The Uses and Misuses of Accreditation
President Shirley M. Tilghman
November 9, 2012
Presented at Reinvention Center Conference
Good afternoon, and thank you, Dan, for your gracious introduction. I have spoken at many conferences over the years, but this is the first to have "reinvention" as its organizing principle. Building on the work of the Boyer Commission, with its bold prescription for transforming undergraduate education in our nation's research universities, the Reinvention Center has played an important role in invigorating and reinvigorating, if necessary, baccalaureate teaching and learning on our campuses. And that is as it should be, since universities that are content to stand still fall behind. As I once reminded a group of our alumni, many of whom believe that Princeton attained perfection whenever they were students and that it has been downhill ever since, "Charles Darwin famously said that it is not the strongest who survives, or even the most intelligent, but the individual who is most responsive to change. And what is true of individuals is also true of universities."
If we are content to follow well-traveled paths; if we allow our practices and structures, however venerable, to outlive their usefulness, history tells us that even the greatest universities will subside into mediocrity rather than press forward. Only by asking ourselves questions that are every bit as hard as the ones we ask our students will American higher education retain its well-deserved reputation for excellence. Are we, for example, exploring new instructional technologies effectively? Do our academic departments provide sufficient scope for interdisciplinary study? Do we have a campus ethos in which research and teaching are synergistic rather than antagonistic? Are we preparing our undergraduates to prosper in an increasingly interconnected world? Do our campuses truly reflect the diversity that defines America today? And — yes, you knew this was coming — does the prevailing system of accreditation advance or inhibit that pursuit of excellence?
Today I would like to focus on the last of these questions, broaching a subject that Patricia Turner tells me you have been discussing more and more frequently of late, which doesn't surprise me at all. For, in my view, the experience of undergoing an accreditation review and the benefits that attend it have changed dramatically since my first encounter with the system as a faculty member in 1994, when Stanford's president, Gerhard Casper, chaired Princeton's decennial review. I recall my conversation with the peer review team on the challenge of teaching science to non-scientists as an interesting and productive exchange of views that helped my own thinking and those of my fellow faculty. By 2009, when Princeton underwent its five-year interim review, we received glowing feedback from two peer reviewers, only to discover that they had been overridden by the staff of Middle States, our regional accreditor, who warned that unless Princeton was able to document student learning assessment more quantitatively, we were at risk of losing our accreditation. Needless to say, this came as quite a shock. At a recent meeting of the subcommittee of the National Advisory Committee on Institutional Quality and Integrity (NACIQI) that was reviewing the accreditation system in preparation for the reauthorization of the Higher Education Act, a speaker commented that the likelihood of Princeton being de-accredited was equivalent to the likelihood of our winning the BCS National Football Championship. All I can say is that our football coach is feeling pretty perky these days.
In my remarks this afternoon, I do not presume to speak for any institution but my own. I do, however, hope to apply a simple test to the issue of accreditation, and that is the test of utility.
Before I do so, let me state the obvious. Every educational institution in our nation has an obligation to its students, parents, and donors to ensure that in awarding a diploma, they are conferring more than a piece of paper suitable for framing; that this symbol of educational accomplishment embodies high-quality teaching, meaningful learning, and a commitment to enhance these activities wherever possible. In recent years, accreditation has been intended to serve two purposes: first to ensure that institutions eligible for federal financial aid meet basic threshold standards of quality; and second to encourage institutional self-improvement through periodic external peer review. The most important of those goals, in my view, is the first one. Taxpayers have a right to expect that students directly and society indirectly are being well served by the institutions they support through student loans and grants. Ours is a fiduciary trust, insofar as federal student aid is channeled through our institutions with the expectation that this investment will be returned to the public in the form of educated citizens who can contribute to the common good. In 2010-2011, postsecondary students received $227.2 billion in financial aid, and of this, nearly 75 percent was provided by the federal government in the form of loans, grants, work-study funds, and tax credits and deductions. So, there are very few, if any, colleges and universities in this country that do not benefit from the federal dollars that support our students and sustain so many of our research programs.
By the same token, however, our nation's system of higher education has always cherished its independence, rightly regarding institutional diversity and academic freedom among the bedrocks of its vitality. Indeed, whether the measure is international rankings or the choices that international students around the globe make about where to study, this system is indisputably the finest in the world. As the Boyer Commission put it, "The speed with which it developed, its record of achievement, the extent of its reach, the range of its offerings are without parallel." Even today, when we have arguably left the "American Century" behind us, the latest Times Higher Education World University Rankings places American institutions in 19 of the top 25 positions in its list of 400 pre-eminent academies.
