In its review of complaints lodged against the Accrediting
Commission for Community and Junior Colleges and its parent Western Association
of Schools and Colleges, the Accreditation Group of the Department of
Education, Office of Postsecondary Education, found the following with respect to an ongoing review of City College of San Francisco (CCSF):
1) A lack of reasonable representation in the
composition of review teams, where faculty employees were under-represented.
2) A conflict or appearance of a conflict of
interest in the composition of the review team, where the spouse of the
ACCJC President was a team member.
3) An inadequate conceptualization of two types of
action - those to “meet the standard” or compliance and those “to increase
institutional effectiveness” or improvement - where accreditation reports provide
ambiguous direction that thwarts due process with respect to compliance or
improvement action required by review.
4) An inappropriate use of corrective timeframes,
where issues of non-compliance are considered serious enough to warrant
sanction but without provision of the recognized timeframe for correction.
These DOE criticisms do not speak directly to the substance
of the review and their rectification is unlikely to affect the finding that
CCSF is not a sustainable institution.
This is because accreditation is a product of the reigning
model for higher education - a triad consisting of institutional service
providers (universities and colleges), public funding and union representation. Operating within this model, accreditation has
evolved to concern itself with input evaluation criteria such as institutional
resources and their management.
Due to substantial cutbacks in public funding, input resources
and their management are now strained to the point of breaking. CCSF epitomizes the effects this has had on higher
education institutions across America.
When considered in its full dimensions this increasingly
familiar circumstance is reason to reconsider the triad model. Given the logic of the complementary relationship
between accreditation and institutional service providers, if the triad was substituted
with a model not centered on universities and colleges, then accreditation would
be subject to modification or elimination.
I have in development a substitute model that
de-institutionalizes the provision of higher education. This alternative is the familiar service
model in routine use by attorneys, engineers, psychiatrists, physicians,
accounts and other professionals. To
appreciate the effect of the professional service model on triad higher
education and its correlate accreditation services consider a distinct attempt
at accreditation reform and replacement.
In 2010 the Center for College Affordability and
Productivity (CCAP) released a document entitled, “The Inmates Running the Asylum?” Its framework for accreditation
analysis assumes a central place for universities and colleges. That is to say, the authors assume the triad.
Though the professional model explicitly denies this
assumption, the CCAP document affords opportunity to present professional recommendations
that are a rational extension of those found in “The Inmates” and arguably what
is needed in cases like CCSF, whose 2600 faculty employees and 90,000 student
consumers are to find themselves on the streets of San Francisco in July.
After providing an historical sketch of American
accreditation, authors Gillen, Bennett and Vedder, zero in on what they
consider a pivotal period.
The GI Bill of 1944 moved accreditation into a stage of evolution
during which a major funding role for the federal government and consequent
need of quality assurance were introduced.
According to the authors, during the period, 1952-1985, the service transformed
from its origins as a voluntary association of institutional actors who define
college education in terms of the types, quantity and quality of institutional input
resources and their effective management to one now charged with assuring the
quality of output at colleges.
It was during this time that accreditation as we know it
today began to take shape. Between 1950
and 1965,the regional accrediting organizations developed and adopted what are
considered today’s fundamentals in the accreditation process: a mission-based
approach, standards, a self-study prepared by the institution, a visit by a
team of peers who produced a report, and a decision by a commission overseeing
a process of periodic review.
“The Inmates” goes on to report that in the post-1985 period
the demand for accountability and quality assurance gained momentum, though
accreditation authorities continued to resist the role and restrict their
activity to the historically established measures of input, process and quality
improvement.
This is where things stand today. The federal government views accreditation as
a mechanism to provide quality assurance as a safeguard for its public financial
commitment. The accreditation community
has declared that its primary purpose is to promote continuous quality
improvement. College officials have
mixed feelings about accreditation, with some viewing it as a burden that
offers little bang for the buck, while others view it as a helpful process that
provides outsiders’ perspectives. Meanwhile, the public has grown increasingly
critical of higher education and, to the extent that it is even aware it
exists, of the accreditation community.
