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an accredited institution, he is not an accredited graduate. He is a graduate of an accredited institution.

The record you speak of is something that many of us have been looking to as a very desirable development, wherein an individual will have-in fact, John Summerville, at Educational Testing Service, is working on a project to develop what is called an educational passport, which would be a lifelong record of an individual's educational activities wherever they may have taken place, whether they be in the formal institution, or whether they be in informal courses, or whatever they may be.

We see that as highly desirable. I think too often in the past we have tried to compartmentalize education too strictly. We have confined certain kinds of education and said, well, that was acceptable, but then we have ignored whole other areas of experience or educational training and development, which I think are equally and sometimes more important.

Our hope really would be that we could develop the concept of the individual as having a continual educational development and experience which could be recorded in one of several ways.

The regents of the New York State Department of Education are developing one way. Thomas Edison College in New Jersey is developing another way. Empire State College in New York, and the Antioch College system are developing in still other ways.

There are a number of very innovative and interesting, if still experimental, projects along these lines. But the thrust of many of them is to give the individual the kind of credentialing which is no longer just a diploma of the accredited university or college, but a credential which reflects more accurately what he has learned through various ways over the course of his entire lifetime.

This I think would be highly desirable.

Senator PELL. Thank you.

What is your view, either of you gentlemen, or both, with regard to the nonresident, or external, less painful Ph. D. program, like Nova University, do you have any view on that?

Mr. DICKEY. Well, it is a very touchy and difficult question, because there are some programs that are very reliable and worthy of recognition. There are others that perhaps have not been adequately staffed and thought out, and maybe the standards are not as rigid as they should be.

Senator PELL. Let us be specific and talk about Nova University. Mr. DICKEY. I would agree with something that Dr. Kirkwood and I talked about earlier, that is that Nova University perhaps has been looked at more carefully and consistently over a longer period of time than many of the more traditional institutions.

The accrediting organization for that region, the Southern Association of Colleges and Schools, has been working with, and has reviewed the programs of Nova for a period now at least, I am sure,

of 8 or 9 years. So they have certainly adequate information I think on which to base their decisions.

The really difficult question comes when you compare it with certain other nontraditional schools and, say what is the real difference between Nova and X University that may not be accredited. But I think that basically in terms of what the product of the school is, what the procedures are, what the staffing pattern is, and so forth, that all of these things have been very carefully looked at by the Southern Association as far as Nova is concerned.

Senator PELL. Is there ever an insidious relationship between individual accreditors and their participation in a university in some of the quirky weekend seminars, whatever they are called?

Mr. DICKEY. So far as I know, I do not know of anything of that


Senator PELL. Is it your view that the graduate of Nova, from your own knowledge, and you should have specific knowledge of this, while he may not measure up to a Yale Ph. D., does measure up to what is considered the lowest level of Ph. D.'s?

Mr. DICKEY. I think that is a safe assumption. The quality of the individuals holding degrees from Nova certainly would be comparable to those from other institutions. I think this is part of the assessment that the accrediting organization made to determine whether or not the product is such that it might be comparable to others.

Mr. KIRKWOOD. I would tend to make a distinction between less painful and less arduous. I think sometimes the doctoral process, as we have known it, has been painful, but not necessarily always as demanding, and as arduous as it should have been.

Senator PELL. It is financially painful.

Mr. KIRKWOOD. Yes, and sometimes even physically painful. But I do think in the case of Nova, as Dr. Dickey has pointed out, there has been a great deal of surveillance on this institution simply because it has been controversial. It is an innovative undertaking, and here I think is a good illustration of the dilemma that the accrediting commissions have been faced with as non-traditional activities have developed in recent years.

The difficulty of drawing a line between what is legitimate experimentation and giving that experimentation an opportunity to prove itself out, and those things which are clearly opportunistic and are at best marginally respectable educationally.

Senator PELL. I thank you both very much for the frankness and thrust of your testimony.