One manifestation of our independence is the nature of the process by which we are accredited. Historically, this has been a private rather than a public function, conceived and conducted by voluntary consortia of academic institutions under the banner of "peer evaluation." In the words of the Council for Higher Education Accreditation (CHEA), "Accrediting organizations derive their legitimacy from the colleges, universities, and programs that created accreditation, not government," and, I might add, are largely funded by these institutions.
There is no doubt in my mind that our nation's accreditors sincerely believe they are serving both higher education's interests and society's, and to the extent they identify the shortcomings of disreputable or failing institutions and encourage others to engage in self-improvement, they are manifestly doing so. But I think it is also fair to say that those agencies have adopted a stance that too often places them in an adversarial posture vis-à-vis their member colleges and universities, inserting their own judgments into decisions of how best to achieve the enormously diverse academic missions of their membership. They are now middlemen, uneasily positioned between an upper and nether millstone. They must justify themselves to their members on the one hand and the federal government on the other. Ironically, in describing the growth of federal oversight of the accreditation agencies themselves, Dr. Judith Eaton of CHEA sounded an alarm with an eerily familiar ring. "Recognition," she noted in a recent podcast, "does not need to be an end in itself; it does not need to be this hugely detailed ongoing review of our accrediting organizations to make sure they're operating effectively. It didn't use to be that way; it has become all consuming, intensely granular. We need to moderate that." To which I say, "Hear! Hear!"
Let me turn now to the question that I laid before you at the outset, namely, how well does our present system of accreditation serve our nation's colleges and universities? The answer is not well enough. I would like to raise three aspects of the current system that I believe need reforming: the clustering of membership in accreditation agencies based on geography rather than sector; the increasingly costly and burdensome requirements placed on institutions irrespective of their record of achievement; and the implications of the current trend toward requiring overly proscriptive quantitative and comparative measures of student learning outcomes.
Let me begin with the problem I see in the way accreditation is organized. To take Middle States as an example, it was founded in the late 19th century by a small number of east coast colleges and universities that took up common cause in defining what a bachelor's degree should signify and exchanging best practices. They shared a unity of purpose and were very similar in educational outlook. Today, in contrast, we have six very large accreditation organizations whose members have little in common save geography. Their membership reflects one of the great strengths of American higher education, which is surely the diversity of its institutions. These institutions vary in size, mission, selectivity, degree of state support, and in many other ways. Some draw their students largely from their local communities or regions, while others are more national or even international in scope. This diversity provides points of entry into higher education for students of very different talents and interests, but it has exposed structural flaws in the current accreditation system. While geography may have been a useful organizing principle for accreditation at a time when travel across the country was time-consuming and expensive, and may even now make sense for institutions that are largely local or regional in nature, there are many institutions for which it does not make sense. By having each of the six regional agencies oversee everything from small local community colleges to large research-intensive universities that draw their students and faculty from throughout the world, the current system creates incentives to adopt standards and review processes that either are so generic as to be meaningless in any specific context or that are so focused on one context that they are meaningless, or even damaging, in others. A "one-size-fits-all" approach to accreditation constrains innovation, creativity, and improvement, even among institutions with a proven record of excellence in teaching and research.
To give you an example of how the current system fails to capture critical aspects of the mission of our sector — research universities — each time I have been involved in accreditation at Princeton, I have been struck by the fact that our research mission is almost entirely invisible in the process. Yet the generation of new knowledge is an integral part of how we measure our success, and we go to considerable lengths to ensure that our research mission cannot be separated from our teaching mission. In our discussions with Middle States, this critical aspect of Princeton rarely, if ever, comes up.
Without implying any hierarchy of social worth, we have managed to mix apples and oranges and bananas while, at the same time, storing them in six different crates. A national, sector-based system of accreditation would, to my mind, be much more serviceable, allowing like institutions — say, research universities or community colleges — to be judged by standards tailored to their missions.
I fully acknowledge that the devil would loom large in the details of any effort to reorganize accreditation at this point. While it is straightforward to distinguish a research university from a community college, many institutions in between share characteristics with both. Furthermore, there are entrenched interests in the current system that would have to be persuaded to cede authority for the sake of the common good. Nevertheless, I was heartened that the NACIQI subcommittee raised this possibly, and I quote from their report: "The regional foundations of some accreditor organizations may be due for reassessment by those entities as the diversity of educational activities and missions have expanded within a region, and as educational activity and mission increasingly span regional and national boundaries." They go on to "encourage a dialogue within the accreditation community about the structure and organization of the accreditation enterprise. The diversity of educational activity and mission today may call for a system of accreditation that is aligned more closely with mission or sector or other educationally relevant variable, than with geography. This dialogue may also afford institutions greater opportunity to choose among accreditors." This is really progress, to my mind.
