10
1 Center for American Progress |  Up to the Job? Up to the Job? National Accreditation and College Outcomes By Ben Miller September 2015  Alber Gray has prob ably had be ter days han June 1 7. As he execuive direcor o he  Accrediing C ouncil or Independ en College s and Schools, or A CICS, Gray heads one o he small nonproagencies ha he U.S . Deparmen o Educaion asks w ih evalu- aing higher educaion insiuions o deermine which colleges are qualied o oer ederal grans and loans o heir sudens. 1  On ha day, Gray had been called beore he Senae Healh, Educa ion, Labor and Pensions Commitee o alk abou ACICS’ role in ensuring qualiy in possecondary educaion. 2  Wha happened during G ray’s esimony was as close o a viral momen as obscure possecondary policies can come. In a video ha’s since been viewed more han 290,000 imes on Face book, Sen. Elizabeh W arren (D-MA) repeaedly challenged he role o Gray and his agency in overseeing Corinhian Colleges, a publicly raded compan y ha closed or good in lae April afer he Deparmen o Educaion orced i o sar w ind- ing down in 2014. 3  Similarly, Sen. Chris Murphy (D-C) old Gray ha his deense o  ACICS’ acions showed ha he was “living on a dieren pla ne han everyone else who reviews he rack record o Corinhian.” 4  Senaors grilling Gray abou his role in overseeing a raudulen mulibillion-dollar operaion encapsula es he odd way ha qualiy assurance works in possecondary edu- caion. Despie he ac ha ACICS is a small nonprowih jus 50 employees and $15 million in revenues, is decisions aec how billions o ederal dollars are spen. 5  A posi- ive accrediaion decision by ACICS grans a college access o all major ederal suden loan and gran program s, which is worh millions o dollars and serves as he lieblood or mos insiuions. aking his approval away can be a deahblow. 6 Bu among he colleges ha ACICS approved or ederal aid are several dozen ha Corinhian Colleges had owned a some poin. 7  Corinhian was buil on a business model o recruiing low-income and minoriy sudens o atend expensive programs o quesionable qualiy ha were largely paid or w ih suden loans. 8  e ederal govern-

Up to the Job?: National Accreditation and College Outcomes

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Citation preview

Page 1: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 19

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 29

2 Center for American Progress | Up to the Job

men is sill rying o clean up he mess he company lef behind by orgiving he loans

o derauded sudens991252a process ha will likely cos axpayers millions i no billions

o dollars in addiion o he $35 billion he company received rom he ederal govern-

men over he pas five years9

Despie years o warning signs ACICS ook minimal acion agains Corinhian

Colleges10 In April 2014991252while he Deparmen o Educaion was acively invesiga-ing he company or is quesionable job placemen raes and jus a ew monhs beore

he deparmen aced o sar Corinhianrsquos closure991252ACICS renewed he accrediaion

o wo Corinhian campuses and auhorized a new branch campus Gray coninued o

deend his agencyrsquos acions even afer he company closed noing a he Senae hearing

ha ACICS ound no evidence o he college lying o is sudens or commiting raud11

Alhough ACICS has received991252and should coninue o receive991252scruiny or is

oversigh o Corinhian a new Cener or American Progress analysis suggess ha

concerns abou he accrediorrsquos role in ensuring college qualiy exend beyond his one

educaional provider According o he analysis one ou o every five borrowers a an ACICS-accredied college deauls on his or her loans wihin hree years o enering

repaymen991252a mark ha is 50 percen higher han he naional average12 Such high

deaul numbers are paricularly roubling because sudens a ACICS-accredied col-

leges ake ou suden loans a higher raes and in greaer amouns han hose a colleges

accredied by oher agencies

While ACICSrsquo perormance is worse han ha o is peers ha provide similar gae-

keeping uncions CAPrsquos analysis suggess ha problems wih ACICS are emblemaic

o larger srucural flaws ha exis in his naional accrediaion space which is mosly

ocused on career educaion is is no an arcane policy mater As he gaekeepers oederal suden aid accrediorsrsquo lax approval sandards can open he door o mass raud

