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Senator PELL. What about an example of nonaccredited cosmetology schools?

Mr. KIRKWOOD. Cosmetology schools are to be represented through the Council of Specialized Crediting Agencies, which has representation on the Board of the Council on Postsecondary Accreditation. Senator PELL. So every institution beyond high school will be represented?

Mr. DICKEY. I think I see your point. The nonaccredited institutions would not have direct representation, because representation comes through the various accrediting organizations.

Now, there is one other side of that, though. The 25 percent public representation on this Board, we think, would speak for the entire populace regardless of whether they are accredited or nonaccredited. So, on that basis, I think there would be some voice that would be available for them.

Senator PELL. What about the Berlitz School?

Mr. DICKEY. There is a possibility that their courses will be eligible for evaluation, and for ultimate transfer of credit through a new organization that has just been established by the American Council on Education, namely the Office of Educational Credit, which for many years has reviewed the military courses. Now they are ready to expand their services to include courses that are offered by various types of organizations or institutes, such as Berlitz.

On this basis, the Berlitz courses are eligible not necessarily for accreditation per se, but at least for inclusion as credit courses in accredited institutions. The representation on this Board would come directly, because the American Council on Education, which is the sponsoring agency for the Office of Educational Credit, will have one representative on this Board also.

Senator PELL. Thank you.

Mr. KIRKWOOD. May I just outline briefly some of the purposes of the Council on Postsecondary Accreditation?

They shall be to promote the improvement of postsecondary education, principally through the process of accreditation and such other means as it shall devise;

Review continuously the accrediting practices of all its members to insure the integrity and consistency of their policies and procedures and to safeguard the freedom and quality of postsecondary educational institutions and programs;

Promote the interests of the educational consumer, including provisions for direct public presentation in the conduct of the affairs of the Council; and

Insure that each member accrediting agency of the Council shall provide clearly defined procedures for handling appeals through due process; and a number of other purposes all directed toward strengthening postsecondary education in the United States.

It is fashionable in some quarters these days to deprecate the importance of postsecondary education and to derogate the value of its contributions to American society. We deplore any such tendency. Time and again the educational community has responded vigorously

and imaginatively to the Nation's continuously changing needs, and we are confident of its ability to go on doing so.

Formation of the new Council on Postsecondary Accreditation is a current manifestation of that ability. But vigor and imagination are stultified by unnecessary and unwarranted regulation. To lose entirely or even partially the creative and constructive potential of the voluntary accrediting process as it relates to postsecondary institutions would be a profound loss for American education and the Nation.

We respectfully submit, therefore, that the efforts of this subcommittee to reexamine the relationship between accreditation and eligibility for Federal funding are both timely and welcome. The regional accrediting commissions are fully prepared to meet their social and educational responsibilities.

We can do so best, however, in cooperative partnership with Government and not under the constraints of administrative regulation authority by the Congress.

Thank you for your attention, and for the opportunity to testify. Senator PELL. I thank you both very much. I appreciate, Dr. Dickey, the frankness of your testimony, the open thrust of it.

I understand you are not retaining your present position, and that may account for the extra degree of frankness.

Mr. DICKEY. That is correct. I am going back to the firing line, and get back on the college campus for a while.

Senator PELL. Just for the record, is your Commission set up as a Government Commission or a private commission?

Mr. DICKEY. Private commission. It is nongovernmental, and is supported by the institutions of higher education, and they hold membership in the organization. So it, in essence, represents institutional interests in their relationships with the various professional and specialized accrediting agencies, such as those in law, medicine, and engineering.

Senator PELL. Is there any Government money which goes into its administration and operations?

Mr. DICKEY. No.

Senator PELL. Dr. Kirkwood, the proposed Council you are setting up, would any Government money go into that, or would it be completely private?

Mr. KIRKWOOD. Completely private.

Senator PELL. Basically this proposed Council, which to me, at first brush, sounds like a fine idea, would be taking over the total accrediting processes that are now performed by the Commission which Dr. Dickey has been Chairman, is that correct?

Mr. KIRKWOOD. Well, not taking over the accrediting process. The Council on Postsecondary Education will not be an accrediting agency itself, except insofar as you might interpret the recognition of accrediting agencies as accrediting the accrediting agencies.

But the function of accreditation will remain with the accrediting bodies as presently constituted, with whatever modifications, recogni

tion or changes in that status the Council may decide at some future date.

But the functions of the National Commission on Accrediting and of the Federation of Regional Accrediting Commissions will indeed be taken over by the new Council.

Mr. DICKEY. I might just add that the function of the new Council will really be one of coordinating and monitoring the various accrediting agencies that will continue to perform the functions that Dr. Kirkwood has just outlined.

Senator PELL. One point where I would disagree with Dr. Dickey's thoughts is his concern, or position on the idea of a Department of Education. I would have thought a Department of Education and Culture would be a very good idea. All our legislation is drafted so that the day will come when we can spinoff a Department of Education and Culture.

Mr. DICKEY. Yes. I am glad you raised the question, because I left the improper impression, I think.

I would have no objection, and in fact, I would be heartily in support of a separate Department of Education.

Senator PELL. Would you support a Department of Education and Culture?

Mr. DICKEY. I think this would be a very fresh and interesting approach to it.

What I had in mind in my statement was the fact that we did not want a Ministry of Education that is all powerful, as they have in many other nations of the world—that would determine the content and the methodology of the schools and the colleges and universities. I would not disagree in any way with the concept of a separate Department of Education and Culture, but I would want the functions of it so defined that we would not get over into the business of determining the very heart and nature of education itself.

