As the class of 2022 weighs their post-secondary options, one thing that is likely far from their mind is how their dream school measured up during its last accreditation review. The public generally knows that accreditation matters and that when considering going to college, they should look for that seal of approval. Unfortunately, today’s accreditation system does not do what many believe it does. And that is a problem that can be remedied by holding accreditors responsible for truly assessing institutional integrity.

Accreditation is one part of the system of regulatory bodies charged with reviewing and approving colleges and universities for approval to participate in federal financial aid programs. Accreditation itself began as a voluntary, peer review process institutions of higher education would undergo to show their commitment to quality. In practice, accreditation is still voluntary, but the process is a high stakes one, because a student’s ability to receive federal financial aid hinges on their school’s status. The high-stakes nature of the system means accreditors may be less likely to revoke approval of a school despite low performance, because of the financial fallout such an action could impose on students.

These dynamics mean that institutions continue to slip through the cracks and receive accreditation renewal even when they do not really merit that seal of quality, and even as their students suffer. A number of accreditors have chosen to focus on institutional compliance with lax standards instead of true institutional integrity. How has a process intended to protect students and the general public devolved into one with so little meaning? The review process for accreditors must be overhauled to ensure the students are aware of, and protected from, predatory institutions by a set of rigorous accreditation standards that center their needs and postsecondary success.

The review process for accreditors must be overhauled to ensure the students are aware of, and protected from, predatory institutions by a set of rigorous accreditation standards that center their needs and postsecondary success.

This commentary will outline how the accreditation process works, the ways in which the design for the system is not being matched by its actual oversight practices, and some of the ways accreditors and related oversight bodies can restore value and meaning to their seals of approval.

How Accreditation Works

The U.S. Department of Education does not directly accredit postsecondary institutions or programs; instead, it recognizes the authority of accrediting agencies. There are some three dozen U.S. Department of Education-recognized institutional accreditors, and over thirty recognized programmatic accreditors. While institutional accreditors review academic and organizational structures at an institution, often serving as gatekeepers for Title IV federal student aid, programmatic accreditors evaluate specialized or professional programs at a college, university, or free-standing institution. All accreditors must meet strict standards as outlined in the Higher Education Act. The process the department utilizes for determining whether accreditors should remain recognized is meant to be public and participatory, though, as we shall see, in its current form is neither.

Since 1992, the National Advisory Committee on Institutional Quality and Integrity (NACIQI) has been tasked with providing oversight and making recommendations to the U.S. secretary of education regarding the accrediting agencies that monitor the academic quality of higher education institutions. During the group’s biannual meetings, both programmatic and institutional accreditors are reviewed to develop a recommendation for whether the secretary should grant or deny them recognition or place them on a monitoring or probationary status. Agencies may be granted initial recognition or renewal of recognition for up to four years. In advance of the formal NACIQI meeting, U.S. Department of Education staff recommends whether recognition should be bestowed based on whether they meet department criteria in several crucial areas. NACIQI committee members then engage in a formal voting process, which, while a necessary procedure, does not determine whether the accreditor’s application will be approved, since the committee is advisory in nature.

In action, NACIQI’s scope is currently limited to reviewing the work of individual agencies rather than determining whether the standards and criteria for federally recognized accreditors are rigorous enough. Federally recognized accreditors are not only gatekeepers responsible for ensuring the quality of the institutions and programs they accredit, but also for ensuring only those institutions meeting stringent standards are able to access federal aid. Accreditors routinely approve and renew institutions that fail to support student success by burdening them with loan debt or offering them no meaningful return on investment. The public and the department must hold accrediting agencies to task when the schools they accredit do harm.

The Accreditor Role in Consumer Protection

Most institutional accreditors have rules governing the way accredited institutions present themselves to the public, meaning everything from their marketing to the way they list their affiliation with the accreditor. Quality oversight regarding truth in advertising is not the sole purview of the institutional accreditor, but accreditors are obligated to enforce their own standards for institutions. However, unfortunately, in practice, discipline of violations infrequently extends to denial or removal of accreditation itself.

Unfortunately, in practice, discipline of violations infrequently extends to denial or removal of accreditation itself.

