EQUIP and the role of accreditors — get it right

Posted on March 3, 2016

The US Department of Education (and government generally) and regional accreditors do not generally innovate. They really are not built to do so, with the former stewarding billions of dollars of federal financial aid and the latter tasked with ensuring at least minimum standards for quality. So ED’s announcement of the EQUIP experimental site has been met with a mix of interest and skepticism.  Generally, experimental sites offer modest tweaks to Title IV rules around disbursement of financial aid, not terribly innovative or experimental.

While modest in its scope (some ten or so programs to be approved, we think), EQUIP is bold in its ambitions. If successfully implemented, EQUIP would for the first time allow non-traditional providers of learning directly into the Title IV eco-system for the whole of their program offering. It would also stand up new outcomes-focused approaches to quality assurance. For example, EQUIP would allow a coding boot camp to be reviewed by a third party quality assurance entity (QAE) and to enter into a partnership with an approved institution of higher education (IHE) so that the boot camp students could receive federal financial aid. While IHE’s can contract with third party providers for 25% of a program offering and up to 50% with accreditor approval, EQUIP waives the 50% cap and allows the whole of the non-IHE’s program to be approved for aid.   There is a lot of interest, with a large number of proposed partnerships and many new organizations expressing interest in being a QAE.

As outlined in the Federal Register (https://www.federalregister.gov/articles/2015/10/15/2015-26239/notice-inviting-postsecondary-educational-institutions-to-participate-in-experiments-under-the#h-10), proposed EQUIP partnerships need not only a review by one of the new QAEs, but also the approval of the IHE’s accreditor. And herein lies a substantial problem for moving forward with EQUIP.

Accreditors have not yet been given guidance on their role and how they should approach the approval process. They are still seen, however, as a critical step in the quality assurance process at the institutional level within EQUIP. Yet they are smarting from a combination of general criticism that they do not do their job well (much of it from ED and members of Congress) and the threat of ED’s Office of the Inspector General (OIG) launching investigations and issuing scathing reports, as it recently did on the Higher Learning Commission’s handling of competency-based education (CBE) programs.

If EQUIP is to go forward, it requires the active participation of accreditors and this is one area of the initiative and while some initial conversations have taken place, the role of institutional accreditors is not yet fleshed out. I want to offer my own two cents on how to address the role of accreditors, informed by my time at the Department of Education and work on the program, and unencumbered by self-interest, as SNHU is not putting forth an application (it would be seen as a conflict of interest given my role in EQUIP’s design and launch).  I fully support the goals of the initiative and offer my counsel in that spirit.

All parties should keep in mind that EQUIP does not open the flood gates to new providers. A small number of such partnerships are being approved and ED can end the experiment at any time. IHEs and institutional accreditors are not being shut out of the initiative (indeed, they retain privileged roles). Most importantly, the quality assurance questions that proposed programs are being asked to address are rigorous. Actually, they are far more rigorous than are asked of traditional IHEs, and many traditional programs would be challenged to adequately address them. Also, all parties are kept on a very short leash, with mandatory reporting every six months. In sum, EQUIP is a tough sandbox in which to play, has a very small number of players, and will be closely monitored.

Another issue of perspective here is to remember that EQUIP is intended to be an experiment. Opponents and skeptics of the program in and out of the Department confuse writing policy – -which is complex and has to account for unintended consequences and the genuine threat of abuse – with creating safe and responsible space for innovation and experimentation.   EQUIP is happening through the Secretary’s authority to create experimental sites within Title IV – -with the aforementioned ability to select, limit, and shut down any and all of them – yet the desire to treat it as policy not only sparked intense debate within the Department, but has resulted in a program design that asks so many questions of the experiments that I marvel at the amount of interest so far shown. Bottom-line: Don’t over regulate an experiment. The Department has already layered enough onto the work. Accreditors should not be asked to pile on with even more expectations. For example, asking for Substantive Change submissions for what is an experiment with a single program less than a degree makes little sense, nor is it required in the Federal Register notice.

My point is to keep EQUIP in perspective. What does that mean for accreditors?

The quality assurance process outlined in the Federal Register notice is so rigorous, the accreditors should adopt it as the basis of their reviews and not add additional layers of review or standards to what is already being asked. The accreditor questions should be:

• Has the IHE and the QAE conducted a review that answers the Federal Register questions in a way that gives us confidence?  How will that review continue as the proposed program is implemented?  How will that information be made available to students?
• Does the IHE have the policies, processes, and resources to provide the ongoing monitoring required?
• Is the IHE making very clear to prospective students for the proposed program what supports and services normally made available to it students will and will not be available to them?  Do the services available appear to be adequate for the intended student body?

For the sake of the experiment and given all that is already being asked, I think accreditors can easily assemble a review team with a reasonably streamlined process to answer these three core questions.

However, the Department of Education also needs to give the accreditors air cover so they are not later taken to task by the National Advisory Committee on Institutional Quality and Integrity (NACIQI), the body that periodically reviews and renews their authority, or by the OIG (full disclosure: I am a member of NACIQI).  As we ask accreditors to strike a balance between serving as watchdogs and supporting innovation, they also need a “safe space” to learn and experiment. Ted Mitchell, the Under Secretary of Education and a champion of EQUIP, can issue a Dear Colleague Letter (DCL) outlining both what is being asked of the accreditors and what they are being given freedom from in terms of their normal review processes and standards. While a DCL does not carry the weight of law or rule making, it can serve as documentation that the accreditors have acted as they have been asked to do by the Department’s top higher education official. Another option is to outline the expectations of accreditors in the formal guidance the Department can issue around the program.   Either approach helps and while that might even seem like a bit of overkill to some, accreditors feel beleaguered and there is only risk and little reward for their participation in EQUIP at this point.

Finally, the Department needs to decide how large any of the approved programs should get while in the experimental site phase. We’d hope to see enough scale to make the learning meaningful. The providers need to see enough scale to help justify their investment of time and resources, but also remember that EQUIP is an experiment, not a new market. At least not yet. Too much scale and risk exposure increases (if these are truly experiments, some of them will work less well than others) and it is harder to shut down if and when the time comes. I’m not sure what the right number is for any given program, but accreditors will seek guidance on this question.

With CBE, we have seen the power of giving regulatory breathing room to institutions and in a very short time, more than 600 institutions are working on CBE offerings that have the promise of improving quality while lowering costs. EQUIP has similar promise, helping us learn how to put high impact new program offerings in the reach of financially limited students and giving us insights into new and better way to assure quality in such programs and in higher education generally.   My hope is that the new QAE processes come to inform the thinking and practices of the incumbent accreditors and can be applied to CBE and other innovative programs in the future, but we have to lower the risks for institutional accreditors and make it possible for them to be involved.