Letter to Members of the Committee on Education and the Workforce

Voluntary Peer Review—Accreditation has been successful in ensuring a high level of institutional quality primarily because it has been a collaborative and voluntary effort among professional peers. In promulgating new legislation, it is important to preserve this character of the accreditation process, in order to avoid an "accountability bureaucracy" that will stifle innovation. In a period when public funds for the support of higher education are severely limited, it is both unfair and unwise to impose new and expensive regulatory restrictions-especially utilizing the vehicle of accreditation-on institutions that are already struggling to maintain quality in the face of increasing demand for their services and limited resources. At the same time, it is important to maintain independent non-regulatory accrediting agencies as the linchpin of federal quality assurance efforts.

Disclosure —Although accreditation serves an important public quality assurance function, much of the work of accreditation necessarily takes place out of the public view. In order to preserve the collaborative nature of accreditation, it is important that external reviewers feel free to comment candidly on their findings, and that institutions be able to determine internally how best to improve their academic programs and operations. Most accrediting agencies already disclose basic information on their actions; requiring further public disclosure of the details of findings and remediation actions will damage the entire accreditation process.

Measures of Quality—The imposition of universal standards for educational outcomes would fundamentally change the role of the federal government in higher education. When external agencies mandate that colleges and universities document the quality of their educational "product," the requirements are most often reduced to easily measurable indicators that address only a narrow range of outcomes. We maintain that the individuals best able to determine how to address the diverse educational needs, goals, and demonstrated abilities of students are those who work directly with them-the faculty and other academic professionals.

Transfer of Credit—Today's postsecondary students are more mobile than ever. Thus, transfer of credit between institutions has become a pressing issue. However, the institutions conferring degrees (with faculty playing a primary role) must retain the ability to determine whether credits earned at another institution fulfill the requirements they set out for their degree programs. We therefore urge Congress not to adopt sweeping requirements for acceptance of transfer credits that would constrain institutions in their efforts to preserve standards of academic quality.