Accreditation: A Flawed Proposal By Alan L



The Politics of Pedagogy: Retaining Faculty Authority for Curriculum Despite the State and National Impositions

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ASCCC Spring Plenary 2008-04-07

Chuck Wisely California Community College Chancellor’s Office

Jane Patton ASCCC Vice President

Janet Fulks ASCCC North Area Representative

Accreditation: A Flawed Proposal By Alan L. Contreras

Inside Higher Ed June 1, 2006

A recent report released by the Secretary of Education’s Commission on the Future of Higher Education recommends some major changes in the way accreditation operates in the United States. Perhaps the most significant of these is a proposal that a new accrediting framework “require institutions and programs to move toward world-class quality” using best practices and peer institution comparisons on a national and world basis. Lovely words, and utterly fatal to the proposal.

The principal difficulty with this lofty goal is that outside of a few rarefied contexts, most people do not want our educational standards to get higher. They want the standards to get lower. The difficulty faced by the commission is that public commissions are not allowed to say this out loud because we who make policy and serve in leadership roles are supposed to pretend that people want higher standards.

In fact, postsecondary education for most people is becoming a commodity. Degrees are all but generic, except for those people who want to become professors or enter high-income professions and who therefore need to get their degrees from a name-brand graduate school.

The brutal truth is that higher standards, applied without regard for politics or any kind of screeching in the hinterlands, would result in fewer colleges, fewer programs, and an enormous decrease in the number and size of the schools now accredited by national accreditors. The commission’s report pretends that the concept of regional accreditation is outmoded and that accreditors ought to in essence be lumped together in the new Great Big Accreditor, which is really Congress in drag.

This idea, when combined with the commitment to uniform high standards set at a national or international level, results in an educational cul-de-sac: It is not possible to put the Wharton School into the same category as a nationally accredited degree-granting business college and say “aspire to the same goals.”

The commission attempts to build a paper wall around this problem by paying nominal rhetorical attention to the notion of differing institutional missions. However, this is a classic question-begging situation: if the missions are so different, why should the accreditor be the same for the sake of sameness? And if all business schools should aspire to the same high standards based on national and international norms, do we need the smaller and the nationally accredited business colleges at all?

The state of Oregon made a similar attempt to establish genuine, meaningful standards for all high school graduates starting in 1991 and ending, for most purposes, in 2006, with little but wasted money and damaged reputations to show for it. Why did it fail? Statements of educational quality goals issued by the central bureaucracy collided with the desire of communities to have every student get good grades and a diploma, whether or not they could read, write or meet minimal standards. Woe to any who challenge the Lake Wobegon Effect.

So let us watch the commission, and its Congressional handlers, as it posits a nation and world in which the desire for higher standards represents what Americans want. This amiable fiction follows in a long history of such romans a clef written by the elite, for the elite and of the elite while pretending to be what most people want. They have no choice but to declare victory, but the playing field will not change.

Alan L. Contreras has been administrator of the Oregon Office of Degree Authorization, a unit of the Oregon Student Assistance Commission, since 1999. His views do not necessarily represent those of the commission.

The original story and user comments can be viewed online at .

A Little Help From Its Friends?

Inside Higher Ed Feb. 28

In the year and a half since the report of the Secretary of Education’s Commission on the Future of Higher Education, the U.S. Education Department has invested significant time and energy on pressuring accrediting agencies to prod colleges to more effectively measure and more transparently report the academic outcomes of their students. In many ways, the accreditation war has been at the center of the department’s effort to carry out the commission’s work.

Which has made it all the more frustrating to Secretary Margaret Spellings and her aides that Congress is poised to shut them down. Bills that both the House and Senate have passed to renew the Higher Education Act would bar the Education Department from promulgating federal rules to guide accrediting agencies on what and how they should assess colleges’ efforts to measure student learning. The measures would also make clear that colleges, rather than accreditors, have primary responsibility for setting standards for student learning.

College leaders, who last spring fought tooth and nail against the department’s efforts to impose a set of new regulations governing accreditation, lobbied Congress hard to limit the department’s work on accreditation. But department officials strenuously oppose the approach lawmakers have taken in the Higher Education Act legislation and have expressed their objections in many venues: interviews with reporters, White House letters outlining their problems with the legislation, and, most recently, a harshly worded op-ed in a Washington political newspaper in which Spellings lambasted for having been “persuaded to block the U.S. Department of Education from overseeing the quality of institutions of higher education by special interest forces determined to keep the accreditation process insular, clubby and accountable to no one but themselves.”

