The Proposed Accreditation Standards: A Summary Critique

February
2002
Linda Collins, Accrediting Commission Liaison

As its recent session, the Academic Senate passed a record number of resolutions concerning the proposed accreditation standards. Other faculty organizations have also gone on record opposing the proposed draft standards, including the Community College Council of the California Federation of Teachers as well as representatives from the American Association of University Professors. The Commission currently intends to adopt a revised draft at their June 2002 meeting.

The Academic Senate has called upon the Commission to extend their timeline and engage in a more inclusive deliberative process. Certainly, the Commission should hold more than one public hearing each in California and Hawaii.

The Academic Senate has also requested that the Commission make available to the public the materials and research upon which they based their extensive proposals.

According to the Commission's "Project Renewal" plan, the revision aims to import quality assurance approaches from business and to address inclusion of the wide variation in instructions now on the higher education "market." But to widen the umbrella in this way essentially reduces the standards to the lowest common denominator.

The content of the standards has been narrowed from the assurance of adequate educational, fiscal, human, physical resources and conditions to the continuous monitoring of outcomes.

The number of standards has been reduced from ten to four; but close reading reveals that these four are restatements of one theme. Essentially, there is but one overarching standard, repeated over and over again. What is required above all is a "systematic cycle of evaluation, integrated planning, implementation and re-evaluation to verify effectiveness." This "standard" is then expected to be applied across the institution, be it in instruction or student services, administrative processes or governance. This approach would inappropriately impose a singular educational philosophy and practice upon all institutions. This represents a radical departure and places the Commission in too partisan a stance in relation to current policy debates about educational reform.

The proposal completes a retreat from historically understood approaches to standards in tow ways. First, the Commission moves away from prior expectations that baseline standards of resources and quality will apply to various areas of the college (full-time faculty, basic counseling and library services, adequate or at least tolerable libraries, or sound deliberative processes for ensuring curricular integrity). At precisely the time our students are the most diverse in the history of the region, the Commission would countenance a retreat from an assurance that the minimum resources and standards in instruction and student services are available for them to fulfill their educational dreams.

Second, the draft avoids any real commitment to or discussion of the levels of achievement expected of students or the educational rigor and integrity of the offerings. It is quite possible to imagine institutions with "systematic cycles" of evaluation and planning used to enhance "outcomes" whose offerings are not educationally sound and whose transcripts will not be honored by transfer institutions. Focus on quantifiable outcomes without the checks and balances afforded by attention to baseline standards of quality and rigor creates premium conditions for accreditation of and institutional pressures toward diploma mills. Privileging educational productivity over educational quality risks the academic reputations of the colleges and undermines the credibility of our degrees and certificates in the eyes of transfer institutions and employers alike. This is no service to our students.

Student outcomes measurements are not complete and exclusive measures of quality. The evaluation of institutions should in fact avoid singular measures. As Wellman has noted, "One strength of accreditation historically is that it has avoided one dimensional measures of quality, instead.[institutions must] demonstrate performance in a variety of areas, including curriculum, faculty, finances, governance and student services. Academic freedom, institutional commitment to the public interest, and other important aspects evaluated through the governance standard should not be sidestepped." (J.Wellman, Chronicle of Higher Education, Sept. 22, 2000)

The proposed Draft significantly weakens the previous standards with respect to sufficiency of fiscal resources, fiscal stability and fiscal accountability. This is a mistake. The public has a right to expect that accredited institutions are fiscally responsible, stable and with sufficient resources to make it likely the institution will be there long enough to allow students to complete their studies.

The proposed Draft would require that all student development, support services and learning support services be systematically assessed against student learning outcomes. This presumes that one can establish a casual connection between say, a counseling hour, or a visit to the library, and a specified set of learning outcomes. Such an instrumentalist approach to justifying student services appears to presume that students do not have rights to access essential student services, including financial aid advisement, health services, and student access to cultural and social events. While we strongly support program review and assessment of student services, and would agree that all such services should be both relevant to student needs and effective, we do not agree that all colleges should be required to try to prove the efficacy of each service in terms of learning outcomes, as though learning outcomes were the only measurement of a college's function within society.

Much that we do in higher education has long term or longitudinal effects, and could not always be shown to be of immediate efficacy. The approach here is overly simplistic, and could have damaging consequences.

Myriad other new requirements would be imposed including: regular validation of course and program examinations; the identification of competency levels and measurable student learning outcomes for all credit, degree and certificates, as well as general and vocational education programs. Yet there is no rationale cited to suggest that documentation of this magnitude is necessary and appropriate in all colleges, nor to justify requirements this extensive.

The Draft also calls for evaluation of faculty to include "effectiveness in producing stated student learning outcomes." This particular suggestion is the most likely to exert immediate downward pressure on academic integrity, rigor and standards-especially given the absence in the Draft is any stated commitment to tenure, due process and other central academic norms.

