Center for American Progress

Transforming Accreditation by Centering Students

Transforming Accreditation by Centering Students

Negotiators coming together to revise the regulations that govern college accreditation should take a student-centered approach.

In this article
A large building labeled with
The U.S. Department of Education building is seen in Washington, D.C., on September 23, 2020. (Getty/Robert Knopes)

Navigating college in the United States has always been challenging. Despite an overall increase in the number of students pursuing and completing a postsecondary credential since 2000, students still face a range of difficulties.1 In 2022, the U.S. Supreme Court ruled against affirmative action, and efforts at providing student debt relief have stalled.2 There is still a widespread college affordability crisis.3 All these issues heighten the risk that students will slip through the cracks of the system and fail to begin or complete their degrees.

In general, the public believes accreditors, which are nongovernmental organizations tasked with assessing the quality of higher education institutions and programs, significantly influence college and university operations and thus the student experience.4Under current regulations, accreditation centers colleges and universities at the expense of protecting students from low-quality institutions and programs. Opinions differ, however, on how to mold accreditation into the effective quality assurance tool it is meant to be.5Some lawmakers have called for dismantling the system altogether, while other advocates wish to improve it.6

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This issue brief proposes reforming the existing college accreditation system to make it fundamentally student-centered. The recommendations below prioritize student welfare in every aspect of reform, ensuring the evolving landscape of higher education directly benefits the students at its core.

The recommendations below prioritize student welfare in every aspect of reform, ensuring the evolving landscape of higher education directly benefits the students at its core.

This week, the U.S. Department of Education kicks off its program integrity and institutional quality negotiated rulemaking.7Negotiators should use this rulemaking to redefine accreditation for a new era in which students take center stage through the following recommendations:

  1. Provide stronger oversight of events that may substantively change an institution. Oversight should include continuous and detailed monitoring, specialized training for review teams, and internal audits to ensure that standards are consistently applied.
  2. Eliminate expedited reviews of substantive changes. Expedited reviews can overlook critical risks to students, and accreditors should have ample time to review substantive changes.
  3. Address compliance issues more rapidly. Accreditors should be required to act as soon as it becomes evident that institutions are not in compliance with standards, as well as give institutions a maximum of two years to course-correct.
  4. Report institutional performance data in a consistent format. Accreditors should retain the ability to assess schools against their stated missions while also uniformly reporting that information using metrics that are consistently defined across agencies. This will enable students to compare key insights into the level of quality to expect at different institutions.
  5. Democratize the accreditation process. This should include easing the requirements for submitting feedback to both institutions and the federal panel that oversees accreditors.

Accreditation is higher education’s golden seal of approval

Accreditation is meant to be an indicator that students can reasonably expect a quality experience at an institution of higher education. Accreditation indicates that an institution has gone through a peer review process and meets standards set forth by an external organization. The Department of Education also uses accreditation to indicate that colleges provide some baseline level of academic quality.

This process is meant to safeguard students and withhold federal investments from subpar institutions that provide a low-quality education.8 Such an endorsement is crucial, as deciding where to attend college is often one of the most consequential choices a student can make.

In the United States, college accreditation began as a voluntary process that allowed institutions with high academic standards to distinguish themselves from the rest.9 That all changed in 1952 when accreditation became a prerequisite for accessing federal funds in the expanded GI Bill of Rights for Korean War veterans. This was done in an attempt to clean up the abusive practices of fly-by-night schools in the wake of the first GI Bill.10 Under the expansion, veterans were only able to use their benefits at institutions whose accreditation was federally recognized.11 Today, accreditors are the gatekeepers to federal financial aid, meaning that the regulations binding them are enormously consequential for students.

The federal government oversees accreditors with input from the National Advisory Committee on Institutional Quality and Integrity (NACIQI), whose one student representative and 17 other members are appointed by the U.S. secretary of education and Congress.12The Department of Education gives NACIQI information about accrediting agencies applying for federal recognition, third-party comments about agencies up for review, and the responses of accrediting agencies to the department’s analyses. The public also has the opportunity to provide comments at NACIQI meetings. Despite the intention that NACIQI’s process represents and includes students and the public writ large, federal review of accreditors has not always effectively ensured educational quality, and students have suffered as a result.13

Learn more about NACIQI

Recommendations for centering students in accreditation rules

Through several rounds of negotiations since 2021, the Biden administration has considered revisions to federal student aid programs as well as to the rules that institutions must follow regarding things such as revenue sources, student debt, and earnings outcomes.14 The Department of Education will continue that process this week by reviewing the federal regulations that govern accrediting agencies.15 The department is bringing together a rulemaking committee that represents entities affected by the regulations—including accreditors, institutions, students, civil rights organizations, and consumer protection groups—which must weigh student and borrower perspectives when revising accreditation regulations.

