Planning for Accreditation: Evaluating the Curriculum
Upon completion of Chapter 17, readers will be able to:
1. Analyze the various forms of accreditation and typical accreditation processes that are used to indicate a program meets specific standards and criteria
2. Outline a plan for accreditation, developing a timeline, and providing for involvement of faculty, students, and other stakeholders in the self-study and site visit
3. Apply principles of continuous quality improvement in accreditation activities
4. Evaluate current issues in accreditation within higher education, particularly those related to the increasing role of federal agencies in establishing accreditation standards and policies, the impact of technology, and the development of a global market place in higher education
Accreditation is a process that educational programs and curricula undergo to receive recognition for meeting standards or criteria set by national, regional, or state organizations. Programs undergo accreditation to demonstrate their quality to consumers (students, alumni, and employers) of their products. Because programs such as nursing prepare students for the practice of a profession involving activities that have a direct impact on public health and safety, there are rigorous standards and more numerous types of accreditation reviews that are common for other academic programs. For this reason, it is important for faculty and program directors to have a broad understanding of accreditation and the significant role they play in evaluating the program and curriculum to meet accreditation standards.
Chapter 16 explored the broader areas of educational program evaluation and presents examples of models used in nursing education. Selecting a model for evaluation can assist faculty members in focusing and organizing their work and 370in expressing their particular philosophy of education. Use of a particular model also provides a comprehensive framework to guide the work of faculty and staff in the evaluation process. In Chapter 16, readers were introduced to the benefits of developing a master plan for program and curriculum evaluation. The development of a master plan for evaluation indicates that faculty thoughtfully considered key learning outcomes and the importance of determining the extent to which these outcomes were attained. Optimally, the master plan provides data that can be used for both formative and summative evaluation, with evidence being used for continuous improvement of the program.
Chapter 17 explores the world of accreditation and the external requirements that must be satisfied in order for a nursing program to operate successfully in the context of the state or province in which it exists, within its region, within the larger boundaries of the country, and within the special world of a profession. Trends toward globalization of accreditation are explored.
DEFINITION OF TERMS
1. Institutional accreditation—provides a comprehensive review of the functioning and effectiveness of the entire college, university, or technical institute. The state mandate or institutional mission provides the lens used to guide the review.
2. Programmatic accreditation—focuses on the functioning and effectiveness of a particular program within the larger institution (e.g., nursing, medicine).
3. Specialized accreditation agencies—focus on the functioning or effectiveness of a particular kind of program (e.g., nursing, nurse anesthesia) or review a specialized, single-purpose college or postsecondary school.
4. Regulatory—a form of approval, recognition, or accreditation required by a federal, state, or provincial government agency.
5. Voluntary—a form of accreditation not required by law or regulation. Voluntary accreditation processes are managed by private, voluntary organizations composed of peer member institutions or programs.
6. National accreditation agency—any accreditation agency that accredits colleges, universities, or technical institutes within an entire country. These include agencies that accredit faith-related or career-related institutions.
7. Regional accreditation agency—One of seven private, voluntary accreditation agencies within six defined regions of the United States, formed for the purpose of peer evaluation and setting of standards for higher education.
8. State-regulatory agencies—Agencies with a mandate to recognize or approve colleges, universities, or programs for operation within a state as governed by state statutes.
9. CQI (Continuous quality improvement)—The implementation of a system designed to provide for ongoing evaluation, analysis of findings, and implementation of plans for improvement within an organization.
NATIONAL ACCREDITING BODIES
The United States is distinctive in that historically its accreditation efforts have been managed by private, voluntary organizations formed by peer institutions for 371the purpose of judging quality and setting standards to guide educational practice. Although the federal and state governments play a role, particularly as it relates to eligibility for licensure and state or federal financial aid, the independent accrediting agencies are key figures in quality assurance through accreditation of colleges, universities, and technical schools. In Canada, as is generally true in the international community, institutions are granted the right to operate within their respective province according to statutes established by provincial legislatures and the Ministry of Education (Ontario Ministry of Education, 2010). Since 1987, collegiate nursing programs in Canada that offer the baccalaureate in nursing may also apply for specialized accreditation from the Canadian Association of Schools of Nursing (CASN, 2014a).
