From Ohio’s College Credit Plus to Hawaii’s Running Start, dual enrollment (sometimes called dual credit) programs are spreading all over the nation. In these programs, eligible high school students can take certain college courses as part of their high school education. As Hawaii’s program name implies, dual enrollment is intended to give high school students a running start on gaining a college education.

Dual-enrolled students are now a significant portion of college enrollment. Fall 2022 estimates indicate as many as one in five community college students, or 1.4 million, are high school students.1 In spring 2024, dual-enrolled high school students accounted for more than one-quarter of the undergraduate enrollment increases from the previous semester. While 70 percent of dual enrollment students are enrolled at community colleges, the remaining 30 percent attend four-year institutions. Whether earning just a few credits, completing a certificate, or pursuing an associate degree, more young Americans are opting to start their post-secondary career early. 

High school students who take dual enrollment courses are more likely to graduate high school, enroll in a post-secondary institution, and receive a post-secondary degree. Despite the growth of dual enrollment, however, gaps in access remain, with four out of every five school districts showing racial equity gaps in access to dual enrollment. Low-income students, students of color, English language learners, and students with disabilities all participate in dual enrollment at lower rates than their counterparts. For historically underrepresented students, including low-income and rural high school students, dual enrollment can help ease the transition to post-secondary education, reduce time to degree or certificate, and offer cost-savings when students can transfer the credits from courses they complete satisfactorily. 

With so many students pursuing dual enrollment, who ensures accountability for these programs? That is, who makes sure that the running start to college that these programs are intended to give students is a high-quality, effective way for them to begin higher education? And who makes sure that the students who would most benefit from dual enrollment have access to these programs? Does the fact that these programs exist at the boundary of secondary and postsecondary education impact oversight? 

This commentary will first briefly describe what dual enrollment is, then review the roles of various players in maintaining dual enrollment program quality, most particularly college accreditors. It then concludes with a series of recommendations for accreditors, states, and other stakeholders to improve quality and equity of dual enrollment programs.

What Is Dual Enrollment?

Dual enrollment most commonly refers to programs that enable high school students to be enrolled in their high school as well as a post-secondary institution at the same time.2 The concurrent enrollment in a high school and post-secondary institution is what differentiates dual enrollment from similar programs like Advanced Placement (AP) and early college high school initiatives.3 Additionally, while the College Board does not require Advanced Placement teachers to have special training, instructors of dual enrollment courses—regardless of where they are conducted—must meet the same expectations as instructors of similar college courses. Students have the option of attending dual enrollment courses in a variety of settings and modalities; courses may be offered on-site at a student’s high school, online (synchronous and asynchronous), hybrid, or at a post-secondary institution. Students who complete dual enrollment courses receive academic credit from the post secondary institution they are enrolled in.4

High school students taking these advanced courses are expected—at least in theory—to adapt to the academic rigor and expectations required of other post-secondary students taking college courses.

High school students taking these advanced courses are expected—at least in theory—to adapt to the academic rigor and expectations required of other post-secondary students taking college courses. Dual enrollment students should also receive appropriate levels of academic support and access to resources from the post-secondary institution and their high schools. The expectations about academic rigor, faculty qualifications, and student support services in dual enrollment programs may be set by legislation at the state level but they are also enforced through postsecondary accrediting agency standards.5 Institutions of higher education use the accreditation process to signal to other institutions, the government, and prospective students that all of their programs, including dual enrollment, meet appropriate levels of quality.

How College Accreditors Set Quality Standards for Dual Enrollment

Because dual enrollment students are receiving credit for their coursework, post-secondary and high school programs serving these students must be held to the same academic rigor standards as traditional college courses for matriculated students. An accrediting agency’s standards are an accountability framework for evaluation and review that all institutions’ programs must meet, including dual enrollment programs. Dual enrollment students are entitled to the same quality education as traditional students. Accreditation standards generally draw no distinctions between the two, though secondary students may also receive additional program supports from their high school. Regardless of the location or modality of the dual enrollment student, the course content must meet institutional and accreditor expectations.