Because accreditors are meant to evaluate the quality of education provided, they must center students when making determinations because students experience educational quality, or lack thereof, firsthand. An accreditation rulemaking that centers students will give both institutions and accreditors the chance to consider required inputs—such as staffing levels and student support infrastructure—from a student perspective and may foster truly innovative approaches to institutional quality. The federal rulemaking panel should consider the following recommendations in order to truly make college accreditation the seal of approval the public already assumes it is.16

Strengthen substantive change reviews

Under current regulations, accreditors are required to reassess institutions following certain significant changes in their structure or operations, such as changes in ownership.17 This reassessment is meant to ensure that changes are being properly managed and the institution in its newest form remains compliant with the accreditor’s standards. To strengthen this process, accreditors should continuously—or at least at regular intervals—monitor the impacts of changes. Substantive change reviews could also be strengthened if the federal government required accreditors to equip review teams with certain expertise and training, especially in financial analysis, distance education, and education technology. Accreditors should also be required to conduct internal audits of their handling of substantive change reviews to ensure institutions are applying their standards consistently and fairly. While current requirements mandate fairness, there is a lack of clarity on what “effective controls against the inconsistent application of the agency’s standards” actually entail.18 The rulemaking committee should spell out what those controls could be.

Currently, there are 11 events that accreditors must review as a substantive change.19 One of these events is changes in ownership, which can present considerable risk to students and federal funding programs. Ownership changes can lead to shifts in educational philosophy, financial stability, or operational practices: New owners bring new priorities and philosophies that can affect a school’s educational approach and thus students’ experiences. Ownership changes can also bring financial shifts, such as changes in tuition and fees, the availability of scholarships, and the quality of facilities and resources. The school administration may also shift dramatically, which could affect things such as admissions procedures and student services. Finally, changes in ownership can affect a school’s reputation, which could have consequences for graduates relying on their alma mater’s reputation when applying for jobs.

Other types of substantive changes accreditors are required to review include program modifications, changes in mission, geographic expansion, changes in mode of delivery, mergers, changes in measuring student progress, and substantial increases in credit hours awarded, as well as outsourcing academic programs to unaccredited entities and the addition of direct assessment programs. The latter are programs that are not measured based on clock or credit hours earned but rather on students’ performance on skill or knowledge assessments.

At the start of 2023, a NACIQI policy subcommittee found inconsistencies between accreditors and institutions in terms of their referral and treatment of substantive change events.20 In some cases, the subcommittee discovered confusion as to what constitutes a change in mode of delivery. It also found confusion around calculating the involvement of unaccredited third parties in providing academic programs—a key question when determining whether a change will affect a school’s compliance with federal requirements.21 The rulemaking panel meeting in early January 2024 should clarify what types of events constitute a substantive change, make it clear that some events can overlap (for example, an arrangement with an unaccredited entity could result in a change in mode of delivery), and expand the list of possible events to include significant changes in enrollment. Drastic increases or decreases in enrollment warrant review because they can affect class sizes, campus life and culture, and the allocation of resources.

Eliminate expedited reviews of substantive changes

Under current regulations, accrediting agency staff can review some of the substantive changes listed above in an expedited manner, as opposed to through the public, deliberative review process that agency commissioners normally conduct.22 Expedited reviews may make sense in some cases because commission reviews apply a heightened level of scrutiny and require an extended timeline, but they rarely make sense for substantive changes. For example, outsourcing the management of academic programs to unaccredited providers can pose enormous risks to colleges and universities—something that Concordia University in Portland and Eastern Gateway Community Collegefound in their experiences hiring such contractors.23 Research shows that accreditors perform perfunctory reviews of member institutions’ contracts with unaccredited third parties, despite the risks associated with outsourcing.24 Moreover, in 2019, the Trump administration adopted regulations requiring accreditors to review proposed outsourcing deals within 90 days—a rule that was neither student nor institution centered, despite being billed as a policy that would enable colleges to innovate at a faster pace.25 In practice, the policy only benefits the contractors on the receiving end of such arrangements and the tuition dollars associated with the deal. In revising the regulations that govern accreditors, the Department of Education should eliminate the option for agency staff to review substantive changes on an expedited schedule. If a change is big enough to affect students’ learning experiences, it deserves an in-depth review.

If a change is big enough to affect students’ learning experiences, it deserves an in-depth review.

