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3. Study of Licensure and Related Health Personnel Credentialing,

conducted by the Department of Health, Education, and Welfare;

4. Study of Accreditation of Selected Health Educational Programs, sponsored by the American Medical Association, the Association of Schools of Allied Health Professions, and the National Commission on Accrediting;

5. Model State Legislation for Approval of Postsecondary Educational Institutions and Authorization to Grant Degrees, developed by the Education Commission of the States through funds supplied by the Office of Education, the Veterans Administration, and the Department of Defense; and

6. Study of Private Accrediting and Public Funding, prepared for the Office of Education under contract with the Brookings Institution and the National Academy of Public Administration Foundation. Review Procedures for Listing Nationally Recognized Accrediting Agencies

Those accrediting agencies requesting recognition by the Commissioner of Education undergo intensive review by the Office's Accreditation and Institutional Eligibility Staff and by the Commissioner's Advisory Committee on Accreditation and Institutional Eligibility, in order to determine whether or not they comply with the Criteria for Nationally Recognized Accrediting Agencies and Associations.

The Accreditation and Institutional Eligibility Staff was established by the Commissioner of Education in 1968 in order to centralize matters within the Office of Education dealing with eligibility and accreditation and to provide support for the Commissioner of Education's Advisory Committee on Accreditation and Institutional Eligibility.

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Accrediting agencies seeking recognition by the Commissioner, or

those undergoing regular periodic review, file petitions with the Director of the Accreditation and Institutional Eligibility Staff. The Staff reviews the petition and may take various investigative steps in order to prepare a summary report to the Advisory Committee concerning the applicant's status with the Criteria for Nationally Recognized Accrediting Agencies and Associations. At the time of the Advisory Committee review, agency representatives and interested third parties are offered time for brief oral presentation before the Committee. Advisory Committee recommendations regarding petitioning accrediting agencies are forwarded to the Commissioner of Education for his review. The Commissioner informs the applicants of his decision following his consideration of the Advisory Committee's recommendations.

The

Agencies listed, or recognized, by the Commissioner are normally reviewed every four years. Developing agencies may be given a shorter period of recognition, indicating the Commissioner's determination that such agencies have potential to eventually fulfill the Criteria. The Commissioner exercises the right to review at any time a recognized, agency which has developed problems relevant to its compliance with the Criteria.

Appeals of the Commissioner's decisions are heard by specially constituted panels of knowledgeable nongovernmental persons who are not members of the Advisory Committee. These hearing panels report directly

to the Commissioner, who acts upon their advice.

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The Advisory Committee performs a key role in the process of recognizing accrediting agencies and associations for the purpose of determining institutional or program eligibility for Federal funding programs. The Committee was established by the Secretary of Health, Education, and Welfare in 1968 and was subsequently chartered under the Federal Advisory Committee Act (P.L. 92-463). It is composed of 15 members from various segments of the secondary and postsecondary education community, student/youth population, State departments of education, professional associations, and the general public. The Committee is advisory to the Secretary of Health, Education, and Welfare and the Commissioner of Education. Its functions include the authority to:

1. Review all current and future policies relating to the responsibility of the Commissioner for the recognition and designation of accrediting agencies and associations wishing to be designated as nationally recognized accrediting agencies and associations, and recommend desirable changes in criteria and procedures.

1 2. Perform similar functions relevant to the Commissioner's authority to recognize State agencies for approval of public postsecondary education and nurse education;

3. Review and advise the Commissioner of Education in the formulation of all current and future policy relating to institutional eligibility;

4.

Review legislation affecting the Office of Education's

responsibility in the area of accreditation and institutional eligibility and recommend needed changes;

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5.

Review and recommend action to the Commissioner of Education regarding applicant national accrediting agencies and State vocational

and nurse education approval agencies;

6. Develop standards and criteria for specific categories of vocational training institutions and institutions of higher education which have no alternative route by which to establish eligibility for Federal funding programs;

7. Advise the Commissioner regarding the award of degree-granting status to Federal agencies and institutions.

STRENGTHS, WEAKNESSES, AND PROBLEM AREAS IN THE PRESENT SYSTEM

I turn now to several key observations about the dynamics of the present system, gleaned from the Office's six years' experience in monitoring the eligibility mechanism I have described above. These observations are offered in the spirit of enlisting your continued support for the improvement of the system.

1. The relative autonomy of the accrediting agencies.

Accreditation has been written into Federal legislation as a quality control device in order to help ensure the Government's investment in postsecondary education, and, even more importantly, as a means of aiding students and others in identifying institutions and programs deemed to be educationally worthy. We must constantly bear in mind, however, that the accrediting agencies are private, independent, voluntary agencies having discrete, albeit laudable, purposes which do not always coincide neatly with the objectives inherent in Federal aid to education.

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Accrediting agencies are committed philosophically to stimulation of institutional or programmatic uplift through a traditional pattern of expert peer review. They do not view themselves, nor do they function, as regulatory bodies. They have no legal authority to require compliance; they work instead by persuasion to maintain understanding and acceptance of their role and function by their constituents and the general public. All accrediting agencies are limited in funds and staffing, and rely heavily on volunteer labor from member organizations. All are now deeply aware of, and some have already experienced, a marked vulnerability to litigation, which they are ill-prepared to engage in successfully.

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One aspect of the Office's relationship to accrediting agencies involves the processing of complaints against accredited schools and schools which are eligible for participation in Federally-funded programs of assistance to postsecondary education. Complaints about schools whether accredited or non-accredited - are directed to the Accreditation and Institutional Eligibility Staff from many sources. These include parents, consumer organizations, students, USOE regional offices, other divisions within O.E., other Federal and State agencies, the Congress, and the White House. These complaints include such matters as misrepresentation by salesmen, inadequate or late refunds of tuition, poor quality of instruction or equipment, and enrollment of persons

incapable of benefiting from the instruction.

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