Accreditation standards apply to all courses and programs of an institution, so any dual enrollment program with a higher education partner must comply with that institution’s accreditation standards. In addition, some accreditors have explicit standards that apply to dual enrollment programs. For example, in its standards on “Integrity in the Award of Academic Credit,” the New England Commission on Higher Education (NECHE) specifically states that courses and programs offered for credit off campus, including at high schools through dual enrollment, must be consistent with the educational objectives of the institution and that the post-secondary institution is solely responsible for the academic quality of all aspects of these programs. The Distance Education Accrediting Commission (DEAC) mentions dual and concurrent enrollment once in the appendix of its accreditation handbook under “Special Circumstances that Warrant Waivers of DEAC Standards & Procedures.”6 Under “Policies Pertaining To Institutions,” the Transnational Association of Christian Colleges and Schools (TRACS), an institutional accrediting agency with forty-three institutions, identifies eight dual enrollment policies pertaining to: notification, faculty, curriculum and instruction, institutional effectiveness, library and learning resources, academic and student support services, admissions and transparency, and facilities. Others make no specific reference to dual or concurrent enrollment in their procedures and accreditations standards.

Predictability and Consistency in Credit Transfer

Earning college credits while in high school does not guarantee a shorter path once in college. Decisions about whether to accept transfer credits are mostly left to the discretion of the receiving institutions. While some students will matriculate at the same two- or four-year institution they were enrolled in for dual enrollment, others will explore different colleges and programs. The college credit transfer process is rife with challenges and students may face credit loss as a result of institutional policies or see their credits, but not their grades, transfer. There isn’t a consistent policy across accreditors or across institutions on whether a specific numerical grade is required for a student to receive the credit or if simply passing the course is sufficient.7Likewise, how an institution will scrutinize whether another school’s course is “equivalent” to a course it offers is often left to the admissions or registrar’s office where the student is enrolling. Students enrolled in dual enrollment need to understand course and credit transfer policies between their home institution and other college programs which is crucial for ensuring students avoid taking extra/unnecessary courses. Even institutions with the same accreditor and within the same state public education system may evaluate a course differently, creating confusion and frustration for students.

Earning college credits while in high school does not guarantee a shorter path once in college.

While dual enrollment students have the opportunity to reduce their time to degree or certificate and the associated costs, they can only access this benefit if their credits transfer. To address this issue, some states have required that public colleges and universities accept dual enrollment credits, but credit loss remains an issue for many transfer students, including those who do dual enrollment. NECHE, a formerly regional accreditor with 203 institutional members, requires that each institution’s credit transfer policy be publicly disclosed on its website and in other relevant publications. The Higher Learning Commission (HLC), another former regional accreditor for postsecondary institutions in the central United States, also specifies that the institution is responsible for informing students clearly and accurately whether courses taken for dual credit will transfer to other institutions. In general, transparency is severely lacking in the credit transfer process, which is particularly unfortunate for dual enrollment community college students as complicated transfer policies make it harder for transfer students to earn a four-year degree. Even when transfer policies are posted, students may not have school or course level information on credit mobility or applicability of credit, adding further opacity to the process.

Faculty Qualifications

Another area where accrediting standards are relevant to dual enrollment is faculty or instructor qualifications. Dual enrollment courses may be taught by adjunct faculty, full-time college faculty, graduate students, or high school teachers who meet the qualifications. Most accrediting agencies have faculty qualification standards that detail what credentials or training faculty members must possess to teach a course. High school teachers that serve as instructors for dual enrollment coursework often receive instruction from both the post-secondary institution and their high school, but their school’s expectations and the tendency of high school teachers to be more lenient may contradict the expectations of the postsecondary accreditor, undermining implementation and course rigor. 

While faculty criteria and competency standards may vary by accreditor, most require an institution to justify and document the qualifications of its faculty members. In addition to the federally recognized accreditor standards for instructor qualifications, most states also specify instructor qualification requirements for at least one of their dual enrollment programs through state policy. More than half of U.S. states require that instructors meet the postsecondary institution’s specified faculty qualifications and nine states require faculty in dual or concurrent enrollment programs to hold a graduate degree. 

