewed. In some cases, trustees may also be members of decision-making bodies. They take their roles very seriously, reading thousands of pages of documents and reports, and attending hearings and meetings so that they are fully informed, as required by the Department of Education. The work is daunting, time-consuming, and meticulous, yet very important.
A fundamental requirement of all regional accreditors is the institution’s adherence to its mission. At times, the leadership of a college or university becomes mesmerized by “quick fixes” and can be seduced into changing the direction in ways that do not support the existing mission or stated purposes. Strategic thinking and planning may ultimately lead to such a shift, but the administrative officers and board have to own the decision and strategically change the mission, if appropriate.
Missions are also subject to external influences, particularly in the public sphere. Too often, elected officials put pressure on board appointees to carry out an individual or political agenda, which can become very costly both literally and figuratively. A few years ago, when Wisconsin Gov. Scott Walker proposed removing the University of Wisconsin System’s public service mission—known as “the Wisconsin Idea”—the outcry was a historical moment for that state. As reported in the Feb. 15, 2015, issue of The Chronicle of Higher Education, Chancellor Ray Cross tweeted, “The Wisconsin Idea is embedded in our DNA. It is so much more than words on a page. We will work to preserve it in all of its forms.” The governor later said the language in his budget proposal was simply “a drafting error,” and did not make changes to the mission. Accreditors watch these situations very closely and sometimes weigh in to help advance the important values and support of higher education.
BEYOND THE SELF-STUDY
In addition to concerns over straying from mission, there are reasons not reported or revealed in self-studies and campus visits that will lead accreditors to consider sanctions. Both external and internal factors can be red flags that result in accreditation concerns. The following are specific examples from real cases.
- Individual agendas of powerful opinion leaders, often elected officials
- Donors and athletic boosters attempting to influence leadership and decision making
- Community groups weighing in too frequently on the mission or direction of the college and its leaders
- Individuals, businesses, or K–12 systems that will benefit financially from decision making
- Detractors of presidents and chancellors, and attempts to preempt the governance oversight of the college’s trustees
- System leadership with influence over separately accredited institutions
- Political appointees at the state or federal level interested in their “home” institutions
- Grant-making organizations or foundations setting an agenda that does not necessarily support the core mission of a college or university
- Decisions at the state and federal level leading to disinvestment in higher education
- An environment of mistrust in the return on investment of higher education
- Split boards on critical issues, in particular the leadership
- Boards reaching beyond governance into operations
- Tensions between the governing board and foundation board
- A lack of transparency between institutional leadership and the board
- Disputes about shared governance process or authority
- Frequently changing leadership of the college or university, creating a sense of instability
- Faculty holding to commitments and ways of operation that may no longer be applicable in the 21st century
- Weaknesses in faculty credentials, financial statements, and ratio scores
- Enrollment declines and fragile financial situations, with attendant “quick fixes”
- Campus scandals or mismanagement, town-gown issues, and union issues that lead to noncompliance of federal regulations and accreditation’s “integrity” criteria
- Negative stories in the news media
- Distractions of any of the above that take the focus away from the students
There are many positive influences and outcomes as well, and all have an impact on accreditation. We are witnessing a bipartisan national push for “riskmanaged” accreditation, which requires a “lighter touch” for the many successful colleges and universities in America. The intent is to allow the stronger institution more time between visits and less reporting, while weaker colleges and universities require more frequent interactions with accreditors. That may include more campus visits and other forms of monitoring. Some regional accreditors already are implementing this approach, and others are considering it. The Higher Learning Commission began its version of risk-managed accreditation through its Open Pathway option in 2012, which allows less frequency in visits and reporting. Other positive influences include the push for outcomes versus inputs to measure student success and an inclination to consider softening regulations that block innovation. In many cases, new innovations require additional monitoring to validate quality assurance and compliance with the institution’s mission. It is highly advisable that the board and administrators carefully oversee all new innovations and concomitant state, federal, and accreditation guidelines.
CARE, LOYALTY, AND OBEDIENCE
What should governing boards know about their roles in accreditation? Let’s return to the fictional university that began this story. What is wrong? Principally, governance and communication are lacking—governance in terms of fulfilling the fiduciary responsibilities of care, loyalty, and obedience, and communication between institutional leadership and the board.
The board chair, as have many others across the country, generously gave nearly three decades to this institution of higher learning, yet demonstrates a lack of awareness of the duty of care expressed in AGB’s 2015 Board of Directors’ Statement on the Fiduciary Duties of Governing Board Members:
Under the duty of care, governing bodies of colleges and universities are responsible for both the short- and long-term financial health of the institution and achievement of the goal of preserving the institution and its resources for future generations. At the same time, governing boards have the obligation to develop and protect the quality of the institution’s academic programs and to become appropriately engaged in the oversight thereof.
Trustees who do not push for accuracy of information neglect their duty of care. Trustees must take responsibility for the health of an institution, and they cannot deflect ownership when things go awry. They are obligated to know and uncover all the information needed to make informed decisions. The lack of board oversight at the college described above placed accreditation at risk, even though there is no ill intent.