ha undermines confidence in loan programs and he broader possecondary educaion

sysem e role o accrediaion and qualiy assurance is also likely o be a major opic

o discussion in he upcoming reauhorizaion o he Higher Educaion Ac as well as

he 2016 presidenial elecion On one side here are concerns similar o hose Sen

Warren raised a he Senae hearing over accrediorsrsquo abiliy o properly proec consum-

ers On he oher side individuals such as Sen Marco Rubio (R-FL) have called or

rehinking accrediaion o allow or more innovaive possecondary educaion provid-

ers13 Alhough hese concerns come rom differen sides o he argumen hey lead o

he same oucome991252a sense ha he way in which accrediors deermine who eners and

exis ederal suden aid programs needs improvemen

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 39

3 Center for American Progress | Up to the Job

Accreditation and its types

Gaining access o he ederal suden aid programs is a mulisep process or colleges and

universiies In addiion o needing approval rom a sae and he US Deparmen o

Educaion hey also mus be accredied o become accredied an insiuion mus be

approved by 1 o he 37 agencies ha he Deparmen o Educaion recognizes o serve

as gaekeeper o ederal gran and loan program access14 Agencies are supposed o visicampuses and conduc in-deph invesigaions o hings such as eaching and learning

pracices aciliies aculy and a hos o oher issues15 In ha regard hey are expeced

o ake a much closer look a wha acually occurs in a given school wih respec o learn-

ing han any oher par o he higher educaion oversigh srucure

While approval rom any accrediaion agency auhorized o serve as a gaekeeper is

sufficien or a college o offer ederal loans and grans here are several differen ypes

o accrediors e larges are known as regional accrediors ere are seven regional

accrediors in he Unied Saes and each represens a specific geographic area (see

able 2 or ull lis o regional accrediaion agencies) For example colleges in he Mid- Alanic have o be accredied by he Middle Saes Commission on Higher Educaion

o gain regional accrediaion while colleges in he Souh need o be accredied by he

Souhern Associaion o Colleges and Schools In general he vas majoriy o public

colleges have regional accrediaion as do all presigious nonprofi insiuions a

being said regional accrediors also accredi some privae or-profi colleges including

large naional chains such as he Universiy o Phoenix and Srayer Universiy16

Naional accrediaion is he second mos common ype o accrediaion Naional

accrediors are no limied o any given par o he counry bu end o have a more

specific ocus han regional accrediors For example some naional accrediors onlyapprove career colleges while ohers ocus on bible colleges or ar schools e majoriy

o schools wih naional accrediaion are privae or-profi colleges991252ofen hose ha

offer career-ocused programs17

Naional accrediors can fill he gaekeeper role or ederal suden aid in wo main

ways Some such as ACICS are able o perorm his uncion or any college Ohers

such as he Accrediing Bureau o Healh Educaion Schools or ABHES can only

gran a college access o ederal aid i i is a standalone college in heir field18 In oher

words ABHES can approve he Foley Alabama campus o Foris College or ederal

aid because i only ocuses on healh care bu i canno do so or Penn Foser College in

Scotsdale Arizona because i offers oher non-healh care programs as well19

Depending on he siuaion he ype o accrediaion boh does and does no ma-

er From he perspecive o ederal suden aid benefis i is no relevan Princeon

Universiy ges access o he same suie o grans and loans as Jayrsquos echnical Insiue a

Houson barber school From he collegesrsquo perspecive however i does mater20 Many

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 49

4 Center for American Progress | Up to the Job

regionally accredied colleges are relucan o accep credis rom naionally accredied

insiuions his is a leas parly due o concerns abou he qualiy o hose schools21 As

a resul sudens may atemp o ranser rom one college o anoher under he impres-

sion ha heir credis991252like heir loans991252will move reely only o find ha differing

accrediaion saus may mean his is no he case

CAPrsquos analysis looks at results for ACICS and the other four national accreditors that approve

entire colleges as well as the seven regional accreditors Performance data are drawn from

several federal data sources The US Department of Educationrsquos Postsecondary Education