Southern Association of Colleges and Schools Commission on Colleges (SACSCOC) requires that the “instructor of record” in dual enrollment courses possess the same academic credentials and/or documented professional experience required by the institution of all of its faculty. Each of the 753 SACSCOC accredited institutions are responsible for documenting the qualifications of any dual enrollment instructors, whether they’re high school teachers or not, and including them on the faculty roster for review by the SACSCOC committee. Full-time faculty are also expected to teach and/or provide appropriate oversight for dual enrollment courses. While “appropriate” is not defined in the standards it seemingly refers to a level of instruction that meets standards for integrity, teaching, and learning. The SACSCOC policy echoes, as others accrediting agencies do, that content and rigor of dual enrollment courses be comparable to that of the same courses taught to the institution’s other students. 

In winter 2023, HLC revamped its faculty qualification policy. The new policy allows institutions of higher education to determine their own faculty qualification standards. The more than 900 institutions accredited by HLC also have the option of utilizing the previous rule, which required that instructors possess an academic degree relevant to what they are teaching and at least one level above the level at which they teach. It’s worth noting that many high school teachers do not have advanced graduate training in specific disciplines because it is not a requirement of high school teacher licensure, as such the majority of these teachers would be ineligible under the strictest faculty qualification standards, at least without obtaining another advanced degree first. Likewise, high schools that largely serve students of color are less likely to offer any dual enrollment courses. The old rule also required a full list of its instructors and their academic credentials be made available to students. 

HLC’s new rule opens up the possibility that institutions could adopt standards that allow for considerations other than degree type held or number of credit hours completed toward a credential when determining faculty qualifications to teach dual enrollment courses. For example, the institution may consider an instructor’s minimum threshold of experience, research and/or scholarship, recognized achievement, and/or other activities and factors. This policy change could allow instructors with expertise and training in a field or licensed profession where people do not traditionally earn advanced degrees or where advanced degrees programs (such as metalwork and fabrication or cosmetology) are not offered to still qualify to be instructors in a program where students are pursuing an associate or bachelor’s degree.8 Instructors with practical knowledge of the field who can provide students an industry-focused education as well as mentorship are crucial for success. This could be helpful in expanding the pool of available instructors for high-demand workforce training and educational opportunities related to skilled trades or for technical classes, which would in turn help more students have an opportunity to get a jumpstart on these careers by gaining credits in high school. While this policy change may open pathways for career and technical education (CTE) or other work-based learning dual enrollment programs, it remains to be seen whether other agencies will see this as a model worth replicating. Additionally, given the number of other agencies that regulate dual enrollment, it’s difficult to understand how changes to accreditor policies and procedures will interact with existing legislation and standards. While flexible requirements about faculty qualifications may be good for access, they are potentially problematic unless institutions also update their assumptions and reflect the change in their credit acceptance policies. Additionally, steps must be taken to ensure this change in policy does not result in loss of rigor and academic standards. 

Review of Proposed Programs

Accreditors may occasionally call for special or additional reviews when an institution undergoes a change like a merger, change in ownership, offering courses at a higher or lower degree level than currently authorized, adding graduate programs when an upper division did not previously exist, and more. Under U.S. Department of Education regulation, accreditors must review any proposed changes an institution makes that are significant departures from the educational mission, programs, or mode of delivery since the institution’s last accreditation review. Some changes like changes in educational programs, changes in modality or entering into a contract for an unaccredited education provider to offer 25–50 percent of a program do not require approval by the commission of the accrediting agency. While establishing a dual enrollment program with a high school is a change it generally carries low-risk and will not fundamentally change the institution or educational mission. An accreditor may still require institutions that enter into these partnerships to ensure appropriate notification and prior approval of off-campus instructional sites where dual enrollment courses and programs are offered but only if needed. 

When a college establishes a joint, dual, or concurrent degree program with a high school, or in a field of study, degree level, or mode of delivery not previously included in the institution’s accreditation, this substantive change proposal is evaluated at the accreditor’s next regularly scheduled meeting. The proposal may be approved, deferred pending additional information, or disapproved. Compliance with the substantive change reporting and approval standard are the key for getting dual enrollment programs off the ground. The NECHE review requires high school faculty to meet the teaching, learning and scholarship standards outlined by the accreditor. The substantive change application requires a list of faculty and their qualifications, NECHE also notes if the dual enrollment faculty member doesn’t meet the institution’s criteria for faculty qualification the applicant should explain how they determined the person is qualified to teach the course. TRACS asks institutions offering dual enrollment courses and programs to notify the agency of the dual enrollment instructional locations by submitting the appropriate Non-Substantive Institutional Change Form.