“While business leaders embrace the future, Congress is vigorously defending old structures and outdated practices in higher education at the behest of entrenched stakeholders who advocate the status quo,” Spellings wrote in the Politico.

Department officials have tried, so far unsuccessfully, to persuade leading members of Congress to drop or soften their prohibition. As House and Senate lawmakers and staff begin work on a compromise version of the Higher Education Act legislation, they may get a little help from a friends — former members of the secretary’s higher education commission.

This month, Sara Martinez Tucker and Diane Auer Jones, respectively the department’s under secretary and assistant secretary for postsecondary education, held a conference call for former members of the Spellings Commission to, as a spokeswoman characterized it, update them on the department’s efforts to carry out the panel’s recommendations. The spokeswoman said that the department has done so occasionally, although she could not say when or how often.

By all accounts, department officials — who like all federal officials are barred contacting or encouraging others to lobby Congress — did not in any way encourage the participating members of the Spellings panel to urge lawmakers to reconsider their approach to the accreditation issue. According to several participants on the call, Tucker and Jones updated the members on a wide range of recent administration and Congressional initiatives, including the renewal of the Higher Education Act, and they did make clear that they were unhappy about the outcome of the accreditation issue.

“Sara said something like, ‘We’ve been beaten up on this accreditation issue,’ and she may have said that the department had been ‘emasculated’ or something to that effect,” said Richard K. Vedder, a commission member who is an economics professor at Ohio University.

Vedder and Charles Miller, who chaired the Spellings panel, insisted that department officials “did not in any form or fashion ask us” to advocate on the agency’s behalf, as Miller put it. But someone — Miller, Vedder and Arthur J. Rothkopf, another former commission member, all said it “may have been” them — asked Tucker whether there was anything the panel’s members might do.

“I may have initiated it,” said Rothkopf, a former Lafayette College president and now senior vice president at the U.S. Chamber of Commerce. “Some of us wondered, If we don’t like what the Congress is doing, maybe those of us who are commissioners could say, ‘We think this is going in the wrong direction.’ “

Vedder, who like Rothkopf describes himself as generally sympathetic to the department’s position on accreditation, said that Tucker responded along the lines of: “We are constrained by the law, we cannot lobby Congress. but you people can do whatever you want.”

And they just may, says Rothkopf, who notes that he is speaking as an individual capacity and not for the Chamber of Commerce. “I think that most commission members felt that the accreditation process was a way to get more outcomes out there, to give students and parents and the public more information. Congress’s approach would seem to cut the accreditors loose and cut the department loose. What Congress has done here runs counter to our recommendations and will make it harder to achieve the results we would like to achieve. It’s a possibility that some members of the commission will express their views.”

Some commission members on the call said they did not believe they were not familiar enough with the department’s conflict with Congress over accreditation to know whether they should weigh in, and asked for more information from department officials about the issue. The followup e-mail from Vickie L. Schray, the department’s point person on accreditation, contained a series of documents — all public, she noted — about the accreditation disagreement.

That e-mail, and the fact that department officials had chosen to hold a rare conference call with former commissioners at the precise moment when the department might have its last chance to influence Congress’s actions on accreditation, prompted some college officials to question whether Spellings and Tucker had held the call hoping to spur just such an intervention. In an e-mail sent after a reporter inquired about the call and its purposes, another department official wrote to reassure the commissioners that “the Department has conversations with outside stakeholders regularly and the call/briefing many of you participated in was entirely appropriate and not subject to the open meetings requirements that we all operated under when the Commission was active.”

Miller, the former commission chair, dismisses such talk as conspiracy theorizing. He acknowledges that the Congressional restrictions on accreditation “does in the short run cause a problem” for the administration’s efforts to promote more transparency and accountability in higher education, and “maybe the legislation will slow down what she was going to do.”

But “I don’t think she could have done a lot more in this year” anyway, Miller said. The bigger deal is that it “potentially impedes a future secretary,” he said. “If I were talking to Senator [Edward M.] Kennedy, I would ask him, if there’s a Democratic president, why would you want to have in place and assure the continuation of a fluffy system [of higher education accreditation] with no oversight of how we measure how colleges are doing?

“In the long term, this is not going to be good for the institutions or the accreditors,” he added. “This is the same kind of behavior that all dying industries engage in when they feel pressure. They run to Congress, they lobby special interests.”

Congressional aides said that despite the administration’s unhappiness and any potential last-minute lobbying by Spellings Commission members or anyone else, the language on accreditation is likely to be sustained in whatever compromise version of the legislation emerges within the next few weeks from the House-Senate conference committee. (Among other things, the legislation would also essentially gut and revamp the federal committee that advises the education secretary on accreditation, which has been another point of attack in the department’s efforts to compel change in the behavior of accrediting agencies and colleges.)