For example, the Middle States Commission on Higher Education (MSCHE) requires that accredited schools possess honesty and truthfulness in public relations announcements, advertisements, recruiting, and admissions materials and practices, as well as in internal communications. Despite this requirement, several schools have failed to meet their obligation, resulting in a lack of transparency, formal investigations, and hundreds of defrauded students. Shortly after their most recent renewal of accreditation, the New York City Department of Consumer Affairs sued Berkeley College, alleging the college engaged in deceptive recruitment tactics, ranging from dishonesty about transfering credits to misleading students into borrowing loans directly from the school. The school would eventually enter into a $20 million settlement agreement with the City of New York. Despite this legal action, the institution remains accredited and received no sanctions related to these concerns about dishonest practices.

Unfortunately, Ashford University, now called the University of Arizona Global Campus (UAGC), which at one time enrolled among the largest number of undergraduate students of any WASC Senior College and University Commission (WSCUC) accredited school, has faced similar accusations of wrongdoing, with a similar lack of commensurate consequences. Students who have been misled by institutions, or fear that other forms of misconduct have occurred, including violations of state and federal law, can file borrower defense to repayment claims with the U.S. Department of Education. As of December 2020, the Department of Education received nearly 2,000 borrower defense claims from Ashford University students. Following accusations of fraud and deception Ashford University and its parent company, Zovio Inc. were fined $22.4 million in penalties for misleading students about financial aid and student outcomes. These accusations stand in direct contrast with WSCUC’s own accreditation standards and resulted in a formal notice of concern from the accreditor, but did not prompt WSCUC to deny their request for renewal.

The department has also received an alarming number of applications from students alleging fraud and misconduct by Higher Learning Commission (HLC)-accredited institutions. Former University of Phoenix and Devry University students were overrepresented among those seeking relief through borrower defense to repayment applications, submitting a combined 41,743 applications as of December 2020. Despite the concerning pattern, both institutions remain accredited. This is made all the more jarring by the fact Apollo Education Group, the University of Phoenix’s previous owner, agreed to pay $191 million to settle federal charges stemming from the institution’s deceptive marketing about job placements and opportunities.

Insufficient Accreditor Response to Harms Done

While the Apollo Education Group settlement is significant, it also speaks to one of the fundamental flaws in the higher education oversight system. Each year, tens of thousands of students file claims about the ways they’ve been irreparably harmed by any number of institutions, but they find little help and even less recourse. While institutions that have committed the most egregious offenses, including ITT Tech, have been raided and closed, oversight agencies, including accreditors, should have recognized this fraud, sanctioned the entities, and withdrawn their implied support long before they did. At the federal level, student well-being has taken a backseat to concerns about consumer protection and institutional financial responsibility, so it is accreditors who should be the first to uncover and investigate broad concerns with student outcomes. While students are encouraged to report allegations and make formal complaints, the allegations must address a specific accreditation standard or concern about institutional or programmatic compliance. Unfortunately, locating and understanding accreditation standards can be difficult for people who are not well-versed in education oversight.

Institutions should be evaluated based on how well they serve their students, not just whether they are able to meet standard criteria; and accreditors have a responsibility to ensure student progress and success are at the core of their quality standards.

Institutions should be evaluated based on how well they serve their students, not just whether they are able to meet standard criteria; and accreditors have a responsibility to ensure student progress and success are at the core of their quality standards. If the higher education oversight system worked the way it was intended, institutions with poor student outcomes would be identified during the (re)accreditation process and receive appropriate sanctions. Unfortunately, institutions with weak student outcomes are no more likely to be penalized by an accreditor than any other institution.

Even schools graduating small fractions of their enrolled students can remain accredited in part because the standards for evaluating outcomes are so varied. Schools are required to report data, including their retention rates, graduate rates, and other measurements of student and institutional success, but in most instances, there is no threshold that triggers a formal sanction from their institutional accreditor. While several programmatic accreditors, especially those in the health sciences, have minimum graduation rate requirements that, if unmet, result in the need for corrective actions plans, institutional accreditors have not opted to implement similar policies. While student success cannot only be measured by graduation rates and job placements, both are crucial evaluation tools that give insight into whether students are receiving appropriate support services, what programs can be developed to help students, and whether attendees receive a financial return on investment.