Recruitment and Eligibility

NECHE’s “Policy on Dual Enrollment Programs” also outlines how institutions can prepare substantive change proposals for dual enrollment programs. NECHE requires commission review of dual enrollment programs as a “substantive change”9 before implementation if the high school instructors are not selected, supervised, and evaluated by the institution. For example, the guidelines provide an expectation that an institution can demonstrate how it will ensure dual enrollment students are prepared for college level coursework and how they’ll be recruited. Institutions submitting substantive change applications must describe how students will be recruited and how the institution will maintain appropriate oversight of recruitment materials and enrollment decisions. The recruitment process can look different across secondary and postsecondary institutions with some using co-branded messaging to inform students and families about their programs (and student eligibility requirements). It can also be targeted recruitment to underrepresented students like distributing materials in multiple languages. 

While inclusive communications strategies can help marginalized students learn about dual enrollment, the best way to grow equitable programs is to rethink enrollment criteria.

Too few students get the opportunity to participate in dual enrollment, but more robust recruitment efforts can change that. While inclusive communications strategies can help marginalized students learn about dual enrollment, the best way to grow equitable programs is to rethink enrollment criteria. While some level of vetting may be educationally necessary, students can be locked out of dual enrollment by overly rigid requirements, such as minimum standardized test scores and nonessential prerequisites. Likewise, there are students who may be able to demonstrate proficiency or academic readiness in a subject but can’t simply because the pre-requisite course is not offered in their high school. When reviewing how students will be recruited for dual enrollment programs, accreditors should evaluate whether recruitment is strategic, inclusive, and responsive to student and district needs. 

TRACS specifies in its Admissions and Transparency policy that advertising, recruiting, and admissions information for dual enrollment students must adequately and accurately represent the programs, requirements, and services available. Similar to other accreditor standards governing integrity and ethics in advertising, TRACS reiterates that statements and other representations about credit transferability must be accurate and transcription practices for dual enrollment students must be consistent with those in effect for all other students. 

HLC also outlines specific guidelines for dual credit courses, or those courses that are taught to high school students for which the students receive both high school and college credit. HLC reviews dual credit activities at least at the time of an institution’s comprehensive evaluation.10 Dual credit courses or programs must have equivalent learning outcomes and levels of achievement to its higher education curriculum.

It’s worth noting here that dual enrollment programs across the country and occasionally in the same state have different student eligibility criteria. A look at New England states reveals just how varied the recruitment and enrollment processes for dual enrollment are. Maine’s Aspirations Program, which allows high school students in the state to receive academic credits toward a high school diploma, and a post-secondary degree,11 requires students to have a 3.0 GPA,12 have parent approval and school unit approval, and have satisfactorily completed any course prerequisites. Massachusetts’ Commonwealth Dual Enrollment Partnership does not have a GPA requirement, but students must be state residents, enrolled in a public or nonpublic secondary school and meet all course prerequisites per the policies of the participating college or university. Many but not all states have specific eligibility requirements including, SAT/ACT score, minimum performance on a state examination, and/or minimum overall or subject area GPA requirements, as previous academic performance is an important indicator for the likelihood of success in dual enrollment. Dual enrollment programs have a vested interest in ensuring that participating students are likely to pass the courses. Students enrolled in dual credit courses, or courses for which they receive both high school and college credit for the same course, that do not pass a course face an additional burden because a failing grade can also affect their high school completion.

Who Else Is Responsible for Evaluating Dual Enrollment?

As of May 2022, forty-eight states and the District of Columbia have policies that regulate the design and implementation of dual or concurrent enrollment. State policy may dictate which students are eligible, which institutions are allowed or required to participate in dual enrollment, requirements for credit transfer, and quality and data reporting requirements. For example, several states, including Florida, Indiana, Kentucky, Maine, Maryland, Michigan, and Mississippi, require every high school in the state to participate in the dual enrollment program.13 While Illinois and Indiana specify that dual credit coursework is transferable to all public institutions in the state, Alaska and Wyoming do not state which postsecondary institution types are required to accept credits in the state policy. New Jersey’s policy on high school enrollment in college courses states that district boards of education and partner colleges shall ensure that college courses for high school students are taught by college faculty with academic rank. Adjunct faculty and members of the district staff who have a minimum of a master’s degree may also be included. Louisiana policies state that dual enrollment instructors must meet the postsecondary institution’s policy on minimum faculty qualifications required to teach the dual enrollment course as required by the accreditor.14 To address some of the transparency and predictability concerns around credit transfer policy, states like Florida utilize common numbering and articulation policies while Indiana gives students course and institution-level information through its Core Transfer Library. These state requirements support broader access or other goals. 

