The U.S. Department of Education today took the first step toward terminating a college accrediting agency with a history of greenlighting predatory and substandard institutions. While the reasons for the action against the Accrediting Council of Independent Colleges and Schools (ACICS) have been in the news (see here and here and here and here), the process for ending such an agency’s federal recognition has been less discussed.

One of the reactions to today’s announcement is going to be worry about students at more than two hundred colleges that ACICS accredited suddenly losing access to federal financial aid, and the mayhem that could produce. That will not happen. There is a long process ahead that will stretch out two years into the future. Today’s staff recommendation will be combined with an advisory committee recommendation next week, and then a senior official at the U.S. Department of Education has ninety days to make a semi-final decision about the agency’s fate. After that, ACICS will have thirty days to file an appeal with the secretary of education, who then has an indeterminate amount of time to make a final decision. Finally, if the result is the termination of ACICS, any colleges accredited by the agency will still remain eligible for federal aid for eighteen months.

All of that means that, if ACICS is shut down, there is still a total of probably two years before the ax falls on any college’s access to federal financial aid. And in the meantime, the colleges will be seeking accreditation from other, less-disreputable accrediting agencies. If these schools  are quality institutions, they will not have any problem finding new accreditation (and they would not be starting from scratch, since they already have been submitting self-studies and other accreditation material to ACICS over the past several years). If they are not quality institutions and fail to find new accreditation, well, then they should never have been approved  in the first place.

If they are not quality institutions and fail to find new accreditation, well, then they should never have been approved  in the first place.

In recent weeks, as ACICS saw the handwriting on the wall, the accreditor has promised to make changes to its ethics rules and to better train the peer review teams that visit institutions. The changes are too little too late, with too many institutions that have access to taxpayer funds through an inadequate process rife with conflicts of interest. (One note about the number of colleges. The number that would need to seek new accreditation is the 243 reported by the Department of Education. The larger numbers often mentioned in news coverage are campus locations that need accreditor approval but do not require a full review. Furthermore, as Ben Miller of the Center for American Progress has pointed out, many of the 243 institutions have common ownership that could result in even fewer distinct entities needing to seek approval).

Accreditation documents are usually considered confidential. But The Century Foundation has been able to acquire, from a California state agency, a number of the reports that ACICS teams have submitted as evidence of colleges’ quality. Normally, at the accreditors that review traditional public and nonprofit colleges, the peer team that visits a college writes an essay like this one, a discussion of what the team found and its reflections. In other words, it’s a thoughtful essay from experts.

In contrast, the ACICS documentation consists of a checklist that is simplistic in the extreme, like this 2014 example from the now-defunct Westwood College, seventy-one pages of yes-no questions and short answers. Does the campus publish a catalog that is appropriately printed and bound and available to all enrolled students? Yes or no. Is the campus committed to successful implementation of its mission? Yes or no. Does the campus provide employees with adequate training or supervision? Yes or no.

The questions in the ACICS checklist about academic freedom do not even ask whether such freedom exists at the schools. Instead, they only ask whether a policy—any policy—exists and is documented. (Has the campus adopted a policy on academic freedom that has been communicated to the faculty? Yes or no.)

A few of the more-substantive questions are quite telling, such as one that asks how the team was able to determine whether the school’s method of student recruitment was ethical. In the Westwood example, the answer was simply because they told us so:

“The director of admissions for the campus discussed in detail the recruitment procedures, shared admissions forms, training manuals and the supervision process for the admissions representatives. Based on this conversation and observation the team was able to determine the recruiting process is ethical and compatible with the educational objectives for this campus.”

The recruitment processes of for-profit colleges have been among the most rife with fraud and manipulation. Relying on a school to self-report on its marketing does nothing at all to ensure integrity. Instead, it demonstrates how terribly inadequate the ACICS process is, an accreditor that cannot be trusted to do even an adequate job.

Accreditation is frustrating because there is no simple formula for doing it well, especially when it is serving as a screen for government aid. But it is possible to tell when it is being done poorly—ACICS is it—and the Department of Education is right to start the process of ending the accreditor’s recognition.