There is no issue swirling around accreditation that unites institutions more vigorously than the enormous financial and administrative burden it imposes at a time when many colleges and universities are managing flat or declining endowments and state appropriations. In their quest for one-size-fits-all measures of performance and learning, accreditation agencies have come to demand volumes of paperwork and bureaucratic reporting, much of it untied in any constructive way to the educational mission of the institutions they are evaluating, resulting in rapid escalations in the cost of going through an accreditation review. Furthermore, there is no effort to apply anything resembling a cost-benefit approach that would focus the accreditors' attention and limited resources on the institutions that are of greatest concern to the federal government — the diploma mills and fly-by-night for-profit companies that depend upon student loans to attract students, and which then fail to prepare them for productive careers. Instead, colleges and universities of international repute are tasked with assembling the same onerous documentation as the most egregious diploma mill. Let me quote from a letter that John Etchemendy, the provost of Stanford University, sent to WASC last year, highlighting their experience with reaccreditation: " We have been engaged in our reaccreditation project for more than four years and have approximately two more years until we are finished. . . . With three submissions and two visits, it is hard to find peer reviewers willing to be part of the process because of the duration of the review. . . . In one count a few years ago, we determined that the cost of staff time devoted to the accreditation process in that year alone was nearly $849,000. Furthermore, this figure only describes staff and faculty whose effort is partially allocated to the process, and does not account for the time and effort of more than 50 faculty and staff who are working on the accreditation review in less formal roles. Thus the true expense is far greater on an annual basis and the opportunity cost is incalculable."
I am willing to risk being tagged with the label of "elitist" and assert that there is little to be gained from asking an institution with Stanford's financial stability and long record of success in preparing its students for productive lives to go through such a burdensome review process. It simply does not pass the common sense "sniff test." Indeed, Etchemendy ends his letter by pointing out the following: "We have confidence that the majority of colleges and universities are similarly motivated to serve their students to the best of their abilities, and that over time their reputations will be determined by the extent to which they succeed or fail. Higher education in the U.S. is unique in the extent to which it is exposed to market forces and competition. We believe that the role of accreditors should be to identify those few institutions that are not operating with integrity or basic competence, and to let the large majority of institutions focus their resources on serving their students, rather than on a bureaucratic process of questionable value."
Happily, this is an issue that the NACIQI subcommittee also took up, and warmly embraced. They urged accreditation agencies to adopt "reasonable cost-benefit standards, in which regulatory obligations, effort and cost are consistent with the results in terms of important protections and quality control" and recommended that they design an expedited review process for those institutions that had been continuously accredited for many years and/or could meet a rigorous set of threshold standards.
This brings me to what I and many of my colleagues regard as the most troubling feature of accreditation today, and the one that is beginning to dominate accreditation reviews — the growing emphasis on quantifying and comparing student learning outcomes and continually assessing these outcomes in the name of progress and accountability. To question this approach, which, under the rubric of "No Child Left Behind," has taken our nation's public schools by storm and placed them in the thrall of standardized tests, is to invite bewilderment or indignation, for who can be opposed to wanting to know whether and how much students are learning? But this is to conflate the means and ends of education. The end was succinctly summarized by Woodrow Wilson, Princeton's 13th president, more than a century ago when he declared, "What we should seek to impart in our colleges . . . is not so much learning itself as the spirit of learning . . . It consists in the power to distinguish good reasoning from bad, in the power to digest and interpret evidence, in a habit of catholic observation and a preference for the non-partisan point of view, in an addiction to clear and logical processes of thought and yet an instinctive desire to interpret rather than to stick in the letter of the reasoning, in a taste for knowledge, and a deep respect for the integrity of the human mind." This has always been my favorite definition of a liberal education, and it continues to inform our work at Princeton, even as our curriculum — and scholarship writ large — has continued to evolve. Wilson's words are a welcome reminder that the primary task of colleges and universities is not solely to provide our students with a specific body of knowledge or preparation for a single career, but to nurture the open yet critical minds they need to deal effectively with knowledge in all its forms, not only on our campuses but throughout their lives. And the means? Well, the means are infinitely varied and, like the end, cannot be captured in a data set.
In addition to generating and disseminating knowledge through a multiplicity of methods, our faculty administers exams, grades papers and problem sets, and lays out expectations for attendance and participation, creating a corpus of benchmarks that students must attain. And at Princeton we take great pains, much to the annoyance of some of our students, to ensure that grades are an accurate reflection of performance. So no one can reasonably say that our students are left to determine for themselves if they are growing intellectually. Yet these activities are dismissed by proponents of assessment as too subjective and of no utility in measuring learning.