Require institutions to act faster when things go wrong

Institutions facing sanctions due to noncompliance must swiftly address issues. Current regulations permit institutions to remain out of compliance for the lesser of either four years or 150 percent of the length of their longest program offered. This is not in the interest of students:26 Such an extended time frame can lead to prolonged periods of substandard education or management as well as negative student outcomes. The federal rulemaking panel should shorten the allowable period of noncompliance to a maximum of two years. This would compel institutions to act more urgently in resolving compliance issues and ensure that educational quality and institutional integrity are promptly restored. Such a change is not just about regulatory compliance; it is about safeguarding students’ learning experience and prospects for the future.

Similarly, the rulemaking panel should strike a 2019 Trump administration provision allowing institutions to be out of compliance for up to three years before accreditors take any action.27 To safeguard students, the panel should require accreditors to take immediate action on noncompliance.

Improve the utility of accreditor websites by obtaining consistent performance data

Accreditors are required to consider student achievement in their reviews and approval of institutions, but current regulations do not include a federal standard defining which outcomes institutions or accreditors must use to measure performance. Historically, accreditors have assessed institutions according to their own unique missions, as per the Higher Education Act.28 This means that successful outcomes at one institution may look different from those at another. Such flexibility is important for accreditors because they are best situated to define student success in relation to the institution’s mission.

However, accreditors should be required to at least measure and disclose institutional data in a way that is consistent across all accreditors.29 Accreditors could enable students and other members of the public to access and compare key insights into what kind of quality to expect at different institutions, and the federal rulemaking panel should update regulations to require accreditors to collect, report, and make public information about college performance in a manner that is standardized based on institution and program characteristics and uses high-quality data. This would also enable NACIQI to more effectively determine whether accreditors are appropriately establishing and using standards that drive institutional quality.30 This balance will uphold the diversity in educational goals while providing a clear, comparable framework for evaluating institutional quality.

Democratize the accreditation and recognition processes

To make the department’s process for recognizing accreditors more democratic and participatory, significant changes are needed in how it gathers and utilizes public input. Currently, the accreditation system only nominally supports public and participatory processes. One major hurdle is the lengthy timeline for submitting comments about accrediting agencies, which effectively bars meaningful public participation. The department typically issues a request for members of the public to submit comments on agencies up for review at least one calendar year before the NACIQI review meeting.31 This timeline should be shortened, as it could prevent the department and NACIQI from considering the most current data and information in their deliberations. Additionally, the department should actively solicit input from a broader range of stakeholders—including students, faculty, and the general public—in order to gain more diverse perspectives and insights. Integrating more voices more effectively into the review process would help ensure that emerging issues are promptly addressed and that the accreditation process reflects the needs and concerns of the broader educational community.

To make accreditor decision-making bodies more inclusive of diverse voices and student interests, the federal rulemaking panel should also revise the regulations that govern who can sit on accreditation commissions.32 In practice, public commission members, who are meant to represent the public outside of higher education, are sometimes individuals whose personal interests intertwine with the interests of the institutions they are tasked with reviewing, or with the higher education industry writ large. These sorts of conflicts of interest are dangerous for students and for other regulators, such as the federal government and states, who rely on accreditation status as an indicator of independent quality and trustworthiness. New regulations should limit the eligibility of recent employees or associates of higher education institutions or organizations that represent them from taking on a public commissioner seat, along with those with equity interests in schools or their third-party service providers.


The upcoming program integrity and institutional quality rulemaking presents an opportunity to redefine accreditation for a new era centered around student needs and experiences. By considering these recommendations—strengthening substantive change reviews, requiring institutions to address noncompliance issues more promptly, improving the utility of accreditor websites and outcomes data, and democratizing the accreditation process—negotiators can ensure the accreditation system not only upholds high standards of educational quality but also reflects the interests and concerns of students. These reforms are essential for making accreditation a reliable indicator of quality and effectiveness.