“The consensus seems to be that it is appropriate and necessary for accreditors to look at student learning, but not appropriate for Washington tell accreditors how to do that,” said one education committee staff member. “It’s not appropriate for Congress and then the department to say, Here’s how you’re going to do it.”

Colleges should not think, though, that they’ve been given a permanent injunction from Congressional or Education Department scrutiny of their efforts to measure student learning and outcomes effectively, the aide warned. “We’ve bought them some time to learn better how to communicate and come to some consensus about how to do this, and how to help us figure out how to do it more appropriately.”

— Doug Lederman

The original story and user comments can be viewed online at .

CCC responds to USDE Proposed Guidelines on requiring 3rd Party Testing

Executive summary

Chuck Wisely

In the summer of 2007, the United States Department of Education (USDE) released a draft proposal for comment that identified both the types of assessments considered “Gold”, “Silver,” and “Bronze” (GSB) and a time-line for phase-in of the proposal. Those proposed guidelines would require all institutions to abandon faculty and curricular driven assessments (Bronze) for state developed and/or approved assessments (Silver) or external third-party assessments (Gold) by 2010.

Multiple Postsecondary and Secondary representatives identified concerns about the elevation of third-party tests of technical knowledge in general program areas as the “Gold” standard of Technical Skill Assessment. The CCC Chancellor’s Office submitted a written response to the proposed guidelines.

The draft USDE guidelines document states that Grades and GPA “are non-assessment related indicators of student achievement” (p. 3) but considers a single pass/fail test score as an assessment of skill attainment. The CCC response argues that GPA is a valid indicator of student skill attainment. The validity of GPA as a measure is based on the cumulative assessment of skill attainment as measured by the tests, papers, projects, activities, demonstrations of competency and other evaluative activities by local instructors. That cumulative assessment is reported in course grades of students to ensure that students have mastered the necessary academic and career and technical skills before they complete their postsecondary education. Student grade point average (GPA) then, as a reflection of grades, can be used as a valid and reliable unduplicated measure of students’ technical skill attainment over their educational career.

There are a number of issues that were raised by the GSB proposal that go against specific directions from congress. First, Congress specifically prohibits USDE from controlling curriculum (Perkins Act, Section 8(a)), mandating costs not required by the Act (Section 8(a)), and approving or certifying standards (Section 8(b)). The GSB proposal indirectly facilitates Federal control of college curriculum and Federal approval of standards, and states must incur expenditures not required in the Act. The proposal does so by requiring adoption and implementation of third-party tests developed by a few test-developing companies as a requirement for approving state applications for Perkins funds.

The proposal would require states to phase-in third-party or state developed or approved assessments and phase-out local control over curricula and assessments. Although the GSB proposal does not directly control curricula, require expenditures, or introduce standards from USDE, it does indirectly introduce a set of generalized content standards within program areas through third-party test requirements that go against sound educational practices that California and many other states value. Required third-party tests would change curricula even when it is not appropriate. Although the proposal states, where appropriate and available, the phase-in requirements disregard it.

Although USDE decided not to release the GSB guidelines, they continue to argue that GPA is not a valid and reliable measure of skill attainment and are preparing to begin denying approval of Perkins state plans that propose using GPA.

In Focus: The Spellings Commission

Since September 2005, the Secretary of Education’s Commission on the Future of Higher Education has generated enormous discussion about the role and performance of higher education in the United States. The commission’s members voted overwhelmingly, with one dissenter, to approve a version of their report in August 2006. This page brings together Inside Higher Ed’s coverage of the commission and the Education Department’s efforts to carry out the commission’s work, as well as other relevant information about the panel.

Summary with links of all the articles at

|News articles on post-commission developments: |News articles on the commission |

|“Campus Accountability Proposals Evolve,” June 29 |“The Sounds of Conciliation,” September 27, 2006 |

|“Questioning College-Wide Assessments,” June 21 |“The Spellings Plan,” September 26 |

|“Senate and Secretary: Showdown Looms,” June 18 |“The Secretary Offers a Preview,” September 8 |

|“Key GOP Senator Warns Spellings,” May 29 |“Changing the Report, After the Vote,” September 1 |

|“AAU Gets on Board,” May 7 |“Regulatory Activism?” August 21 |

|“Stacking the Deck,” May 1 |“Carrying Out the Commission’s Ideas,” August 17 |

|“Coke and the Spellings Commission,” April 30 |“18 Yesses, 1 Major No,” August 11 |

