Next month, four college accreditors that are responsible for vetting the quality of schools attended by more than 7.5 million undergraduate students—that’s over half of all undergraduate students attending Title IV eligible institutions in the United States—will themselves be reviewed by a federal advisory committee. Institutional accreditors are gatekeepers to federal funds for colleges; without accreditation, colleges and their students lack access to federal student aid. The committee, known as the National Advisory Committee on Institutional Quality and Integrity (NACIQI), will review each accreditor’s standards and practices and make recommendations to the U.S. Department of Education on whether they merit continued recognition as such a gatekeeper.

The work of NACIQI is high stakes, despite its relative obscurity. Because the Department of Education does not directly evaluate the academic quality of each college and university, accreditors are tasked with providing expert, peer-level review and ensuring institutions are operating at a certain standard. Unfortunately, some accreditors have failed to fulfill this role effectively. Accreditors have allowed some schools to fall through the cracks, to the detriment of students and taxpayers. It is crucial for NACIQI to intervene in such cases—and the committee should do so during next month’s review of five major institutional accreditors.

What Can the Public Expect from the Next NACIQI Meeting?

Under the Higher Education Act, the secretary of education recognizes accrediting agencies as authorities on education quality at the institutions or programs they accredit. Accrediting agencies must periodically apply for renewal of this recognition. When agencies are reviewed, the senior Department of Education official can also determine an accreditor has been noncompliant with specific criteria and order a compliance report. At the upcoming meeting, NACIQI will review accreditors’ applications for renewal of recognition, as well as compliance reports. Before the NACIQI meeting, members are given access to the application, the department staff analysis, third-party comments, and the accrediting agencies’ response to these items.

During the biennial NACIQI meetings, Department of Education officials present on each accreditation agency and solicit questions from the NACIQI members. Members may also ask questions of agency representatives to get additional information or context about their application submission. The general public is also able to participate in the meeting by responding to requests for written comment due a full year in advance of the meeting or providing oral comments at the meeting. NACIQI members can ask questions of those who provide third-party comments. Time is also reserved for the agency representatives to address any concerns flagged by the public or address subsequent questions from the NACIQI members. Finally, the department staff may provide final comments on the agency or third-party presentations before NACIQI members discuss and vote on each accreditor’s renewal application or compliance report.

In general, there are two types of accreditation: institutional and programmatic. Institutional accreditors oversee the academic and organizational structures of an institution as a whole, while programmatic accreditors review specialized and professional programs within an institution. For example, New York’s SUNY Buffalo State has institutional accreditation from the Middle States Commission on Higher Education (MSCHE), but its Coordinated Program in Dietetics is accredited by the Academy of Nutrition and Dietetics, Accreditation Council for Education in Nutrition and Dietetics (ACEND). Programmatic accreditors can also be recognized by the Department of Education for the accreditation of single-purpose freestanding institutions, causing them to function as institutional accreditors. While the Accreditation Commission for Education in Nursing, Inc. (ACEN) is a programmatic accreditor, there are fifty-seven nursing-only institutions, such as Saint Elizabeth School of Nursing and Trinity Health System School of Nursing, that gain access to federal financial aid through ACEN.

Who’s Up for Review?

The large institutional accrediting agencies slated for discussion at the winter 2023 NACIQI meeting are responsible for overseeing more than 1,500 federal financial aid eligible institutions of higher learning (see Table 1). The Higher Learning Council (HLC) accredits more institutions than any other agency. HLC Title IV participating institutions include 507 public institutions; 397 private, nonprofit institutions; and 26 for profit institutions. HLC accredits more than one-third of the institutions that received greater than $200 million in Title IV aid volume during the academic year 2019–20. As the largest accrediting agency in the United States, HLC should be well equipped to assess institutional quality and enforce compliance with its own standards. Unfortunately, advocates argue HLC has systematically failed to ensure institutional compliance with its minimum quality standards through stringent monitoring.