I wish Dr. Dickey good luck in his new pastures back in academia. Thank you for being with us.

Mr. DICKEY. Thank you.

[The prepared statements of Mr. Dickey and Mr. Kirkwood and other material subsequently submitted by the National Commission on Accrediting follow:]

41-997 O 75 16



Frank G. Dickey

Executive Director

National Commission on Accrediting
September 12, 1974

Mr. Chairman and members of the Senate subcommittee on Education, I am Frank G. Dickey, Executive Director of the National Commission on Accrediting. The National Commission on Accrediting is a private, nongovernmental association of some 1,200 institutions of higher education that banded together in 1949 through the associational mechanism to monitor and coordinate the existing and merging programs of accreditation for professional and specialized education in this nation.

I appreciate the opportunity to present this testimony and even though time may preclude the inclusion of the entirety of this written statement in my oral presentation, I request that the entire written statement be entered into the record of these hearings,

During this summer several Congressional subcommittees have held hearings relative to the relationship of accreditation and eligibility for federal funding. The vast majority of the witnesses appearing at these hearings have expressed the belief that the federal government should not continue to rely as heavily as they presently do upon accreditation as the almost sole determinant of eligibility for federal funds. Accreditation was not designed or developed to serve this particular purpose. The accrediting agencies did not seek this function; rather,


it was assigned to them by Congressional action; however, in doing so, Congress did not intend that the nongovernmental accrediting organiza

tions should become subject to a set of criteria that now are forcing the accrediting agencies to conform to certain federal criteria and also to perform tasks that take on the flavor of policing functions not compatible with the work of voluntary associations.

More specifically, accrediting organizations have been enticed to

become reluctant extensions of the U.S. Office of Education in order

that the accredited schools, programs, and colleges might share in the largesse writ large. Many now would like to break off the relationship, and some have indicated they intend to do so, in order to return to the prerogative which historically and professionally has belonged to them -that of promoting and insuring quality programs of education. capable of doing just that and are perfectly willing to abide the scrutiny of the federal benefactor in so doing. They are not willing much longer to abide the prod which inevitably has followed the scrutiny.


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If, as believe Congress originally intended, there is to remain the "partnership" relationship between the U.S. Office of Education and the private accrediting bodies in this country, then the federal body is going to have to quit presuming the majority stockholder attitude in the


Let me say that accreditation and accrediting bodies have not been put upon altogether unjustifiably since 1952 when the Commissioner of Education began to rely upon them as the primary determinant of eligi


bility for federal funds.* I will say, that in my opinion, the accrediting community has moved much faster in correcting some deficiencies and establishing its capability to speak for eligibility based on quality than has the federal mechanism in establishing any valid system for determining eligibility for institutions outside the prerogative of accrediting bodies. That really is where most ofthe current abuse we

read about resides.

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And, the accrediting bodies can yet go some further, perhaps, in incorporating some of the needed consumer interests into their evaluating processes. They cannot and should not go much further in the direction of acting as enforcers of social policy such as affirmative action, health and safety standards, or collective bargaining agreements.


The time has come, in our opinion, for the legislation relating to the determination of institutional eligibility for federal funds at the postsecondary level to be revised or amended in such a manner that other factors in addition to accreditation should be utilized in determining


After I had presented testimony to another Congressional subcommittee earlier this summer some of my colleagues indicated that they believed I had sounded the death knell for nongovernmental accreditation when I advocated a separation of the accreditation and eligibility functions for purposes of federal funding. They pointed out that if my sug‐ gestion were to be taken seriously by the U.S. Office of education the

Veterans' Readjustment Assistance Act of 1952 (P.L. 82-550) **Proposed Criteria for Recognition, Nationally Recognized Accrediting Agencies and Associations, Office of Education, Federal Register, Vol. 39, No. 42, Friday, March 1, 1974. p. 7948, 149.6 (Criteria) b(4).

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