One can argue that former administrators did not communicate to the board the breadth of issues facing the institution. Did previous presidents misunderstand the gravity of the challenges? Or worse, did they choose to act on critical issues without board knowledge or support? Maybe the former administrative team simply did not realize that potential long-term problems could reach an inflection point and threaten the very sustainability of the college. Regional accreditors repeatedly witness plausible denial. The outcomes are not good.
What is apparent, however, is that this trustee chair views the new president as riding in on a white horse and rescuing their beloved institution. He is “the one” who will unveil all the unknowns. The board members are optimistic that accreditors will weigh the strength of the CEO very strongly in their decision. The faith in the president is palpable; understanding the role of the governing board is not.
The duty of loyalty noted in the 2015 AGB statement requires officers and board members to act in good faith and in a manner that is reasonably believed to be in the interests of the college or university and its nonprofit or public purposes rather than their own interests or the interests of another person or organization. Newspaper stories about internecine wars among trustees are a huge red flag for accreditation. When trustees are advancing political or individual agendas, they cannot keep their eye on the most important stakeholder— the student.
As noted in the 2015 AGB statement, the duty of obedience also relates to accreditation:
It is the duty of board members to ensure that the college or university is operating in furtherance of its stated purposes (as set forth in its governing documents) and is operating in compliance with the law. The board should also periodically re-evaluate its purposes and mission and must be prepared to amend or change them when it is necessary and appropriate to do so under the law and the institution’s governing documents.
Fast-forward two years; the president attends a second hearing, which results in removing probation. He repeatedly informs accreditors and a new set of reviewers that the commission’s original sanction decision gave him the ammunition to make substantive changes that strengthen the college. Trustee governance and oversight are more effective, transparency is apparent, and board members are now part of the solution.
Today more than ever, colleges and universities need to work closely with accreditors to find the balance of quality assurance and innovation, as competition for students is growing exponentially. We are so much more than the link to federal financial aid. Our intent is to guide higher education institutions toward a strong future.
Trustees and CEOs serve very important leadership roles in these unimaginably challenging times for academia. The public has lost confidence in higher education; trustees and CEOs have an opportunity and a responsibility to ensure the quality of the education provided by our nation’s colleges and universities. We live in exponentially changing times, and we all share the goal of this country having the greatest higher learning system in the world. Accreditors stand ready to help. Together, we need to rise up to meet the call to action, show willingness to change, and reimagine postsecondary education in America.
For more information on accreditation, see c-rac.org.
12-Step Program for Boards and Institutional Leaders
Given the complexity of factors that can influence accreditation, what should trustees and presidents know about accreditation to be successful? Below are some suggestions for trustees and administrators as they face the accreditation process.
1. Integrate the quality assurance standards and guidelines of regional and specialized accreditation into the regular operations of the institution. Do not wait to get prepared two years (or less) prior to a comprehensive visit. This includes attentiveness to all new innovations, which must adhere to accreditation standards, policies, and guidelines.
2. Budget accordingly to support the criteria and other standards of accreditors (i.e., faculty qualifications, assessment of student learning, and measurement of learning outcomes).
3. Select a very knowledgeable accreditation liaison representative to work with the accrediting agency. Be certain that person does not hold on to all the information learned. It should be integrated into the institutional operations and governance.
4. Be transparent internally and with your accreditors. Trustees and presidents do not like surprises. Neither do accreditors.
5. Work closely with the accrediting commission’s liaison to the institution, and speak up if there are any concerns about the relationship and service.
6. Invite these liaisons, when needed, to visit the campus and present current information about criteria and expectations. Invite trustees to join the conversation. Or, as stated so well in the award-winning musical Hamilton, board members should “want to be in the room where it happens.”
7. Assign a committee or the full board responsibility for receiving updates on accreditation—regional and specialized. The board’s role is to accept responsibility for oversight for accreditation and to continuously reinforce that the administrators ensure the college remains fully in compliance with all standards.
8. Remain current on strategic planning and align the plan with budget and measurable metrics as well as the current directions of accreditation. This includes a commitment to key national initiatives, such as protecting students from sexual harassment and honoring diversity, inclusion, and equity.
9. Avoid historical behaviors that impede continuous improvement. Trustees need to be aware of the challenges CEOs and other leadership may face in trying to effect change. With increased competition, a static institution will be among the many that are merging or, worse, closing under the heavy weight of a changing higher education environment and consumer expectations.
10. Comply with federal requirements, as they will be reviewed by accreditors on behalf of the U.S. Department of Education. They can be arduous, if not completely outdated, in some cases. Contact your congressional representatives about any burdens of over-regulation. It is also critical to communicate if proposed legislative changes may weaken the oversight of value-based compliance, such as sexual harassment.
11. Become or remain active in accrediting agencies’ activities; attend annual conferences and occasionally present to attendees on best practices. Remember that we are membership organizations; members vote on all policies and accreditation standards. Do not wait to weigh in when asked.
12. Advise and support accreditors advocating for higher education in Washington. The Higher Education Act and other legislation hold a great deal of influence on every college and university. Accreditation is closely tied to the federal government and the states; trustees need to be willing to put themselves out there to fight against over-regulation that impedes innovation or lessens a college’s opportunity to serve its students.