  1. National Student Clearinghouse, “Stay Informed with the Latest Enrollment Information,” October 26, 2023, available at
  2. Students for Fair Admissions Inc. v. President and Fellows of Harvard College, U.S. Supreme Court, No. 20–1199 (June 29, 2023), available at; Biden, President of the United States, et al. v. Nebraska et al., U.S. Supreme Court, No. 22–506 (June 30, 2023), available at; Sara Partridge and Madison Weiss, “The Future of Student Debt Relief: What To Expect Next,” Center for American Progress, October 6, 2023, available at
  3. National College Attainment Network, “College Affordability: The Growing Gap,” available at (last accessed December 2023).
  4. Stephanie Hall, “The Students Funneled Into For-Profit Colleges” (Washington: The Century Foundation, 2021), available at
  5. Madison Weiss, “Policymakers must strengthen — not dismantle — the college accreditation system,” Higher Ed Dive, December 22, 2023, available at
  6. Ibid.; Jennifer Blum and Robert Shireman, “Strange Bedfellows on Accreditation,” Inside Higher Ed, January 4, 2024, available at; Emily McCain, “DeSantis announces lawsuit against Biden admin over higher-education accreditation,” ABC Action News, June 22, 2023, available at; Josh Moody, “North Carolina Forces Changes to Accreditation,” Inside Higher Ed, October, 10, 2023, available at
  7. U.S. Department of Education, “Negotiated Rulemaking for Higher Education 2023-2024,” available at (last accessed November 2023).
  8. U.S. Department of Education, “Accreditation in the United States,” available at (last accessed December 2023).
  9. Robert Kelchen, “Higher Education Accreditation and the Federal Government” (Washington: Urban Institute, 2017), available at
  10. Ibid.; Veteran’s Readjustment Assistance Act of 1952, Public Law 550, 82nd Cong., 2nd sess. (July 16, 1952), available at
  11. Ibid.
  12. U.S. Department of Education, “National Advisory Committee on Institutional Quality and Integrity: Welcome,” available at (last accessed November 2023).
  13. Antoinette Flores, “The Unwatched Watchdogs: How the Department of Education Fails to Properly Monitor College Accreditation Agencies” (Washington: Center for American Progress, 2019), available at
  14. U.S. Department of Education, “Negotiated Rulemaking for Higher Education 2021-22,” available at (last accessed December 2023).
  15. U.S. Department of Education, “Negotiated Rulemaking for Higher Education 2023-2024.”
  16. Stephanie Hall, “The Students Funneled Into For-Profit Colleges” (Washington: The Century Foundation, 2021), available at
  17. Code of Federal Regulations, “Title 34: § 602.22 Substantive changes and other reporting requirements,” available at accessed December 2023).
  18. Code of Federal Regulations, “Title 34: § 602.18 Ensuring consistency in decision-making,” available at (last accessed December 2023).
  19. Code of Federal Regulations, “Title 34: § 602.22 Substantive changes and other reporting requirements.”
  20. U.S. Department of Education, “Policy and Process Recommendations: Policy Subcommittee of the National Advisory Council on Institutional Quality and Integrity, U.S. Department of Education,” available at (last accessed December 2023).
  21. Ibid.
  22. Code of Federal Regulations, “Title 34: § 602.22 Substantive changes and other reporting requirements.”
  23. Rick Seltzer, “What Led Concordia Portland to Close?”, Inside Higher Ed, February 13, 2020, available at; Stephanie Hall, “It’s Time to Make Repairs to Online Higher Ed,” The Century Foundation, September 12, 2022, available at
  24. Taela Dudley and others, “Outsourcing Online Higher Ed: A Guide for Accreditors” (Washington: The Century Foundation, 2021), available at
  25. U.S. Department of Education, “Student Assistance General Provisions, The Secretary’s Recognition of Accrediting Agencies, The Secretary’s Recognition Procedures for State Agencies Final Regulations,” Federal Register 84 (2019): 58834–58933, available at
  26. U.S. Department of Education, “Part 602—The Secretary’s Recognition of Accrediting Agencies,” Federal Register 64 (56617) (1999), available at
  27. U.S. Department of Education, “Student Assistance General Provisions, The Secretary’s Recognition of Accrediting Agencies, The Secretary’s Recognition Procedures for State Agencies Final Regulations.”
  28. Congressional Research Service, “An Overview of Accreditation of Higher Education in the United States” (Washington: 2020), available at
  29. Chazz Robinson and Emily Rounds, “How Common Definitions for Student Achievement Can Strengthen College Accreditation,” Third Way, November 3, 2023, available at
  30. U.S. Department of Education, “Policy and Process Recommendations of the Policy Subcommittee of the National Advisory Council on Institutional Quality and Integrity.”
  31. Madison Weiss, “CAP Comment Urges NACIQI To Increase Transparency and Accountability in the Accreditation Space,” Center for American Progress, December 20, 2023, available at
  32. Ben Miller, “Bolstering the Public Voice in Accreditation: Accreditation Agencies Need To Include More Truly Independent Members Among Their Commissioners” (Washington: Center for American Progress, 2019), available at

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Stephanie Hall

Senior Director, Higher Education Policy

Madison Weiss

Policy Analyst


Higher Education Policy

The Higher Education team works toward building an affordable and high-quality higher education system that supports economic mobility and racial equity.

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