Participants System or PEPS was used to identify the accreditor for higher education insti-

tutions that receive federal student aid dollars22 The analysis only includes an institutionrsquos

primary accreditormdashthe one whose approval is necessary to gain access to federal aid not

the one that only accredits a specific program These data were then matched with student

loan default rates from the Office of Federal Student Aid and with information on comple-

tions and borrowing which colleges reported to the Integrated Postsecondary Education

Data System or IPEDS23

In assigning an accreditor to each college the fact that IPEDS and federal student aid data

use different identifiers for colleges needed to be addressed The result is that one college

listed by the Office of Federal Student Aid may represent multiple branch campuses in

IPEDS Because accreditation data are tied to the Office of Federal Student Aid data this

analysis consolidated the multiple IPEDS campuses into a single figure The unavoidable

result of this data limitation is that if a branch campus has a different accreditation agency

than the main campus it is still treated as having the same accreditation agency

The analysis uses the number of credentials awarded for every 100 full-time-equivalent stu-

dents instead of a traditional graduation rate because the graduation rate does not count

part-time students or those who transfer in or out of the institutionmdashwhich are more likely

occurrences at the less selective colleges approved by national accreditors24 This measure

addresses both of these flaws by counting all credentials that a given college awards in a

single year and dividing it by a count of all students including those who attend part time

In general a good level of degrees awarded per every 100 full-time-equivalent students is

a number close to the percentage that a college is expected to graduate each year due to

completion Consider the following examples A college that grants four-year bachelorrsquos

degrees where everyone goes full time and graduates should have a rate of 25 degreesper every 100 full-time-equivalent students since that would mean that one-quarter of its

student body graduates each year At a two-year program with similar characteristics this

rate would be 50 degrees for every 100 full-time-equivalent students

About CAPrsquos analysis

8202019 Up to the Job National Accreditation and College Outcomes

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5 Center for American Progress | Up to the Job

Results

able 1 shows he differences in deaul raes borrowing raes average loan amouns

and degrees per every 100 ull-ime-equivalen undergraduae sudens beween

regional and naional accrediors As illusraed he deaul rae or naionally accredied

colleges is subsanially higher han he deaul rae or regional accrediors o pu his

number in perspecive i regionally accredied colleges were o deaul a he same raeas naionally accredied colleges more han 293000 addiional sudens would be in

deaul each year han is currenly he case

TABLE 1

Results by type of accreditation agency

Accreditor

type

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per 100

full-time equivalent

undergraduates

(2012ndash13)

Share of

undergraduates who

borrowed federal

student loans

(2012ndash13)

Average amount of

debt a student

borrower takes out

in a single year

(2012ndash13)

Percent of

undergraduate

credentials that are

certificates

(2012ndash13)

Regional 12 23 39 $6856 16

National 20 46 60 $7405 78

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Similarly he colleges approved by naional accrediors are ar more likely o have su-

dens who borrow991252and borrow more is is parly due o he ac ha sudens atend-

ing naionally accredied colleges are generally lower income 62 percen o sudens anaionally accredied insiuions receive Pell Grans versus 38 percen o sudens a

regionally accredied insiuions Bu he borrowing difference should sill be concern-

ing because 78 percen o he credenials awarded per year a naionally accredied col-

leges are cerificaes Many o hese cerificaes do no lead o paricularly high incomes

and provide reurns well below he expeced resuls or bachelorrsquos degrees which make

up 56 percen o he credenials ha regionally accredied colleges award each year25

Borrowing more or lower-reurn programs means ha sudens may have more rouble

paying off heir suden loans

e one measure on which naional accrediaion agencies appear o perorm beter

is compleion is is due o he mosly shorer programs ha naionally accredied

colleges offer

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 69

6 Center for American Progress | Up to the Job

TABLE 2

Results by accreditation agency

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per

100 full-time

equivalent

undergraduates

(2012ndash13)

Share of

undergraduates

who borrow

federal student loans

(2012ndash13)

Average amount

of debt a student

borrower takes

out in a single year

(2012ndash13)

Percent of

undergraduate

credentials that

are certificates

(2012ndash13)