As they respond to calls for increased technical education, some accreditors of specific programs, such as nursing, have also assumed responsibility for the oversight of CTE and postsecondary vocational programs. For example, public postsecondary education programs in the field of practical nursing programs in New York State come under the oversight of the New York State Board of Regents, State Education Department, Office of the Professions (Public Postsecondary Vocational Education, Practical Nursing).

In addition to the federally recognized accreditors that oversee Title IV institutions offering dual enrollment, there is a professional association, the National Alliance of Concurrent Enrollment Partnerships (NACEP), that started setting standards for dual enrollment programs in 2003. NACEP is one of the main sources states look to on dual enrollment standards. While not required, some state concurrent enrollment programs encourage colleges to participate in the NACEP accreditation process. The agency’s standards apply to both concurrent enrollment partnerships and college-provided faculty model programs.15 At present, 134 concurrent enrollment partnerships hold NACEP accreditation across 132 institutions. These include two and four-year, public and private institutions across twenty-six U.S. states. The NACEP standards cover six areas: partnership, faculty, assessment, curriculum, students, and program evaluation. NACEP’s work to center and elevate practitioners in the field of concurrent enrollment is similar though not identical to that of other accreditors. While they evaluate quality, the focus is on practitioners and the formal partnerships between the secondary and post secondary institutions. The goal of NACEP’s standards is to ensure that resources and education provided to high school students through dual enrollment programs is consistent with those provided to traditional college students. Likewise, NACEP seeks to ensure that all students have equitable access to quality dual and concurrent enrollment.

Looking Ahead

Dual enrollment programs, particularly those programs that are fully funded by a school district or state, are a powerful tool that can open up opportunities to low-income and rural students in under-resourced communities. These programs can also address the equity gaps that persist in access to advanced and college-level coursework. Given the tremendous impact dual enrollment can have on a student’s academic life and long-term financial well-being, stakeholders should advance policies that expand enrollment in such programs and ensure high-quality programs. Accreditor regulations must continue to evolve to better meet these goals.

Given the tremendous impact dual enrollment can have on a student’s academic life and long-term financial well-being, stakeholders should advance policies that expand enrollment in such programs and ensure high-quality programs.

Accreditors should revisit faculty qualification standards to ensure that these standards align with best practices in the field and don’t artificially lock CTE educators out of dual enrollment programs. Accreditors should also issue special guidance for institutions on standards for dual enrollment programs so that those postsecondary and secondary institutions looking to establish partnerships understand the rigorous requirements and expectations. Accreditors play a key role in regulating and ensuring the quality of dual enrollment programs and their requirements on student access and outcomes are the cornerstone of a quality higher education experience.

While changes to the 2023–24 IPEDS data collection included a significant rewording that changed “dual enrolled students” terminology to “high school students enrolled in college courses for credit” for clarity, as well as a new part collecting counts of high school students enrolled in college courses for credit, better data on dual enrollment is still needed. State data systems must be able to collect comprehensive data on student access and outcomes in dual enrollment to help inform policy; this includes student demographic information as well as data on the type of dual credit taken, number of credits taken, and whether student was a CTE or non-CTE participant.

For students in secondary school districts that offer no or very few AP courses, dual enrollment is one of the only ways to gain college credit in high school. States should require all school districts to send information about the availability and eligibility of dual enrollment to families in multiple languages with clear, concise messaging about any related costs. States should also consider how eligibility requirements create artificial barriers to entry for students who do not meet the overall student performance minimums but could, through alternate means, illustrate their competency and preparedness for dual enrollment coursework. This says nothing of the work states could do in helping credential more high school teachers to qualify to teach dual enrollment, thus increasing access and opportunity for students.