Though the structure of accreditation may differ from country to country, universities and nursing education programs are generally required to be accredited or approved by regulatory bodies within the country, state or province in which they operate. Other forms of accreditation, even regional accreditation in the United States, are voluntary, that is, the institution or nursing program may choose to seek accreditation in order to demonstrate that it has a particular commitment to meeting high standards. Some would argue that it is a euphemism to say that regional accreditation and specialized accreditation are voluntary today, since eligibility for student financial aid in the United States is tied to these approvals, but technically, most forms of accreditation, except those that authorize a college or university to operate within a state, remain voluntary in the United States.
Depending on their purposes, accreditation agencies evaluate institutions or specialized units within an institution. Thus colleges or universities have institutional accreditation, and programs, departments, or schools within larger institutions have specialized or programmatic accreditation. Specialized accreditation is common among professional health science programs, as well as among other professions, and there are numerous specialized accrediting agencies. A few specialized accreditation agencies also accredit single-purpose institutions of higher education, such as colleges of chiropractic medicine, acupuncture and oriental medicine, and colleges of nursing, some of which are hospital-based.
Over the years, as the number of students enrolled in postsecondary institutions increased dramatically, and as higher education received increased funding both for direct operations and for student financial aid, accreditation requirements and expectations for accountability increased (Eaton, 2010). As a result, accreditation processes and standards continue to become more demanding and costly to address (Eaton, 2008b).
ROLE OF THE U.S. DEPARTMENT OF EDUCATION
Unlike many other countries, the United States does not have a central ministry of education that controls postsecondary institutions of higher education. States assume a role in the approval and control of colleges and universities within their boundaries and approval processes and regulations vary widely among them. Thus American colleges and universities have operated with a great deal of autonomy and independence as reflected in their diverse missions and organizational structures. 372A distinctive feature of American higher education, and one that may be considered both a strength and a weakness, is the diversity in type and kind of institution operating with considerable variation in quality and reputation.
Although the states have primary jurisdiction over U.S. colleges and universities, the federal government, through the U.S. Department of Education (USDE), has begun to play a larger role in higher education in the past decade. One of the USDE’s primary roles is to ensure that federal student aid funds, administered under the provisions of Title IV of the Higher Education Act of 1965 as amended, are used to provide access for students enrolling in academic programs and courses of high quality (Eaton, 2012b; USDE, 2009). It does this by reviewing and approving both regional and specialized accrediting agencies. USDE’s recognition process for accrediting agencies uses standards that address recruitment and admission practices, fiscal and administrative capacity, facilities, curricula, faculty, student support programs, records of student complaints, and success in student achievement. Only those colleges and universities accredited by a USDE-recognized accrediting agency are eligible to receive federal financial aid for students (Eaton, 2012b). The USDE maintains a list of approved accreditation agencies and maintains a comprehensive website with detailed information on accreditation, as well as a listing of all accredited postsecondary education programs in the United States (USDE, 2014).
Regional and specialized accrediting agencies are periodically reviewed by the USDE and/or a private organization, the Council for Higher Education Accreditation (CHEA). The recognition process for institutional and specialized accrediting agencies is a part of the federal regulatory mandate in the United States (Eaton, 2008a).
Accreditation agencies are not only approved by the USDE and CHEA but their scope of authority is also determined. For example, an accreditation agency may be approved to accredit programs only at the certificate or baccalaureate level, but not at the master’s or doctoral level. Approval may also be extended to include accreditation of programs offered through distance learning modalities. Abuses in federal financial aid have led to increasingly stringent oversight of all forms of accreditation that provide access to federal financial aid.
In the United States, there are six regions within defined geographical areas, which are served by seven regional accreditation agencies (New England Association of Schools and Colleges Commission on Institutions of Higher Education, 2014). A region may have separate and autonomous commissions, which accredit institutions offering degree programs at different levels or for technical institutes. For example, the Senior Commission of the Western Association of Schools and Colleges (WASC) accredits colleges and universities offering baccalaureate and higher degrees within California, Hawaii, Guam, and the Pacific Islands, while the WASC Commission for Community and Junior Colleges accredits institutions offering associate degrees in the same region. Refer to Table 17.1, Regional Accrediting Agencies in the United States, for a complete listing of the regional accrediting agencies and a description of the geographic areas they cover.
In recent years, more colleges established campuses across state lines from the original campus and more programs are offered using technology that makes time and location unimportant. For this reason, among others, the regional accreditation agencies have formed the Council of Regional Accrediting Commissions (C-RAC).