Higher education institutions themselves may be responsible for supporting student success, but accreditors play a key role in evaluating their educational effectiveness. MSCHE’s standards indicate schools accredited by the agency must evaluate key indicators of student success, such as retention, graduation, transfer, and placement rates—but is institutional evaluation enough? Strayer University, which has sixteen brick-and-mortar sites as well as a global, online campus, had among the largest pre-pandemic undergraduate enrollment of any MSCHE accredited school. Strayer University Arkansas, Strayer University Alabama, and Strayer University Global Region all report high dropout rates, with graduation rates in the single digits. Additionally, just 49 percent of former Strayer students earn more than a high school graduate ten years after entering the school. While Strayer’s open admission policy ensures all students who apply are accepted, it doesn’t guarantee they will reap the economic benefits of a post-secondary education. Graduation rates and salary data must be read with caution; but they are useful success and quality indicators to evaluate, specifically because they are always at the forefront of the public’s mind. Strayer was one of several colleges the Federal Trade Commission (FTC) placed on notice in 2021 regarding promises made about post-graduate outcomes, including job prospects and earning potential. Perhaps relatedly, Strayer University has also been the subject of more than 600 borrower defense claims.

Dereliction of their duty to the public is something found in both institutional and programmatic accreditors, and limited access to data makes it difficult for any other body to to fill in the gaps.

Unfortunately, dereliction of their duty to the public is something found in both institutional and programmatic accreditors, and limited access to data makes it difficult for any other body to to fill in the gaps. Specialized or programmatic accreditors play a unique role because they focus on a single program, and their approval signifies that the academic quality of a program generally meets industry standards, and that the students attending accredited programs can count on the value and marketability of their degree of interest. Some programmatic accreditors oversee just a dozen programs; others, like the Joint Review Committee on Education in Radiologic Technology, oversee several hundred. Capturing employment and student loan data on smaller programs with fewer admitted students is nearly impossible due to privacy concerns and the Department of Education’s data suppression policy. The inaccessibility of programmatic data submitted to federally registered accreditors makes public scrutiny of the accreditation process and individual accreditors decidedly more difficult.

Programmatic accreditors should face the same intense scrutiny we expect in the institutional accreditor process, not only for their diligence but also for the quality of their rules and requirements. These specialized accreditors review programs in a range of fields and disciplines, as well as single-purpose freestanding institutions, and many of these accreditors are the only ones overseeing their particular field. The Center for Chiropractic Education (CCE), for example, is the sole accreditor for programs and institutions offering a Doctor of Chiropractic degree. CCE accredits the National University of Health Sciences, which sued the accreditor in 2018, alleging that their probation that year and the subsequent denial of their appeal by CCE’s appeals panel violated common law due process. Despite the National University of Health Sciences’ assertion that CCE’s accreditation standards did not permit it to grant reaffirmation of accredited status and impose probation, the court found that CCE provided enough notice and time to correct the violations. This highlights an interesting question regarding the establishment of bright lines and which violations warrant sanctions such as probation. Accreditors are entrusted with protecting students and issuing accreditation only to programs that meet their requirements, but these requirements themselves need reexamination and improvement.

Accreditors Should Engage with Other Oversight Agencies

Because accreditors are only one part of a larger higher education oversight system, concerns linger about what they can and should know about the schools to which they offer their seal of approval. When multiple actors are responsible for keeping a system going, it is easy to assume each is doing its part, but it’s unclear how much each part of the oversight system communicates with the others. Accreditors have enforceable standards about student outcomes and can sanction schools based on these performance measures, but it’s only the Education Department that can prevent schools with excessively high student loan default rates from accessing federal aid. If a state attorney general starts a fraud investigation into an institution and files suit, does that automatically signal to their programmatic and institutional accreditors that they may be out of compliance with their standards? While law enforcement action could be used as evidence that something may be wrong, even if it isn’t criminal, it doesn’t appear that the accreditors use this information when evaluating institutions. Reforming the accreditation system requires a shift toward more information sharing between agencies and a renewed focus on student well-being. Only when partners in oversight effectively collaborate can the system function as seamlessly as it was intended.

Strengthening the relationship between accreditors, the Department of Education, and NACIQI is an achievable goal and worth striving for. One clear example of how accreditors can better engage with other parts of the oversight system is in their responsibility to ensure program quality. Accrediting agencies are also tasked with reviewing written agreements between institutions and third-party contractors. This includes looking into arrangements between institutions and online program managers (OPMs), which provide products and services that assist institutions in taking their academic programs online. Third-party online program managers may provide a variety of functions for online degree programs including advertising, student recruitment, instructional design, and course development. Due to the various roles OPMs can fill and the fact that OPMs charged with recruitment are paid on a percentage of revenue raised, there is reasonable concern about potential abuses and the excessive redirection of federal student aid and tuition dollars to the companies managing online programs. The redirection of funds caused by contractual agreements with OPMs can further harm students by causing financial instability leading some institutions to close their doors leaving students in a lurch. Unfortunately, accreditors may not be taking a careful look at the arrangements between institutions and their contractors.

