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federal government would establish a parallel system of accreditation by another name with a giant bureaucracy to administer it.

This was not what I had in mind and I should hope that the thousands of institutions in this nation would resist such a move if it

do so.

should occur. I assure you that the private accrediting community would My earlier proposal, stripped of any fancy language, was simply that the federal government should rely on accreditation as a significant criterion in determining eligibility for federal funding, as was originally intended by Congress, but at the same time, the Congress should introduce its own, simpler system, for ascertaining the eligibility for the myriad of programs and institutions.

I wish to emphasize for this subcommittee, as I did for the earlier committees, that accreditation should not be expected to serve as collateral for, nor procurer of federal funds for institutions, programs or Accreditation can and does speak to the consumer

individual students.

up to a point and that point is that the institution or program is providing the very best quality it is capable of providing given its human and financial resources. But, accreditation cannot authorize the establishment of institutions, nor can it force them to cease to operate. It can only work to help improve those institutions in existence that sincerely seek consultation and services.

Accreditation has served education in this nation most effectively for more than half a century and it is willing to continue doing so, if it is allowed to operate within its capabilities and voluntary parameters.


It should be pointed out that accreditation cannot be a surrogate ministry of education in a nation where the founding fathers clearly guarded against such a structure; nor can accreditation serve as a protective agency to respond to every consumer complaint.

You may well ask what the alternatives are for determining eligibility if we do not use accreditation as the sole determiner. May I suggest that there are two or three other sources of assistance that should be considered. First, it is my judgment that the Higher Education General Information Survey (HEGIS) has the capability of aiding in the determination of institutional eligibility.

This annual report form, now required of all nonprofit educational institutions, contains enough quantitative data from which quality

could be interpolated to satisfy the federal requirement for eligibility for federal funding. I dare say that it contains more data on which to make a determination than do the periodic reports required of institutions by bona fide accrediting bodies.

Probably with only little modification, the same HEGIS-type report could be made available to the proprietary sector of postsecondary education. Through this method, even though accreditation might be assigned a weighted factor in the eligibility determination, the institutions would be relieved of establishing eligibility solely through the accrediting mechanism. It would, at the same time, relieve the accrediting bodies of institutional pressure and pressure from various professional bodies to attest to qualitative indices which perhaps should only be de


are attached.

cided over a longer period of time. It certainly would, we feel, reinstitute among institutions and programs the desired atmosphere of competing for excellence within parameters other than those to which dollars Hopefully, accrediting agencies, for which assuredly there would be decreased activity under such a plan, could then engage in a more cooperative surveillance of postsecondary education with the Federal Government than now exists. To be sure, such a plan forces institutions to pursue a dual route--toward eligibility for federal funds in one lane and accreditation in the other-but they will have the option of traveling in either lane independent of the other. now have this option.

They do not

If what I have proposed would be construed as a threat to some accrediting groups because without the absolute necessity of accreditation for funding many institutions might not seek their services, then so be it. Such a condition would reduce the degree of "mandatism and reesta


blish a "voluntarism' on which the concept of accrediting was established. Those institutions voluntarily seeking accreditation would then be doing so at an educationally higher level of desire.

Second, I should suggest that elements in the assessment of institutional or programmatic quality that have to do with areas set forth in the laws of the land (such as affirmative action, racial integration, equality of opportunity, consumer protection, etc.) should be eligibility factors monitored by some agency other than the accrediting agencies. It would be quite appropriate for these responsibilities to be assigned


to a qualified state agency, provided the Accreditation and Institutional Eligibility staff of USOE has sufficient evidence of the ability of the state agency to perform these tasks in an effective manner.

In conclusion, let me re-emphasize that the education community does not desire that the United States Office of Education or any division of that office become a ministry of education, such as that operating in France. If such a pattern is developed further, we shall lose the spirit of innovation and experimentation that has characterized American higher education over the years. It is appropriate to expect that the federal government should check on the proper expenditure of funds; however, the government should not place itself in the position of oversight that would permit it to determine what should be taught, by whom it should be taught, or how it should be taught. If the present trends continue in the exercise of controls over the accrediting organizations, such an occurrence is most certainly within the realm of possibility.





The Senate Subcommittee on Education

Honorable Claiborne Pell, Chairman

presented by

Robert Kirkwood, Executive Director

Federation of Regional Accrediting
Commissions of Higher Education
September 13, 1974

Mr. Chairman and Members of the Subcommittee:

On behalf of the Federation of Regional Accrediting Commissions of
Higher Education and its nine regional constituent commissions, may I express
our appreciation for the opportunity to participate in this hearing.
We are
keenly aware of the importance of this Subcommittee's work and trust that our
contribution will facilitate your efforts on behalf of postsecondary education
in the United States.

Let me begin by distinguishing between the two major types of voluntary nongovernmental accreditation, institutional and specialized, each with particular characteristics. Institutional accreditation normally applies to an entire institution, indicating that each of its parts is contributing to the achievement of an institution's objectives, although not necessarily all on the same level and quality. The Federation of Regional Accrediting Commissions of Higher Education works directly with the nine regional commissions in the field of institutional accreditation, and they in turn work with approximately 2600 individual institutions. Specialized or professional accreditation deals with

Jack K. Williams, President

President, Texas A & M

University, College Station, Texas

Donald L. Roush, Vice Pres.
Vice President, New

Mexico State University

Robert Kirkwood, Executive Director
Eugene I. Van Antwerp

Associate Executive Director

One Dupont Circle, Suite 770 Washington, DC 20036 202-872-1197

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