Senator PELL. This is one of my own dreams. Some time during my chairmanship we may see spun off such a department, because I believe now that the Office of Education, the Endowments for the Arts and Humanities and whatever Federal support there is for Museums, all of this should be put into one agency.

I see it myself as an individual Senator, because I am Chairman of the Subcommittee on Education, Arts and Humanities, and the Smithsonian Institution. They all come under my jurisdiction. It should come under a departmental head, I think.

Mr. DICKEY. You may be interested in knowing, in my first draft of this testimony I had included some several paragraphs about the desirability of a separate Department of Education, separate from the Department of Health, Education, and Welfare.

In an effort to direct the testimony more directly at the topic under consideration, I left that out. But I think we are in complete agreement on that.

Senator PELL. Good. As I see it, my idea is not just a Department of Education, but a Department of Education and Culture.

Now, as I understand the general broad thrust of your testimony, and as I understand the thrust of the Government people yesterday, the Government feels the private accreditation groups ought to do it, and you feel that the Government ought to do it, and we in Congress will have to make the decision on it.

Would that be an oversimplification, as you see the picture?

Mr. DICKEY. I suppose it gives this appearance of trying to shift the responsibility. Actually I think we would like to see a clearer definition of what the responsibilities are. Obviously accreditation is reluctant to undertake some of the responsibilities that the Office of Education would like for it to assume, not because we disagree with the particular concepts involved, but because we feel it is incompatible with the voluntary organizational pattern.

Mr. Kirkwood may have something to add on this.

Mr. KIRKWOOD. Yes. I think there is a further point to be made there, and that is that while the Office of Education has been laying down all sorts of strictures about what the accrediting agencies shall do, and what is expected of them in the criteria, there are no similiar strictures or guidelines as to what we can expect in terms of the behavior of the Accreditation and Institutional Eligibility Staff, for example.

We do not know how they will handle certain grievances, for example, if they are brought by institutions. We do not know whether they will, or can, or are permitted to interrupt the accrediting process, as we carry it out.

There is as of yet no clearly defined procedure whereby we can know how the Office of Education will respond to particular situations.

Senator PELL. As I understand the thrust of your testimony, accreditation should just become one factor in eligibility.

Your thought is, there could be accredited institutions that might not be eligible for governmental financial aid available to students, and there might also be unaccredited institutions that would be eligible, is that correct?

Mr. DICKEY. This is correct from my point of view.

Senator PELL. An academically eligible institution, but on its last leg financially, might be accredited, but noneligible.

On the other hand, an excellent, little, newly started career training school might be still unaccredited, for time reasons, or others, and yet would be eligible?

Mr. DICKEY. I would say I think, the first example is probably unlikely, because if an institution is that much on the rocks it probably is not going to offer quality programs, but it is conceivable. Certainly the latter example you gave is true.

Senator PELL. There are examples, I am sure, of academically sound institutions which are in bad financial condition.

We in the Congress usually are asked, or are expected to come up with quick answers on any given subject. In this field we are expected to create some special law that would affect certain schools which are accredited, but which are also so-called bad actors.

Yesterday's testimony, and yours again, indicates that there is really no simple answer What do you think we should do?

Mr. KIRKWOOD. I am not Solomon, nor do I have a simple answer, either.

Senator PELL. Do you have a complex answer?

Mr. KIRKWOOD. We have tried to suggest, sir, that there is obviously a proper role for the Government in the field of education. Many of us are deeply indebted for the leadership that has come out of the Office of Education, and from the Congress, in recent years in developing what have been often very imaginative programs, programs which inevitably because they were developed by human beings, did have limitations; on the whole, the record is truly a remarkable record, I think something we all ought to be greatly proud of.

At the same time, there is, as Dr. Dickey has suggested, a fear of too much governmental involvement in education. The historic nature of checks and balances in this country has been, I think, often the best solution, where instead of giving ultimate and absolute power to any one agency or any one body of Government, or outside of the Government, whatever it may be, we have devloped balancing mechanisms whereby one agency has certain authority and responsibility, a second agency may be of similar or related authority and responsibility, but one tends to check the other if it gets out of line.

I think there is room for a very effective, cooperative relationship between the Office of Education and the Council on Postsecondary Accreditation, and the various individual accrediting agencies.

I think what we need perhaps most of all is a clearer definition of what the parameters of responsibility and authority are for the government bodies.

I think here it is important to distinguish between the limits of Federal authority for education and the responsibilities of the States for control and regulation of educational activities.

There is a fine line at times, and sometimes the independent nongovernmental bodies can help to fill the gap between the Federal and State government and agencies.

But to get more specific than that at this point, I think, would be extremely difficult.

Senator PELL. The trouble is that we have to be specific, and we are faced with specific problems. Along this line, the total picture of a person's education, certainly the fact that he has finished the Dale Carnegie course, the Berlitz course, or Evelyn Woods' speedy reading course, whatever it is, these courses add a great deal to the total intellectual or earning power-capacity of that individual. Should it be included in the total educational transcript of the individual, or do you keep accredited institutions on one side, and then nonaccredited on the other side, and then add them separately or together? Do you have any views on this rather complicated thought?

Mr. KIRKWOOD. I think there is a very important distinction to be made between the accreditation of institutions and the educational record of the individual. We do not involve ourselves with individuals. We do not accredit individuals. If an individual graduates from

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