The relationship between institutions and OPMs can be an especially difficult one to monitor because they vary so immensely. While in many instances the institution has the power to reject certain course materials or instructors, some OPM agreements limit the institution’s ability to provide oversight into the operations of the program(s) they manage even while using the institution’s name and branding. Not all institutions are partnering with OPMs for the management of degree granting programs. Some offer certification or short-term programs, like coding bootcamps, which have gained popularity due in part to their self-professed ability to quickly upskill or re-skill people in the technology industry.

While there is nothing intrinsically harmful about institutions entering OPM arrangements or other third-party agreements, accreditors have given a green light to schools outsourcing their services and brands to an extent that makes them captive to their contractor(s) and runs counter to federal guidance. Because handing over so much control to for-profit third parties can lead to student harm, NACIQI and the Department of Education should take up issues like outsourcing and provide guidance to accreditors so that they can better assess and support institutions.

Centering Studentsand Integrityin the Accreditation Process

One way NACIQI could more effectively take on its role within higher education oversight is to adopt truly public and participatory ways of doing its work. For example, the public can provide comments about accrediting agencies up for NACIQI review so long as they are submitted a full year in advance of the meeting. While this deadline is posted publicly, it means those submitting comments may not have the full breadth of relevant information about programs and institutions available to make a useful comment. For example, an accredited program may not graduate its first cohort until after the deadline to submit third-party comments, so any newly acquired student outcome data would not be included in the comment. It’s worth noting that no third-party comments were received for any of the five programmatic accreditors seeking renewal of recognition during the February 2022 NACIQI meeting.

Just two weeks prior to that most recent NACIQI proceeding, the Department of Education provided an update that gave the public an opportunity to review the department’s findings and the accreditors’ explanations for poor performance. Unfortunately, this was added after the onerously early deadline to submit written third-party comments. While public oral comments are permitted during the NACIQI meeting itself, the time the meetings are held during the traditional workday may make it difficult for impacted students with work or family obligations to participate. In theory, accreditors evaluate whether students at institutions under their purview receive a quality education, so it seems natural to center student voices in the accreditation process writ large. But under the status quo, students and the public are effectively excluded from what is supposed to be a participatory process.

Under the status quo, students and the public are effectively excluded from what is supposed to be a participatory process.

Higher education advocates have called for an improved review process that allows the public to both understand the accreditation process and comment on accreditors currently under review. In addition to concerns about the availability of public information related to the accreditor’s request for continued recognition, there are no formal guidelines on how public information is featured on accreditor websites, creating a unique challenge for students and their advocates. While accreditor websites should function as student resource portals, they can be incredibly difficult to navigate and occasionally utilize a complicated maze of hyperlinks to access basic information.

Researchers and students should be able to easily navigate accrediting agency websites and find information on accredited programs and student outcomes as well as by-laws, policies, and procedures. Unfortunately, accreditor websites vary immensely in structure, and locating institution-level data on quality indicators for the purpose of comparison or even for simple information gathering is burdensome. A survey of the websites for the eight1 programmatic and institutional accreditors seeking renewal of recognition at the upcoming summer 2022 NACIQI meeting reveals just how complex the process can be. While all eight websites include an accredited program or institution directory, the ease with which a user can find information on recent accreditor actions varies.

While the Association of Biblical Higher Education (ABHE) directory includes an accreditation fact sheet on every institution it oversees, and which lists accreditation decisions, sanctions, approved educational programs, and links to the institution’s graduation and retention rates, the Accreditation Council for Occupational Therapy Education (ACOTE) only lists the accreditation status, date of last on-site visit, and next on-site visit. While ACOTE’s website allows users to search institutions by accreditation status, the site only includes four statuses: accreditation, pre-accreditation, candidacy, and applicant. The inclusion of a limited number of statuses may lead website visitors to conclude that no ACOTE accredited institutions have received a sanction, probation, or other warning, but a search of their recent accreditation actions reveals this to be incorrect.

Clarity around the definition of different statuses within the accreditation process is important for a number of reasons, but because each accreditor is different, what these statuses and related terms mean can only be understood by closely reading a particular accreditor’s regulations. The Association for Clinical Pastoral Education (ACPE)’s recent accreditation commission actions utilizes language about the assignment and removal of notations for various standards, but provides no definitions about these terms nor what was submitted from institutions that were previously non-compliant or had deficiencies in order to have these notations removed.

