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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