373C-RAC develops policies on accrediting institutions that cross regional accrediting boundaries, and builds consensus on accreditation policies and best practices on issues such as distance learning (New England Association of Schools and Colleges Commission on Institutions of Higher Education, 2014). In recent years, the USDE has become increasingly active in establishing rules and regulations to be followed by accreditation agencies. At regular intervals, the USDE appoints representatives from the various accrediting bodies to a negotiated rule-making team. Negotiated rule-making is the process for developing recommendations for proposed regulations governing accrediting agencies. The proposed regulations, which reflect a consensus of the team members, are then considered by USDE. Topics considered in negotiated rulemaking include the definitions of the credit hour, a high school diploma, satisfactory academic progress, “gainful employment” and matters such as state authorization for online programs, and issues surrounding institutions’ management of federal student aid funds (CHEA, 2013a; Eaton, 2012a; USDE, 2009). USDE regulations resulted in less flexibility for accrediting agencies, including definitive timelines by which institutions must come into compliance with accreditation standards. Colleges and universities are monitored in regard to their financial performance each year and eligibility for financial aid is dependent on evidence of fiscal health. Fears of increasing oversight by the USDE have led to growing concern about the fate of the historical autonomy of higher education in the United States (Eaton, 2012a, 2013).
THE COUNCIL FOR HIGHER EDUCATION ACCREDITATION
The CHEA was formed in 1996 as a private, nonprofit, national organization designed to coordinate accreditation activities in the United States. CHEA accomplishes its purposes by providing formal recognition of regional, national, and specialized higher accreditation bodies. The Council’s focus is on academic quality, whereas the USDE’S concern is on quality and accountability as it relates to student financial aid. Accreditation agencies may be recognized (approved) by both the USDE and CHEA or by only one of these organizations depending on the accreditation agency’s role and focus (Eaton, 2008a). In all, there are 80 recognized institutional and specialized accrediting organizations operating in the United States (Eaton, 2012b). Sixty accrediting agencies are recognized by CHEA (CHEA, 2013b).
PURPOSES OF ACCREDITATION
The primary purpose of accreditation is to ensure that at least minimum standards of quality are met. Most voluntary accreditation agencies state that they aim to achieve higher than minimum standards as determined by peers in the field. Accreditation provides recognition that the program was evaluated by peers who found it to meet the standards established by the profession. A second purpose of accreditation is to provide recognition for funding and student financial aid, which can significantly aid in student recruitment and retention. A third rationale for accreditation is to ensure consistency in quality across academic programs, thus facilitating transfer of academic credit from one institution to another and 374the acknowledgment of the comparability of one degree to another in the same field across institutions. Accreditation can also assist employers who seek graduates who are competent nurses as well as fulfilling the eligibility requirements for applicants seeking advanced certification. Accreditation reflects commitment to standards and continuous improvement through reflection and analysis. Accreditation as well as licensure and certification are the means used to regulate the professions. The goal of nursing licensure and accreditation is to assure the public that nurses are providing safe and competent care (Rounds, 2010).
In the United States, where voluntary accreditation is the norm, accreditation is distinguished by emphasis on both self-regulation and peer evaluation. In this environment, accreditation processes tend to be both formative and summative, seeking continuous improvement rather than being oriented only to compliance. Accreditation standards typically require institutions or programs to develop evaluation plans and to write comprehensive self-studies to ensure that a system is in place to ensure CQI. These activities facilitate assessment and reflection on findings. Peer evaluation is a core value in voluntary accreditation where peers work on setting standards, participate in site visits, and serve on review panels, appeal panels, and commissions.
In recent years, there has been some dissatisfaction with traditional accreditation processes and practices. Concern has been raised about whether quality is really assured by the current process of voluntary accreditation in the United States. In 2013, the U.S. House of Representatives Subcommittee on Higher Education and the Workforce proposed exploring reform of traditional accreditation and encouraging innovation in higher education. One factor that precipitated this proposal is the rapid growth of massive open online courses (MOOCs) and other online offerings from noneducational providers. It seems clear that there is significant support for some kind of alternative accreditation process especially for extra-institutional providers of educational offerings (CHEA, 2013a). MOOCs are largely offered by top universities and companies but, in most cases, without credit. Yet the quality of instruction and the rigor of examination rival that of traditional online classes used in many for-credit degree programs (Thrun, 2013). “These classes might easily be leveraged into degree programs if the providers were accredited” (Thrun, 2013, p. 1). The large impact of technology in higher education, specifically online learning, paved the way for significant educational and accreditation reform. Technology greatly impacted accreditation by challenging the brick and mortar approaches that have been utilized for many decades. Accreditation increasingly is being conducted in a disaggregated world and enhanced dialogue is occurring on how best to assess new delivery models and determine success while achieving programmatic and student outcomes (LeBlanc, 2013).