|“Dissent and a Disputed Phone Call,” April 27 |“Whodunit? Chairman Miller, That’s Who,” August 9 |

|“MLA Grades Spellings Commission,” March 30 |“The Making of a Majority,” August 7 |

|” ‘First Step’ on Simplifying Aid Reform,” March 22 |“A Near-Final Report?” August 4 |

|“Assessing the Spellings Commission,” March 21 |“Too Much Change, or Not Enough?” July 18 |

|“Who’s Who at the Spellings Summit,” March 20 |“Commission Report, Take 2,” July 17 |

|“Huge IPEDS on the Atkins Diet,” March 9 |“Prose and Politics,” June 28 |

|“When Is Student Learning Good Enough?” February 23 |“A Stinging First Draft,” June 27 |

|“Huge IPEDS Lives,” February 19 |“Federal Panel’s Fault Lines,” June 26 |

|“Another Way on Unit Records,” February 12 |“U.S. Panel to Meet (Behind Closed Doors),” June 8 |

|“Upping the Ante on Pell Grants,” February 2 |“The Hurdles Ahead,” May 22 |

|“Accountability and Comparability,” January 31 |“Consensus in Short Supply,” May 19 |

|“U.S. Accreditation Official Out of a Job,” January 29 |“Crunch Time for Commission,” May 12 |

|“Another Front on Accreditation,” January 17 |“Will ‘Voluntary’ Accountability Work?,” April 10 |

|“The New Top Fed for Higher Ed,” January 3, 2007 |“Coalescing Around Concepts,” April 7 |

|“Quick Takes: The Secretary’s Summit on Higher Education,” December 28 |“Blame It on the Faculty,” April 6 |

|“Feeling the Winds From Washington,” December 11 |“Dropping a Bomb on Accreditation,” March 31 |

|“Can You Say NACIQI?” December 5 |“Public Hearing, Take 2,” March 21 |

|“IPEDS on Steroids,” December 1 |“No College Left Behind,” February 15 |

|“Consensus (or Not) About Comparability,” November 30, 2006 |“U.S. Commission Hears From John Q. Public,” February 8 |

| |“In Search of ‘Big Ideas,’ “ February 6 |

| |“An Agenda Begins to Emerge,” February 3, 2006 |

| |“A Key Senator’s Suggestions,” December 12 |

| |“Tough Love for Colleges,” December 9 |

| |“Higher Ed Commission Gets to Work,” October 18 |

| |“What Should the U.S. Commission Do?” September 21 |

| |“The Future of Higher Ed,” September 20, 2005 |

|Related news articles: |Commentaries on the commission: |

|“Testing, Testing,” August 8 |“Assessment for ‘Us’ and Assessment for ‘Them’,” June 26 |

|“Accountability Proposal Evolves,” July 11 |“Out of State Checks and Academic Credits,” Feb. 27 |

|“Wrangling Over Unit Records,” July 7 |“Setting the Record Straight,” February 8 |

|“New Source of ‘Tough Love’ for Colleges,” May 23 |“A Warning on Measuring Learning Outcomes,” January 26 |

|“Accountability, Canadian Style,” May 10 |“Sorting Through the Critiques,” January 15, 2007 |

|“Fresh Approach to Accountability,” April 3, 2006 |“A Modest Proposal on the Draft and Higher Education,” December 19 |

|“Graduated But Not Literate,” December 16, 2005 |“What Spellings Got Right and Wrong,” October 3 |

| |“No God Left Behind — Why Not?” September 21 |

| |“A Challenge to the Forum,” September 15 |

| |“Why Colleges Are So Hard to Change,” September 8 |

| |“Grasping the Reins of Reality,” August 16 |

| |“Caring or Uncaring Assessment,” July 26 |

| |“The Value of Commission Reports,” July 18 |

| |“Not All Change Is Improvement, ” July 3 |

| |“Getting the Faculty On Board,” June 23 |

| |“Connecting the Dots,” June 16 |

| |“Accreditation: Why We Must Change,” June 1 |

| |“Accreditation: A Flawed Proposal,” June 1 |

| |“The View From the Peanut Gallery,” March 21 |

| |“Memo From the Chairman,” January 24, 2006 |

| |Other Web resources: |

| |The commission’s final report |

| |The draft report approved by the commission |

| |The commission’s home page |

| |List of members and their bios |

| | |

Additional Books on the subject of Student Assessment

The Big Test by Lemann

Beyond the Big Test by Sedlacek

The Bell Curve by Herrnstein and Murray

Knowing What Students Know by the National Research Council

How People Learn by the National Research Council

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