The authors attempt to remedy this circumstance through reform
and replacement recommendations.
With respect to reform they suggest: 1) Increased public
reporting of accreditation action; 2) Increased types and measures of
accreditation approval; and 3) Increased competition in provision of
accreditation services.
Where replacement of accreditation is concerned the authors indicate
four possibilities: 1) the Market; 2) the Government; 3) a Centralized
Accreditor; and 4) a Certification or Qualification Framework.
In this forum discussion is restricted to the Certification/Qualification
Framework. The reason for this is that
the other replacements explicitly eliminate quality assurance as a function of
accreditation, while the Certification/Qualification Framework tunes
accreditation activity to output or quality assurance measures more in line
with specifications of the professional model.
As a consequence of assuming the triad, the reasoning found
in “The Inmates” applies this framework exclusively to students.
Essentially, the basic idea behind [this alternative] to
accreditation is to develop a CPA or bar exam for other disciplines…The
performance of a program’s [or institution’s] students on the exam(s) could
then be used as a measure of the quality of their educational offerings. Programs [and institutions] that do not
sufficiently increase their graduates’ performance on these exams could have
their eligibility for federal funding terminated.
[This approach has] a big advantage over the current system. Instead of measuring inputs and processes, and
assuming that they lead to desirable learning outcomes, the outcomes themselves
are the measure of quality. The main
drawback is that this requires appropriately defining what is to be learned or
expected of graduates and devising assessments that can measure learning or
skills along those dimensions. Thus,
these reforms are contingent upon being able to design an appropriate content,
certification, and/or licensing exams that are widely accepted…
By contrast, since the professional alternative stands to replace
triad institutions with an association of individuals in professional practice,
the notion of a Certification/Qualification Framework is applied to academics,
not students. Provided academics meet
the educational and membership requirements of the profession they are considered
qualified, certified or licensed to independently offer their services to the
public for a fee.
This professional qualification/certification framework might
be seen as a cousin of institutional accreditation, though applied to
individuals in private academic practice.
As is the case with GI Bills or voucher systems, students would
receive federal monies that are used to purchase the services of professional
academics. In the absence of institutions
diploma mills could find no traction.
Under the professional model something like milling could only occur at
the individual practice or course level.
In stark contrast to the devastation unfolding at CCSF, the impact of
educational fraudulence or economic failure on the system and its participants would
be far less pronounced where it occurs in isolated, small academic practices.
As to quality assurance of the services provided by
professional academics, “The Inmates” prescription for objective evaluation of
students remains the most effective and natural mechanism.
This can be achieved through the objective exams championed
by “The Inmates,” but it can also be achieved through what might be called,
crowd evaluation. If, as the authors
claim, forming a consensus on content and evaluation of standardized exams is a
daunting task, then this can be overcome by crowd sourcing the task.
For instance, material such as essays not readily amenable
to objective computer evaluation can be electronically posted and evaluated by academics
other than the one providing the service. Further, the emerging badge movement or more traditional forms of
evaluation could be embedded in the professional model, with multiple qualified
academics evaluating posted material and a calculated average to stand as the final. As a condition of membership all academics
would be required to perform their share of this objective evaluation in a
triple-blind process, where the evaluator, instructor and student remain
anonymous and the professional association is charged with coordination, oversight
and publication of results.
In such a framework, the performance of an academic’s
students could then be used as a measure of the quality of the educational
offerings of the professional practice. With
detailed publication of the quality of practice service, professionals that do
not sufficiently increase their students’ performance would experience a
decrease in market demand for their services, inspiring practitioners to seek
professional development or another vocation.
Evaluation would be transformed into an activity of genuine
mutual interest to academics and students, where both stand to fail or succeed
based on outcome.
Among other benefits, this model dramatically expands higher
education access to both academics and students, while market forces work to
ensure economic solvency and quality assurance without impeding innovation or
diversity.
I have presented only a hint of the professional model for
higher education. Though it is no
solution to the immediate problems faced by CCSF, it is a viable alternative
that stands to mitigate ongoing and prevent future tragedies of the triad.
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