At Princeton we embrace the idea that our faculty are the best judges of whether their students are learning. Close engagement with professors is the hallmark of an undergraduate education at Princeton, as reflected in its bookends. These consist of direct and sustained encounters with accomplished scholars in Freshman Seminars and the in-depth independent work embodied in our senior thesis. Both experiences, so motivational in one case and so integrative in the other, are emblematic of what our provost, Christopher Eisgruber, calls a "culture of learning and engagement." Neither can be quantified and compared, for every seminar and every thesis differs in conception and execution, nor can a freshman's performance in one be weighed against a senior's in the other in a quest to document continuous improvement. These rites of passage are far more challenging and therefore meaningful and, ultimately, much more consequential than the reductionist proofs of student progress demanded by the various standardized tests that are now being championed by a number of foundations and think tanks.
To cite just one example, Middle States presents as one of its "guidelines for institutional improvement" a document, entitled "How to Achieve Deep, Lasting Learning," that takes a completely different tack, suggesting — and I quote — that "while students do pick up some things through faculty and staff modeling, discussions, and the like, they focus their time and energy learning what they'll be graded on . . . and therefore learn those things more effectively." Twenty-five years from now, I am willing to wager Princeton's endowment that it is not the content of an exam that students will remember, but the intellectual engagement with professors who mentored and inspired them. When I ask alumni what was their most important academic experience at Princeton, 9 out of 10 respond that it was writing their senior thesis.
Paradoxically, the "culture of assessment" is inhospitable to a body of evidence of educational effectiveness that does lend itself to statistical expression. In Characteristics of Excellence in Higher Education, Middle States' compendium of standards, the association relegates to the status of "indirect evidence" "retention, graduation, and placement rates and satisfaction surveys of students and alumni." I would argue that these measures of success are entirely legitimate — and arguably the most meaningful — ways of gauging student learning outcomes. They are certainly the ones that parents are seeking as they send their offspring to college. To use an old expression, the proof of the pudding is in the eating, and to the extent that our students are productive citizens, who use their knowledge to enrich their families, communities, and professions, then both they and we have put the resources of higher education to good use. Finally, in focusing on student learning outcomes, I am also concerned that accreditors will undervalue another vital indicator of educational improvement, namely, our own investments in the academic, extracurricular, and residential wellbeing of our students, whether that means hiring outstanding scholars, creating a diverse student body, maintaining a low faculty-student ratio, building state-of-the-art laboratories, or embracing new initiatives, such as our determination to give every undergraduate an opportunity to engage in the creative and performing arts and to travel beyond the borders of our nation. This matters, and if it did not, no university president would subject herself or himself to the ineffable joys of capital campaigns.
A final observation. In the report of the Boyer Commission, issued in 1998, the word "assessment" does not appear once, and yet I cannot think of a more forceful and thoughtful blueprint for reforming undergraduate education in the context of a research university — from making "research-based learning the standard" to culminating "with a capstone experience" to changing "faculty reward systems." And this, I believe, is where educators and accreditors alike should place their energies. To do otherwise — to make it our paramount goal to teach and learn to a common, measurable standard — would be to fundamentally change the nature of American higher education, both at an institutional and curricular level. We have learned over and over again that external benchmarking creates perverse incentives — from teaching to the test to gaming the U.S. News & World Report ratings. There may well be some institutions that decide that it is appropriate to adopt standardized testing to assess their students' progress. That is a choice that may well make perfect sense in some contexts. But it is not the solution for everyone. As the newly issued report by the American Council on Education's National Task Force on Institutional Accreditation, "Assuring Academic Quality in the 21st Century," cautioned, and I quote: "the imposition of common standards, irrespective of institutional goals or without consultation with faculty and staff, fundamentally undermines higher education, whether it comes from government agencies or accreditors."
Unlike many countries, the United States has nurtured a vibrant and vigorous respect for academic freedom. Under such a system, American higher education has flourished. I respect the right of the public and the government to seek assurance that institutions attended by students with the assistance of federal funds are meeting appropriate standards of quality. I believe that, rightly done, accreditation can play a positive role in sustaining and enhancing our nation's colleges and universities, even as it also seeks to ensure that all accredited institutions meet appropriate basic standards. But if recent trends continue, in which the staff of accrediting agencies seek to substitute their own judgments about how an institution can best achieve its mission and measure success, we risk damaging the kind of outstanding institutions represented at this conference. We should be broadening, not narrowing definitions of excellence at a time when the United States is being challenged as never before to compete in the marketplace of ideas. In a word, our motto should be vive la difference!
Thank you for inviting me to share my thoughts with you today. I would now be happy to take your questions.