For-profit postsecondary institutions of higher education and institutions offering degrees through distance learning modalities have proliferated and their students have participated heavily in federal financial aid. Of particular concern to government officials and legislators is the high dropout rate and high student loan default rate among students enrolled in these programs or institutions (Marklein, Upton, & Kambhampati, 2013). In response to these concerns, in 2011, the USDE passed a regulation that requires any educational program receiving federal financial aid to seek authorization from the state or states in which it operates. This rule, it was argued, could make it easier for states to identify and regulate colleges 375operating within their jurisdictions. The rule was contested by colleges and was struck down but it is being appealed by the USDE. The significant amount of attention given to institutions who receive federal financial aid is a result of the billions of dollars the government currently expends on student financial aid and its desire to implement increased quality control.
Increasingly, institutions of higher education are asked to demonstrate to the USDE (through regulations imposed on regional and professional accreditation agencies) that they are tracking trends in key performance indicators such as student graduation rates, graduates’ loan default rates, and postgraduation employment (Morgan, 2012). In addition, accreditation agencies are beginning to require that these data be readily accessible to potential students so that they can make informed choices about the institutions to which they apply. As a result of additional requirements from the USDE, accreditation agencies are posting accreditation decisions and sometimes the summative site team report and commission action letters on their websites. Eaton urges colleges to embrace this “public accountability imperative” to increase the transparency and credibility of accreditation outcomes (Eaton, 2012c).
Data on these trends are requested by regulatory agencies such as boards of nursing as well as by accrediting agencies. In 2010, the National Council of State Boards of Nursing’s (NCSBN) Board of Directors convened a committee to assess this redundancy and to make recommendations to the NCSBN’s board. This resulted in a commitment to a more collaborative engagement with national accreditors recognizing that accreditation, education, and regulation all have the same goal of providing safe and competent nurses to meet the needs of society (Spector & Woods, 2013).
PROS AND CONS OF ACCREDITATION
Faculty will undoubtedly engage in discussions about the pros and cons of accreditation, such discussions being particularly common when in the midst of a self-study or a site visit. In addition to providing eligibility for student financial aid, there are multiple other benefits that accreditation offers to an institution or a program. Accreditation demonstrates to the public the program’s quality and effectiveness. It can assist potential students to identify appropriate programs for their goals, assuring students that they have selected a college, university, or program that meets high standards in its operations. In addition, accreditation typically assures students that their coursework will be acceptable for transfer credit to another institution of higher education. This is important for students who find they want to change colleges or universities (for whatever reason) or who want to go on to graduate school.
The biggest benefit to accreditation is the strong emphasis it places on self-evaluation, re-evaluation, and continuous improvement. As noted by Spector and Woods in a recent article, “national nursing accreditation ensures the quality and integrity of nursing education programs and serves the public interest by assessing and identifying programs that engage in effective educational practices” (Spector & Woods, 2013).
Achieving and maintaining accreditation provides recognition that a program’s graduates are sufficiently prepared and qualified to compete in an ever-challenging environment.
376Critics of accreditation express concern about increasing demands on faculty time required by accreditation activities and the resulting impact on faculty and staff workload as compared to some decades ago when accreditation was in its infancy. It should be remembered, however, that accreditation came about not just because of the public demand for accountability and quality, but because peers felt a responsibility to work collaboratively to establish standards that would guide their practice. Although time intensive, involvement in accreditation provides the opportunity for faculty to become increasingly familiar with the accreditation standards and to review a program in light of these standards.
Perhaps the biggest complaint about accreditation is its cost. Staff and faculty time involved in planning for either institutional or specialized accreditation is significant and costly. Often institutions or programs must postpone major initiatives while they are working on a major accreditation review. This highlights the “opportunity cost” that may be attendant to accreditation. In a time where resources are perceived to be scarce, institutions and programs sometimes feel these resources should be used for more important activities or initiatives. Duplication of effort with overlapping requirements in regional and specialized accreditation is yet another frequent complaint of current accreditation systems (Spector & Woods, 2013). Preparation of faculty for assessment of student learning, educating them about accreditation standards and policies, and involving them in the self-study and site visit present yet more challenges. Some see these as distractions from their primary role in teaching and research. Accreditation is also charged with being inflexible, parochial, failing to take institutional diversity into account, stifling innovation, and being too focused on inputs. Some critics have expressed the viewpoint that accreditation does not ensure quality (Morgan, 2012).
