Drawing on the lessons of these management-based approaches to quality assurance, a few key design principles emerge for reforming quality assurance in U.S. higher education:
These management-based design principles address a number of the shortcomings of the current system as well as those of performance-based reform efforts. By incorporating benchmarked outcomes in addition to organizational capacity, and using both shared and institution-defined measures, the approach is more rigorously attuned to efficacy than the current approach, and more holistic and sensitive to different institutional goals and contexts than performance-based quality assurance. This combination of flexibility and rigor creates pathways for innovative providers to enter the market, while enhancing monitoring of those new entrants. A requirement to reference peer programs in setting benchmarks creates an opportunity for learning across programs.
Differentiated results provide better consumer information, better formative feedback, and allow differentiated consequences. More frequent and focused review means that programs will have greater motivation to take feedback seriously, while also having less burdensome review processes. Greater frequency also makes it easier for reviewers to take action to address problems as they arise and before they accumulate.
Based on the evidence presented here, the logic of the approach, and the relationship with the existing system, we believe these design principles represent both a feasible and meaningful improvement in higher education quality assurance. But how likely is it that this shift will take place? And by what mechanism would it occur?
There is a federal legislative pathway to these reforms. With the White House and both houses of Congress now under the same party, the prospects for a reauthorization of the Higher Education Act may have improved. Moreover, the design approach we have outlined here has the benefit of representing something of a compromise position between defenders of the current system and advocates of performance-based systems. It increases accountability for outcomes and efficiency while also preserving flexibility in the process for differences in institutional context, and avoiding direct regulation by the federal government. To effect these changes, Congress could amend Title IV of the Higher Education Act to define eligibility to receive federal financial aid to require program accreditation according to these design principles–as opposed to accreditation that addresses the 10 minimum standards identified in the 1992 amendments. Amendments could also relax some of the other requirements for financial aid eligibility, such as the minimum program hours requirement, that inhibit innovation, while dedicating more regulatory resources to emerging actors to ensure accountability. Finally, legislation could shift the focus of the Education Department’s review and recognition of accreditors from the current emphasis on how they monitor compliance with various, specific, administrative requirements to accreditors’ demonstrated capacity to assess and reinforce educational quality and financial stability.
While a federal legislative approach, tied to financial aid eligibility, would yield the most comprehensive shift, it may also be possible—and more feasible in the current political environment—to pursue many of these changes without the involvement of the federal government. Existing accreditors could adjust their processes to align to the design principles, and should build on previous joint efforts to coordinate changes and share practices. Several accreditors have already begun to experiment with more-frequent review of a subset of standards and common measures of student outcomes, and all seven regional accreditors have expressed intent to accommodate competency-based approaches. New entities could emerge to offer a process like the one described, seek recognition as accreditors, and recruit non-traditional providers to participate. States may also amend their licensing and approval processes to align to the design principles, or seek recognition as accreditors themselves.
Simply requiring accreditation aligned to the design principles is not guaranteed to improve institutional processes or student outcomes. One risk is that a poor implementation of the design principles would not be different from the current system. To mitigate the risk of poor implementation, there must be meaningful oversight (by the federal government or another authority) of the accreditors or other third-party quality assurance entities. Such oversight could, perhaps, be augmented with a peer validation process among accreditors, coordinated by the oversight authority, to promote identification and sharing of best practices. Another risk, even if the design principles are implemented well, is that greater transparency around shortcomings and improvement, and the dynamic nature of the process itself, could undermine confidence in the sector or in the process. That risk warrants careful consideration of which information is reported publicly versus shared with providers on a formative basis. Finally, accreditors and institutions and their stakeholders must approach the accreditation process, and other regulatory actions, as opportunities for learning and capacity building, rather than exercises in compliance. This would represent a substantial shift in perspective for many participants in the process, who are entrenched in the way things have always been. Creating opportunities for early, small “wins,” in which a revised process demonstrates some value to all parties involved, will be critical.
Quality assurance for higher education in the United States is a topic of much debate. The urgency of increasing student outcomes, decreasing costs, and accommodating changing instructional models requires that quality assurance and accreditation schemes adopt new practices while keeping bad actors out of the sector. In order to accomplish this, we believe that much of the current system of quality assurance in the United States, including the roles played by the federal government and regional accreditors; the process of self-evaluation, site-visits, and peer reviews; and the focus on institution-specific processes should be maintained. But, we have also identified a number of ways in which this system could be improved to balance greater rigor and transparency with greater flexibility and incentives for institutional improvement and learning. Grounded in a management-based theory of regulation, the design principles aim to reinforce institutional capacity for continuous improvement in processes and outcomes, backstopped by minimum standards. Ultimately, we would expect this system to provide students with access to a diverse set of postsecondary experiences that are more consistent in improving the quality of learning and the likelihood of earning a valuable credential.
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