Table 1
Accrediting Agency Type Title IV Participating Institutions
Higher Learning Commission Institutional 926
Middle States Commission on Higher Education Institutional 481
New England Commission of Higher Education Institutional 206
Western Association of Schools and Colleges Senior Colleges and University Commission Institutional 172
Accreditation Commission for Education in Nursing, Inc. Programmatic 57
Source: NACIQI Accreditor Dashboards,

The Middle State Commission on Higher Education (MSCHE) is another large accrediting agency that is up for review at the upcoming meeting. MSCHE member institutions include the state university systems of New York and New Jersey. More than 2 million undergraduate students rely on the accreditor to provide thorough oversight. One formerly MSCHE-accredited institution, ASA College, was accused of violating New York City’s consumer protection law prohibiting deceptive practices. The for-profit college was accused of running deceptive print ads that targeted vulnerable prospective students. ASA ultimately settled with New York City. Though MSCHE eventually withdrew ASA’s accreditation, the decision came years after concerns about institutional governance were first brought to light. Another troubled MSCHE school is Bryant & Stratton College. Advocates have repeatedly expressed concerns about student outcomes at the school, as well as concerns about the institution’s conversion to nonprofit status. The latest data reveals that one-quarter of former Bryant & Stratton students are not making progress on their student loans and 16 percent are in default.

The Western Association of Schools and Colleges Senior Colleges and University Commission (WSCUC) is another accreditor up for review at the upcoming meeting. In August 2021, WSCUC unveiled a key indicators dashboard that allows users to compare student success and outcomes measures across the 172 institutions the agency accredits. The interactive dashboard is populated with disaggregated data which allows users to assess equity as part of data collection. The portal’s peer benchmarks can be used to understand institutional performance within context and also provides data on variations in student performance by demographic. While WASC should be lauded for focusing on improved data transparency, the agency can and should do more to protect students at the institutions it accredits. Advocates have raised questions, for example, about how WSCUC addressed fraud and predatory abuse by Ashford University, now known as the University of Arizona Global Campus.

Another institutional accreditor being reviewed at the upcoming NACIQI meeting is the New England Commission on Higher Education (NECHE) which accredits 206 Title IV–eligible institutions, including Harvard and Yale, as well as Southern New Hampshire University, which has one of the largest online enrollments of any U.S. college. Earlier this month, NECHE withdrew accreditation from for-profit Bay State College in Massachusetts, after the Department of Education flagged concerns about the school’s administrative capabilities, and elected officials sought investigations into claims of fraud and noncompliance, including illegal telemarketing practices.

In addition, programmatic accreditors—some of whom are seeking renewal of recognition and others submitting compliance reports—will be up for review. Programmatic accreditors on the February 2023 NACIQI agenda are Accreditation Commission for Education in Nursing, Inc.; Academy of Nutrition and Dietetics, Accreditation Council for Education in Nutrition and Dietetics; Accreditation Commission for Midwifery Education; American Physical Therapy Association, Commission on Accreditation in Physical Therapy Education; the New York State Board of Regents, State Education Department, Office of the Professions (Nursing Education); and Maryland Board of Nursing.

What’s at Stake in the Process?

Higher education advocates and NACIQI members alike are certain to raise concerns about the Department of Education’s process and transparency as it relates to document releases and complaint procedures. Adequate oversight of accrediting agencies is the only way to fulfill the government’s obligation to students and taxpayers. While a forthcoming negotiated rulemaking will address broader issues around the revamp of the federal process for reviewing accreditation agencies, the winter 2023 meeting will center ongoing concerns about whether the safeguards established by the accreditation agencies seeking renewal of recognition are being adequately enforced.

Student success should be at the forefront of any conversation about higher education accountability, but student voices are often left out of NACIQI meetings. The meetings are held during the morning and mid-afternoon when many students may be in class, working, or performing caregiving duties, limiting their ability to meaningfully participate. A more open and transparent process would allow greater input from students and give NACIQI members the valuable information they need to make informed agency recommendations.

While NACIQI members are tasked with providing oversight and making recommendations to the secretary of education, the final decision on whether an agency is worthy of continued recognition lay solely with the Department of Education. Following the NACIQI meeting, committee members send their recommendations about each agency to the senior department official. Recommendations can include accepting the application for renewal, terminating department recognition, or requiring the agency submit a compliance report. The senior department official then notifies the agency of their decision, which in the absence of an appeal is final. The department should reconsider NACIQI’s role in the review process to ensure integrity remains central to its accreditation work.