National accreditation agencies

Accrediting Council for

Continuing Education

and Training

21 76 64 $6214 99

Accrediting Commissionof Career Schools and

Colleges

19 45 65 $7338 80

Accrediting Council

for Independent Colleges

and Schools

21 37 73 $7960 51

Council on Occupational

Education20 65 28 $6528 98

National Accrediting

Commission of Career

Arts and Sciences

17 52 58 $6824 100

Regional accreditation agencies

Middle States

Commission on Higher

Education (Mid-Atlantic)

9 22 43 $6743 3

Higher Learning

Commission of the

North Central Association

of Colleges and Schools

(Midwest)

14 24 46 $6921 13

New England Association

of Schools and Colleges7 22 47 $6827 4

Northwest Commission

on Colleges and

Universities

11 24 37 $6794 14

Southern Association

of Colleges and Schools 13 24 39 $6842 16

Western Association

of Schools and Colleges10 22 20 $6875 15

Accrediting Commission

for Community and Junior

Colleges (West)

21 19 4 $6138 40

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Breaking down he resuls by accrediaion agency reveals ha regional accrediors show

subsanial variaion in resuls which may be due o geographic differences such as New

Englandrsquos larger relaive share o privae nonprofi colleges wih high graduaion raes

compared o oher pars o he counry or he Wesrsquos larger communiy college sysems By

conras he naional accrediaion agencies all cluser around similar perormance levels

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 79

7 Center for American Progress | Up to the Job

able 2 shows jus how differen some o ACICSrsquo resuls are when compared wih oher

accrediaion agencies ACICS shows he highes rae o borrowing o any accredia-

ion agency considered 73 percen I is 8 percenage poins higher han Accrediing

Commission o Career Schools and Colleges or ACCSC he second larges naional

accredior I also has higher average deb and lower compleion figures han any

oher naional accredior Only one regional accrediaion agency991252he Accrediing

Commission or Communiy and Junior Colleges or ACCJC991252approaches ACICSrsquodeaul rae Bu only 4 percen o sudens a colleges accredied by ACCJC borrow

And ha agency has also been challenged or he qualiy o is work 26

Undersanding he scale involved also helps pu some o he ACICS resuls in conex

According o CAP analysis in 2011 approximaely 346000 sudens a ACICS col-

leges enered repaymen991252more borrowers han came rom our o he seven regional

accrediors individually O hose borrowers more han 73000 ulimaely deauled

is number is nearly one-hird higher han he number o deaulers or he Middle

Saes Commission on Higher Educaion which had slighly more han 54000 deaul-

ers despie having 234000 more borrowers han ACICS

Anoher way o inerpre he ACICS resuls is ha his accredior appears o be a srange

hybrid o naional and regional models e colleges ha i approves offer ar more

degrees han is naional peers which are ocused on cerificaes is makes i more like

a regional accredior and parly explains is lower number o degrees per every 100 ull-

ime-equivalen sudens A he same ime he ac ha is colleges offer higher-level

degrees does no appear o resul in lower deaul raes

As one o he larges naional accrediors ACICS is responsible or giving hundreds

o campuses access o billions o dollars in ederal suden aid In his role i has acili-aed he growh o several companies wih problemaic hisories including Corinhian

Colleges and he currenly embatled IT echnical Insiue27

In a ollow-up response o his esimony ACICS Execuive Direcor Gray noed ha

ldquohe primary role o ACICS is o assure qualiy and promoe excellencerdquo I looks like

he agency and is naional accrediaion peers have more work o do o make ha role

a realiy28

Conclusion

Accrediaion signals o sudens ha hey can expec a cerain level o qualiy in heir

higher educaion Is link o ederal aid also implies he US Deparmen o Educaionrsquos

imprimaur991252afer all why would a governmen agency le sudens borrow a a low-

qualiy college Bu i qualiy is no acually invesigaed and verified accrediors risk

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 89

8 Center for American Progress | Up to the Job

puting hundreds o housands o sudens in exremely precarious siuaions ha allow

hem o ake on ederal deb which has no saue o limiaions on collecions and is

almos impossible o discharge in bankrupcy

CAPrsquos analysis srongly suggess ha he curren accrediaion sysem does an insu-

ficien job o dealing wih qualiy991252a leas wih respec o he inersecion beween

suden deb and borrowersrsquo abiliy o pay i back when hey ener he workorce Fixinghis issue will require addressing several quesions such as which oucomes should