The proposed draft groups all "personnel" together and de-emphasizes distinctions among employees. This reflects a general inattention in the document to faculty, their qualifications, and their role as teachers, mentors and discipline experts. There is a notable absence of any mention of the relational aspects of teaching and learning. Attention to the discipline expertise of faculty is a critical component of ensuring confidence of transfer institutions, and we de-emphasize it at our students' peril.

Of the thirty-four (34) institutions that have undergone the accrediting process in the last several years, only four (4) have satisfactorily met the Commission's expectations with regard to current standards 3 and 4. Yet these, particularly the current standard 3 on institutional effectiveness, really are the "guts" of the new draft proposal.

This should raise flags for all involved. It suggests that the framers of the new standards may be so taken with the outcomes agenda that they are not sufficiently concerned with the very real considerations of cost or practicality. For any college to successfully implement the Commission's new mandates will require significant, sustained and targeted investment in professional researchers, data analysis and computing capability, professional development, and faculty and staff time. This is particularly problematic (especially for the public institutions that ACCJC* serves) at a time when public funding for community colleges has been cut across the region, and we stand on the threshold of major economic downturn.

The diversion of resources on the scale that would be required will be necessity siphon from those places most likely to provide enhanced student achievement: the classrooms, counseling officers, and libraries where faculty and students interact. Prior to embarking on such an expensive and extended experiment, the colleges, the communities we serve, as well as state level policy makers deserve to see a more detailed analysis of the projected costs, impact and implications of this shift in standards for the colleges. Such an approach constitutes a massive unfounded mandate, and will ultimately undermine our shared goal of serving students in the community colleges.

Ironically, while other minimum educational standards are no longer salient, there is one exception. The draft inserts a new, prescriptive emphasis on ensuring baseline resources for technology in teaching. No corresponding plan is required regarding some of the other generally agreed-upon, fundamental resources that support the provision of excellent education such as qualified faculty and staff or sufficient learning resources.

The singling out of technology mediated instruction, particularly absent any evidence that such instruction is good for our students, or enhances their "learning outcomes," suggests that the Commission is working to promote distance educational and reorient the standards in favor of institutions (such as Western Governors University, Bob Jones University or the University of Phoenix) that are organized primarily around delivery by distance modality.

Judith Eaton, President of the Council for Higher Education Accreditation (CHEA), recently noted that

"Sic core academic values sustain regional accreditation. They are the valuing of: institutional autonomy; collegiality and shared governance; the intellectual and academic authority of faculty; the degree (whether associate, baccalaureate, professional, masters, or doctorate); general education; and site-based education and a community of learning." www.chea.org/Reserch/core-values.cfm

The ACCJC draft retreats from a commitment to collegial governance. This retreat is clearest in the proposed standard on "Leadership and Vested Authority." Gone are the current requirements that faculty have a substantive role in institutional governance, established academic senates and appropriate institutional support. Faculty, staff and students now only need to have a "mechanism or organization" to give "input" on budget, policies and planning.

This overall retreat is particularly problematic in light of the larger agenda in the draft. If colleges are to be organized around the production of student outcomes, then the deliberative processes designed to ensure the integrity of the curriculum and educational programs are even more, not less, critical. They serve as one of the interconnected and necessary checks and balances in colleges and universities. Without sound governance, functional academic senates, and curriculum review processes that ensure the role of discipline expertise, the credibility of our transcripts can and will be challenged by our four year partners.

"Leadership" is not an adequate proxy for governance. The draft also places heightened emphasis on the "vested authority" of the CEOs and governing boards. The general approach to "leadership" appears to be an attempt to reinstate a dated and hierarchical model.

In general, the Academic Senate prefers the more balanced approach to institutional accreditation in the existing standards, and urges a return to multiple measures of educational excellence. While we recognize the current pressures arising from external sources, notably the federal Department of Education, we do not believe that the Commission should adopt unproven, perhaps even faddish measurements and thereby abandon its long-standing commitment to an institution's educational quality evidenced in many ways.

The Commission has simply gone too far. In attempting to accommodate differences among the institutions accredited by ACCJC, the Commission should not lower generally accepted standards, or simply sink to the lowest common denominator. If accreditation is to be of continued value and viability, it must be credible, and that credibility rests in large measure on a shared belief that accreditation does in fact uphold accepted standards of educational excellence.

The Academic Senate believes this proposal should occasion widespread discussion of the role of the Commission and the accrediting process. The Commission serves the educational community, and a substantive redefinition of the basis of accreditation should not be the Commission's alone to determine.

We urge all faculty to carefully read the new draft and contrast it with the current standards. We urge you to work with your local academic senate and other faculty organizations to organize and express concern about these proposals. We urge you as well as to work with classified staff, students, administrators and trustees to raise these concerns with the Commission.

Note: These remarks are drawn a lengthier document submitted to the Commission, available at www.academicsenate.cc.ca.us ACCJC materials can be found at www.accjc.org

Since this article was written, the Accrediting Commission has published Draft B of the Standards. Draft B is available for download at http://www.accjc.org/. The Academic Senate is currently analyzing the new draft, and is sending its liaison Linda Collins to testify at the fearing on March 13th in Hawaii.

*Accrediting Commission for Community and Junior Colleges.

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