ED Wraps Up First Week of Program Integrity and Institutional Quality Negotiations

By Jill Desjean, Senior Policy Analyst

The Department of Education (ED) and non-federal negotiators wrapped up their fourth and final day of negotiations related to program integrity and institutional quality on Thursday, focusing the entire day on the topic of accreditation.

The day began by revisiting topics discussed on Wednesday afternoon, which had been discussed broadly but without visiting proposed regulatory text, which was Thursday’s focus. 

First up was the topic of limiting who can fill public member seats on accreditation decision-making bodies, which was met with limited discussion other than a suggestion that ED look at all positions on such boards for conflicts of interest instead of focusing solely on members of the public.

Also discussed again was the proposed reinstatement of a requirement that accreditors seeking recognition or renewal of recognition provide documentation that the agency’s practices are widely accepted by others by providing letters of support. A robust discussion ensued about the perceived value of such letters, the accountability of letter-writers, and whether ED should be more focused on looking for negative feedback in addition to or in place of letters of support in light of the fact that it would be relatively simple for most accreditors to provide three letters. 

Limited discussion followed on topics like expansion of scope, ensuring consistency, timelines, innovation, substantive changes, anonymous complaints, and applications for recognition or renewal of recognition. ED noted much in these topic areas represents a reorganization of the regulations versus substantive changes. 

Negotiators then moved on to discussion questions posed by the department, starting with how ED can determine whether accrediting agency standards for areas like student achievement, fiscal and administrative responsibility, and recruiting and admissions practices are sufficiently rigorous. Negotiators discussed the distinction between standards and metrics, and accreditation representatives stressed the importance of nuance and the need to look at the entirety of an institution to tell the story of a school’s performance, taking into account many factors about the school and not just the metrics themselves.

Discussion followed on teach-outs, where negotiators generally agreed many problems exist, and how ED could develop and codify a risk-based process for recognizing accreditation agencies. 

The group finished the week’s discussions by addressing the topic of institutional changes to  accreditors in light of 2020 changes that allowed regional accreditors to operate on the national level and action in Florida and North Carolina to require schools to change accreditors. Questions discussed included how the department should define an institution’s voluntary choice of accreditor and which factors to consider in determining a reasonable cause for switching accreditors. 

Thursday’s public comments included Cheryl Dowd from the WCET State Authorization Network, who spoke on the student complaint process for distance education reciprocity agreements with respect to student changes of location, as well as on the proposed requirement for attendance taking for distance education. 

Kimberly Jones of the Council for Opportunity in Education also spoke during public comments, where she urged the department to consider Pell Grant eligibility as a criteria for TRIO programs given changes from the FAFSA Simplification Act that limit sharing of student data that TRIO programs have traditionally relied on.

On Friday, ED’s subcommittee on TRIO programs will meet to discuss proposed changes to the regulations governing those programs. Negotiators will meet next during the week of February 5.


Publication Date: 1/12/2024

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