correlate with longer programs. But default is not a proxy for overall school performance. Too much emphasis has been placed on default rates. Other characteristics have a more significant effect. Some have suggested that tripwire outcome rates should be used to define whether a school is performing adequately. The commission believes that this would be a mistake. It's too simplistic. It would create a safe harbor for schools whose performance should be better. And the apparent exactness of such a test is an illusion. Judgments still have to be made about how to define completion and placement rates. Outcomes assessment cannot be reduced to a mathematical formula. The commission's approach is both quantitative and qualitative. It begins with examining schools' rates of student completion and placement by each program offered at the school and for the school as a whole. And I want to emphasize that the commission's visiting teams verify these rates. We don't simply take the school's word for it. The commission does not use tripwires. The commissioners have backgrounds to make judgments about whether a school's outcome rates are acceptable. If the rates seem low in relation to comparable schools and programs, the school may demonstrate that its performance is still acceptable by pointing to factors outside of its control, such as local economic conditions. The commission then makes a judgment about the school's outcome performance. It is key to whether a school will keep or lose its accreditation. Since 1988, 4 outcomes have been a ground for denial or removal of accreditation in 60 instances. It should be clear, therefore, that the commission believes that performance based outcome measured I've described are critical. In fact, we believe that they should be applied to all institutions of higher education for two reasons. First, the goal of a Federal student aid program is expressed in the original Higher Education Act of 1965 is to provide access so that students can better themselves and meet society's needs for an educated and technically trained work force. That goal applies to all institutions participating in those programs. Ensuring that students are completing and meeting the employment objectives is important to determine whether the Federal investment in higher education is paying off, especially in view of the tremendous and continuing increase in the cost of attending our colleges and universities. Second, the profile of higher education today makes it appropriate to apply performance based measures broadly. The typical student is no longer someone who graduates from a high school in the spring, enrolls in a 4-year college and university that fall, is dependent on his or her family for financial support. The Congressional Research Service reports that 55 percent of undergraduate students are enrolled in proprietary schools of the type that this commission accredits, community colleges or other so-called non-traditional institutions. Students are older, independent and frequently part-time. Their educational objectives are career oriented. Even the American Council on Education has found that getting a better job is the top reason cited for entering fresh men for attending college. In short, these students are much likely to be attending the commission's accredited schools. Let me conclude by briefly offering our views on gatekeeping and how it might be improved. To combat fraud and abuse, Congress, in 1992, mandated tougher gatekeeping by the Department, the States, and the accrediting agencies. The commission, along with other accrediting agencies, expended substantial efforts to meet these expectations. We are pleased to see that Dr. Longanecker in his testimony confirmed that the commission and other agencies are fulfilling these responsibilities. The commission believes that two principles should guide the Congress as it moves toward the next reauthorization. First, accrediting agencies' responsibilities should be focussed on their traditional function of assessing educational quality by using performance based analysis, the outcomes assessment I've described. We have shown that the data and the analysis can be developed for accrediting agencies to do their job. Second, there should be no different level of oversight and regulation for different types of institutions. Congress and the Department should work toward a sensible set of regulations and rules for all institutions, rather than regulatory relief for a chosen few. We should be focusing on results, rather than trying to categorize institutions. Again, outcomes are critical, especially given the changing face of higher education and spiraling costs. We look forward to working with you as these hearings move forward. Thank you. [The prepared statement of Mr. Kube follows:] TESTIMONY OF THOMAS A. KUBE ON BEHALF OF ACCREDITING COMMISSION OF CAREER SCHOOLS My name is Thomas A. Kube. I am Executive Director of the Accrediting Commission of Career Schools and Colleges of Technology ("ACCSCT" or the "Commission"). I have been the Commission's Executive Director since August 1993. Prior to my appointment as Executive Director, I served as the Commission's Associate Executive Director of Operations. Before joining the Commission, I was Vice President and Chief Financial Officer for Arlington Community Residences, a non-profit corporation operating 16 residential vocational training facilities in Northern Virginia, and I managed accrediting functions for the American Automobile Association's national office. I am currently Vice Chair of the Council of National Recognized Accrediting Agencies. I hold an MBA in finance from George Mason University. ACCSCT The Commission and its predecessors have been recognized since 1967 by the federal government as reliable authorities as to the quality of the education and training offered by their accredited schools and colleges. The Commission currently accredits 868 schools located in all 50 states, the District of Columbia and Puerto Rico. They educate and train 450,000 students and employ 16,000 faculty. These schools are private, postsecondary degree and non-degree granting institutions that are principally organized to educate students for trade, occupational or technical careers, including civil engineering technology, computer programming, court reporting, data 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 |