While some states have statewide transfer or articulation agreements that require public colleges and universities to accept credits earned through dual enrollment, all should have protocols in place to reduce the risk of credit loss for dual enrollment students. Dual enrollment can have a significant and positive impact on students but the states, accreditors, practitioners, and professional associations must work collectively to strengthen and expand dual enrollment offerings.

Notes

  1. This number includes enrolled undergraduate students under the age of 18. John Fink, “What Happened to Community College Enrollment During the First Years of the Pandemic? It Depends on the Students’ Age,” Community College Research Center, January 9, 2023,  https://ccrc.tc.columbia.edu/easyblog/what-happened-to-community-college-enrollment-depends-students-age.html.
  2. Some states use ”dual” and ”concurrent” enrollment interchangeably, and some states define dual enrollment as students being enrolled at both the college and high school, and concurrent as taking college courses at the high school. This commentary uses “dual enrollment” to capture both types of programs.
  3. Early college high schools, such as Bard Early College High School, allow students to progress toward a high school diploma while simultaneously receiving up to two years of college credit, through enrollment in high school and college classes. These classes are a part of the high school curriculum and are offered at the high school, not an alternate location.
  4. Some students participate in a form of dual enrollment called dual credit wherein college credits the student receives can be used to satisfy high school graduation requirements.
  5. There are no federally recognized accrediting agencies for the secondary education system. While all public K–12 schools must meet standards set by the state government with private and independent schools sometimes opting to undertake their own accreditation process, it is not a requirement that they be recognized by an accrediting agency or governing body.
  6. “DEAC and the institution can show that the circumstances requiring the period of noncompliance are beyond the institution’s control, such as. . . . Instructors who do not meet the agency’s typical faculty standards, but who are otherwise qualified by education or work experience, to teach courses within a dual or concurrent enrollment program, as defined in 20 U.S.C. 7801, or career and technical education courses.” From “Distance Education Accrediting Commission, Accreditation Handbook: Policies, Procedures, Standards and Guides of the Distance Education Accrediting Commission,” Distance Education Accrediting Commission, April 5, 2022, https://www.deac.org/UploadedDocuments/Handbook/DEAC_Accreditation_Handbook.pdf
  7. This is also true of the Advanced Placement wherein an institution may give no credit for a score of 3 but offer the same number of credits for a score of 4 or 5 on the AP examination. Likewise a student may get three general credits for a humanities course but four credits for a statistics or physics course.
  8. HLC’s “achievement of academic credentials” standard for faculty qualifications states that an instructor should possess an academic degree relevant to what they are teaching and at least one level above the level at which they teach, except in programs for terminal degrees. In terminal degree programs, an instructor possesses the same level of degree. See “Institutional Policies and Procedures for Determining Faculty Qualifications: HLC’s Criteria for Accreditation and Assumed Practices,” HLC, November 2023, https://download.hlcommission.org/FacultyGuidelines_OPB.pdf.
  9. A substantive change is a change in mission, scope or structure that must be reported and approved by the accrediting agency before implementation to ensure the changes do not negatively impact the institution’s ability to meet standards.
  10. HLC conducts comprehensive reviews at various points in the accreditation process, when the institution seeks initial accreditation, during years four and ten when the institutions seeks reaffirmation of accreditation and/or after an institution has been placed on probation or issued a show-cause (a kind of sanction wherein the institution must explain why its accreditation should not be removed).
  11. All of the participating institutions—University of Maine System, Maine Community College System, and Maine Maritime Academy—have NECHE accreditation.
  12. Freshmen, sophomores and students who do not meet the GPA requirement may qualify for an exception if the student receives a recommendation from the secondary school administration or teacher following an assessment of the student by the school administration and the receiving post-secondary institution approves them for participation.
  13. This may students having access to a full suite of traditional college courses or a just few dual enrollment CTE courses.
  14. The policy specifically states faculty qualification should comply with SACSCOC or Council on Occupational Education credential guidelines. See “Academic Affairs Policy 2.22: Minimum Requirements for Dual Enrollment,” Louisiana Board of Regents, revised June 14, 2023, https://www.laregents.edu/wp-content/uploads/2023/06/AA-2.22-Dual-Enrollment_with-new-modality_6.14.23.pdf.
  15. NACEP defines college provided faculty as any college credit-bearing courses taught to high school students by college provided faculty regardless of location or delivery method. This enrollment is due to a partnership between the high school and college/university.