processing, medical and dental technology, commercial art, and automobile and diesel mechanics. Degrees are offered at 277 of these institutions. The Commission's accredited schools offer more than 4,500 programs in over 100 occupational areas, and include such institutions as the ITT Technical Institutes and the Culinary Institute of America. On February 1, 1996, the Secretary of Education re-recognized ACCSCT for a four-year term as a gatekeeper to the student financial assistance programs of Title IV of the Higher Education Act of 1965. In re-recognizing ACCSCT, the Secretary concurred with the recommendation of the National Advisory Committee on Institutional Quality and Integrity that the Commission be commended for its efforts to validate its accreditation process.

ACCSCT is an independent, private, non-profit organization with exclusively educational objectives. It is unaffiliated with any trade association. Six of ACCSCT's Commissioners are public members and have no affiliation with the schools accredited by the Commission. The remainder of the Commissioners are elected by accredited schools through a process administered by the Commission. Commissioners include state higher education officials, faculty at state universities and community colleges, and owners and executives of private career schools. I supervise a professional and administrative staff of 35 who support the Commission by reviewing and processing applications, reports, financial statements and complaints, coordinating site visits, and conducting workshops and seminars. A pool of over 1,000 volunteers assist the Commission and its staff by participating in site visits and preparing team summary reports of the visits.

Recognizing the legitimacy of the public's demand for accountability in the student financial assistance programs, the Commission has adopted and applied rigorous standards to promote educational quality and ethical practices among its accredited institutions. In 1990, the Commission

adopted extensive reforms of its accrediting standards and initiated an annual cycle of review and adjustment of standards. These measures have included more rigorous quantative assessment of outcomes (completion, placement and state licensing examination pass rates), promotion of student loan repayment and reduction of defaults, controls on recruitment, requirements for prior approval of changes of ownership, more comprehensive financial reporting requirements, requirements for program advisory committees, and streamlining of appeals processes after adverse actions.

The Commission has also stepped up its efforts to monitor the performance of accredited schools. Since 1993, ACCSCT teams have visited over 50 percent of accredited schools annually. In fact, 60 percent of the schools were visited in the last year. These have included regularly scheduled visits for renewal of accreditation, visits to schools with high cohort default rates, and unannounced visits by rapid response teams where circumstances indicated a need for immediate investigation of compliance with accrediting standards. Since 1990, the Commission has taken adverse action -- denial or withdrawal of accreditation because of non-compliance with accrediting standards -- against 135 schools. It has not been deterred from taking these actions by the threat or expense of litigation; during this period, the Commission has successfully defended all 16 of the actions challenging its decisions in federal and state courts.

While fulfilling its responsibilities as a gatekeeper to the Title IV programs, the Commission has cooperated with its federal and state partners in the Program Integrity Triad by providing extensive information about its accredited schools. For example, in addition to regular and timely notification of final accrediting actions, including denials, withdrawals, and decisions to place institutions on probation, the Commission responded to 23 requests for information in 1994 from the Department of Education, state departments of education, and law enforcement authorities. The

Commission has also cooperated with the Department and the states in matters involving possible violations of Title IV and fraud and abuse.

In the remainder of my testimony, I will focus particularly upon the Commission's use of performance-based measures to assess and promote educational quality. I will describe the ongoing analysis of outcomes data that the Commission has performed in conjunction with the Center on Education and Training for Employment at The Ohio State University. I will explain ACCSCT's approach to outcomes assessment and express its view that there should be greater emphasis on the intelligent application of meaningful performance measures to affect all institutions' participation in the student aid programs. I will also explain why ACCSCT believes that private accrediting agencies have an important role to play in assessing outcomes data and applying the judgment that is necessary to determine whether institutions are making effective use of federal student aid funds. And, I will offer suggestions for re-orienting the role of accrediting agencies as gatekeepers and modifying the statute to better allow accrediting agencies to perform their gatekeeping role.

PERFORMANCE-BASED MEASURES

Long before the enactment of the Higher Education Amendments of 1992, the Commission adopted and applied accrediting standards requiring schools to achieve reasonable and acceptable levels of completion and placement. In order to improve its own assessment capabilities and the performance of accredited schools, the Commission engaged the Center on Education and Training for Employment at Ohio State in 1990 to undertake an independent, ongoing analysis of data from the annual reports submitted to the Commission by accredited schools. This analysis determines the performance of accredited schools with respect to graduation rates, withdrawal rates, placement rates and default rates. The study also determines whether there are school characteristics that have a

significant relationship to these performance measures. The definitions of outcomes measures have been independently reviewed, and data from the annual reports are verified through random site visits. Variables have been identified through multiple regression analysis that have consistent, statistically significant relationships with graduation, withdrawal, training-related placement, and default. These findings are being used to assist the Commission in evaluating and attempting to help improve the performance of accredited schools.

The Center has prepared three reports on the performance of the Commission's accredited schools over a five-year period. The latest report was released in April 1996 and provides for the first time longitudinal data for cohorts of students who would have had sufficient time to complete their programs in the acceptable time frame of 150% of program length. The Center's report is attached to my testimony as Exhibit A, and a summary of the report is attached as Exhibit B. The new cohort data available in this year's report show the following:

Graduation rate -- 70%.

Training-related placement -- 82%.

Withdrawal rate -- -30%.

In general, the longitudinal nature of the cohort data yields a more careful tracking and counting of

students.

The April 1996 report also provides an additional school year of data on outcomes. The

report shows that for full-time students:

64 % graduated within the acceptable time frame for completion of the program.

78% obtained jobs in the fields for which they were trained.

20% withdrew from their programs.

As expected, for part-time students, the graduation and training-related employment rates were 1012% points lower than the rates for full-time students, and the withdrawal rates were 1-2% points higher. The average default rate in the Commission's accredited schools was 22.7%, the lowest rate over the last five years.

A key objective of the analysis of annual report data on outcomes was to determine the characteristics which have consistent, statistically significant relationships with these outcomes measures of school performance. The Center performed a multiple regression analysis to determine the net, independent effect of 39 different characteristics. As a result of this analysis, six factors were identified that influence outcomes:

Percentage of enrollment receiving Pell Grants.

Percentage of Ability to Benefit students.

Average program length in weeks.

Main or branch campus.

Total enrollment.

Faculty turnover.

These characteristics can thus be used as monitoring signals to identify schools that are more likely to have outcomes problems. Since default rates have occupied the attention of policy makers to such a degree in recent years, it should be noted that a school's default rates did have some correlation with its withdrawal rates and with changes of ownership and the number of Ability to Benefit students. Low default rates also correlated with longer programs. However, the analysis has found that default is not a complete or reliable proxy for overall school performance. Accordingly, undue