Southern Association of Colleges and Schools Commission on Colleges (SACSCOC), the largest institutional accreditor up for review at the next NACIQI meeting, has an expansive institutional database. All entries include accreditation history, including past probations, and general information like the institution’s address, phone number, and degree type(s) offered, as well as an external link to student achievement data. Where that student achievement data hyperlink leads a website visitor varies, whether it’s to a lengthy PDF file containing a performance measures report, an educational effectiveness page with graduation, placement, and student loan default data, or a “page not found.” While the student achievement data can be helpful, the fact that the links are external and lead back to the institution’s website means there’s no standardization, and what information, if any, is contained within the landing page is different.

In many instances, these websites can be easily improved to better serve students seeking information. For example, a doctorate of pharmacy (PharmD) from an Accreditation Council for Pharmacy Education (ACPE)-accredited institution is the only degree accepted by the National Association of Boards of Pharmacy for eligibility to sit for the North American Pharmacist Licensure Examination. Despite this, the ACPE website does not include institutional-level student outcomes data like graduation or board passage rate. While the Commission on Dental Accreditation (CODA) website includes an annual survey of all pre-doctoral dental education programs, the published data which covers programmatic information, student and graduate data, curricula, and financial management of dental schools doesn’t provide insight into student outcomes beyond the graduation rate. By comparison, other agencies that oversee specialized programs, like the Council on Podiatric Medical Education, aggregates and publishes this information for the free-standing podiatric schools it accredits.

With improvements, accreditor websites could be a valuable tool for students seeking more information on institutions prior to enrollment. For example, the Distance Education Accrediting Commission (DEAC) website allows users to easily search their directory of accredited institutions by accreditation status. This is especially useful in instances where an institutional website is incorrect or misleading. Such is the case for Sarasota University, whose website does not contain a public notice that the institution is under a show cause order by DEAC. Though the design, navigation, and general usability of accreditor websites may not be at the forefront of discussions about accreditor oversight, website functionality, and content has a direct impact on how involved the public is able to be in the review process and, just as importantly, how students and prospective students are able to educate themselves about their college choices.

Restoring Faith in Accreditation

How accreditors assure quality and their process for establishing minimum requirements for accreditation varies, and thus no singular threshold exists for how colleges maintain accreditation. And this is by design, since college and university missions vary widely. The lack of a singular standard for minimum requirements is not an excuse for NACIQI or the department to accept low-bar and unclear requirements from accreditors. Even so, some accrediting agencies are doing a disservice to the public and to students by employing vague standards, policies, and procedures. The lack of specificity of accreditation standards of some agencies allows schools that harm students to remain accredited, even as student complaints roll in or disciplinary action is taken by other parts of the regulatory oversight system. NACIQI should step in and advise the department on how accrediting agencies’ standards measure up. The important role NACIQI could play in this regard was on display during its most recent meeting.

College oversight isn’t something high school seniors or adults returning to school think about, because they have faith that the system wouldn’t allow them to enroll in an institution that could leave them worse off. Accreditation agencies and the federal advisory committee that oversees them should adjust their processes so that the public’s trust is earned and valid. And that level of assurance is already within accreditors’ reach: it simply isn’t implemented. While college accreditation should be a tool for accountability and the strict enforcement of quality related policies and procedures, accreditors have underutilized their powers.

Recent, high profile failures have helped to shine a light on accreditation, and we must use this unique moment to restore faith in the process. We can and should urge accreditors to enforce the highest standards, and when schools slip through the cracks, accreditors must improve those standards to prevent troubling patterns from emerging. If underperforming or predatory colleges are able to meet compliance standards, the issue lies not just in oversight but the standards themselves. The eight accrediting agencies up for review at the summer 2022 NACIQI meeting should be prepared to discuss how student outcomes are evaluated at the institutions they accredit and what they do within their role to protect students. Compliance is no substitute for integrity, and student success must be at the center of accreditor and accreditor recognition decisions.


  1. Applications for Renewal of Recognition from the Association for Biblical Higher Education, Commission on Accreditation, American Occupational Therapy Association, Accreditation Council for Occupational Therapy Education, Accreditation Council for Pharmacy Education, Association for Clinical Pastoral Education, Inc., Accreditation Commission, American Dental Association, Commission on Dental Accreditation, Distance Education Accrediting Commission, Middle States Commission on Secondary Schools and Southern Association of Colleges and Schools, Commission on Colleges will all be considered at the Summer 2022 NACIQI meeting. The New York State Board of Regents will also submit a required compliance report during the meeting.