The use of technology in higher education and the overt development of higher education as a market commodity created new issues and criticism surrounding accreditation. As noted earlier in this chapter, technology permits institutions to offer programs outside of their traditional state, provincial, or regional boundaries. More institutions are offering programs through distance learning strategies that provide global access to degree programs. Thus questions arise about which agency has jurisdiction in accreditation of these out-of-region programs. The entry of for-profit colleges and universities into the realm of higher education also brought attention to the vast financial and economic enterprise of higher education. Consider the case of the University of Phoenix (UOP), the largest independent college in the United States. In 2010, UOP enrolled more than 450,000 students, operating campuses in 40 states plus Puerto Rico and Canada (Alberta and British Columbia). A large portion of its students are enrolled in programs that are offered totally online (UOP, 2010). This is just one of the for-profit institutions that has generated concern due to low graduation and high student loan default rates (Marklein et al., 2013).
CONTINUOUS QUALITY IMPROVEMENT
In recent years, concerns about the deficiencies in accreditation and the very episodic nature of accreditation led to consideration of alternative evaluation methods 377for educational programs. Higher education has begun to adopt concepts and processes of CQI from the corporate world in its evaluation systems. Building a culture in which CQI is a core value enables a college or department to create a system of evaluation, which is inclusive, systematic, and reliable (Suhayda, 2006). CQI calls on institutions or programs to identify customers clearly. Customers include students, alumni, clinical agencies, the profession, and consumers. Establishing key requirements for the satisfaction of these stakeholders is an important step in the CQI process. Typically, evaluation strategies in CQI include evaluating satisfaction of students and other customers, as well as establishing whether key requirements have been met (i.e., benchmarks for graduates’ performance and learning outcomes). Cross-functional teams (staff and faculty) work to assess whether systems are optimal to produce best practices and results. A major advantage in the CQI process is that it provides a systematic process for continuous activity in which organizational data are evaluated regularly in order to target results needing improvement. Key performance indicators are established to provide a set of metrics that a program can monitor on a regular basis.
THE GLOBAL ENVIRONMENT
Developments in recent years highlighted the growing competition for the international market of higher education as evidenced by universities offering high demand programs around the world. Increasingly higher education is becoming a “commodity” with value added because of the opportunities presented to those who receive credentials through higher education. Recognizing these developments, a number of regional and specialized accreditation agencies began to accredit institutions or programs offered in various parts of the world. Accreditation often enhances the economic value of the credential received, thus increasing the marketability of an institution’s programs.
A key question being asked today is whether all the money being spent on higher education is really worth the investment. Would this funding be better spent on health care, housing, or other pressing social needs? The accountability question is driving the federal appetite to become more directly involved in accreditation in the United States, particularly as it relates to an institution’s eligibility to handle student financial aid awards. This debate is likely to become even more intense in the United States given reauthorization of the Higher Education Act of 1965 with the passing of the Higher Education Opportunity Act in 2008 (Eaton, 2008b). This legislation included many new provisions regarding student financial aid, along with new regulations for colleges and universities. As a result of the growing importance of student financial aid, regional and specialized accreditation agencies feel a sense of urgency about demonstrating that voluntary accreditation processes are effective. Growing governmental intrusion is also viewed with some alarm (Eaton, 2008b, 2013). Regional accreditation agencies have been responding to this threat with a number of new initiatives that focus on evidence of quality (Higher Learning Commission, 2010).
378ORGANIZATIONAL OVERVIEW OF THE STRUCTURE OF ACCREDITATION
As noted earlier in this chapter, legitimate accrediting agencies in the United States must be recognized by the USDE or CHEA. There are two major types of accreditation bodies, institutional and specialized or programmatic. Institutional accreditation agencies include seven regional associations covering six regions (see Table 17.1). A regional accreditation agency in the United States is a voluntary organization composed of member schools from a defined geographic region of the country. These include the following regional accreditation agencies and the commissions that accredit postsecondary schools and colleges:
• Middle States Association of Colleges and Schools Commission on Higher Education
• New England Association of Schools and Colleges Commission on Institutions of Higher Education Commission on Technical and Career Institutions
• North Central Association of Colleges and Schools Commission on Institutions of Higher Education
• Northwest Association of Schools and Colleges Commission on Colleges
• Southwest Association of Colleges and Schools Commission on Colleges
• Western Association of Schools and Colleges Senior Commission of Colleges and Universities
• Western Association of Schools and Colleges Accrediting Commission for Community and Junior Colleges