be considered when deermining qualiy who should conduc qualiy invesigaions

and wha kind o minimum sandards need o be in place o ensure qualiy ese are

all major issues ha mus be decided in order o ensure ha he possecondary sysem

acually provides sudens he resuls i promises

Ben Miller is the Senior Director for Postsecondary Education at the Center for

American Progress

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray

Page 2: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 29

2 Center for American Progress | Up to the Job

men is sill rying o clean up he mess he company lef behind by orgiving he loans

o derauded sudens991252a process ha will likely cos axpayers millions i no billions

o dollars in addiion o he $35 billion he company received rom he ederal govern-

men over he pas five years9

Despie years o warning signs ACICS ook minimal acion agains Corinhian

Colleges10 In April 2014991252while he Deparmen o Educaion was acively invesiga-ing he company or is quesionable job placemen raes and jus a ew monhs beore

he deparmen aced o sar Corinhianrsquos closure991252ACICS renewed he accrediaion

o wo Corinhian campuses and auhorized a new branch campus Gray coninued o

deend his agencyrsquos acions even afer he company closed noing a he Senae hearing

ha ACICS ound no evidence o he college lying o is sudens or commiting raud11

Alhough ACICS has received991252and should coninue o receive991252scruiny or is

oversigh o Corinhian a new Cener or American Progress analysis suggess ha

concerns abou he accrediorrsquos role in ensuring college qualiy exend beyond his one

educaional provider According o he analysis one ou o every five borrowers a an ACICS-accredied college deauls on his or her loans wihin hree years o enering

repaymen991252a mark ha is 50 percen higher han he naional average12 Such high

deaul numbers are paricularly roubling because sudens a ACICS-accredied col-

leges ake ou suden loans a higher raes and in greaer amouns han hose a colleges

accredied by oher agencies

While ACICSrsquo perormance is worse han ha o is peers ha provide similar gae-

keeping uncions CAPrsquos analysis suggess ha problems wih ACICS are emblemaic

o larger srucural flaws ha exis in his naional accrediaion space which is mosly

ocused on career educaion is is no an arcane policy mater As he gaekeepers oederal suden aid accrediorsrsquo lax approval sandards can open he door o mass raud

ha undermines confidence in loan programs and he broader possecondary educaion

sysem e role o accrediaion and qualiy assurance is also likely o be a major opic

o discussion in he upcoming reauhorizaion o he Higher Educaion Ac as well as

he 2016 presidenial elecion On one side here are concerns similar o hose Sen

Warren raised a he Senae hearing over accrediorsrsquo abiliy o properly proec consum-

ers On he oher side individuals such as Sen Marco Rubio (R-FL) have called or

rehinking accrediaion o allow or more innovaive possecondary educaion provid-

ers13 Alhough hese concerns come rom differen sides o he argumen hey lead o

he same oucome991252a sense ha he way in which accrediors deermine who eners and

exis ederal suden aid programs needs improvemen

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 39

3 Center for American Progress | Up to the Job

Accreditation and its types

Gaining access o he ederal suden aid programs is a mulisep process or colleges and

universiies In addiion o needing approval rom a sae and he US Deparmen o

Educaion hey also mus be accredied o become accredied an insiuion mus be

approved by 1 o he 37 agencies ha he Deparmen o Educaion recognizes o serve

as gaekeeper o ederal gran and loan program access14 Agencies are supposed o visicampuses and conduc in-deph invesigaions o hings such as eaching and learning

pracices aciliies aculy and a hos o oher issues15 In ha regard hey are expeced

o ake a much closer look a wha acually occurs in a given school wih respec o learn-

ing han any oher par o he higher educaion oversigh srucure

While approval rom any accrediaion agency auhorized o serve as a gaekeeper is

sufficien or a college o offer ederal loans and grans here are several differen ypes

o accrediors e larges are known as regional accrediors ere are seven regional

accrediors in he Unied Saes and each represens a specific geographic area (see

able 2 or ull lis o regional accrediaion agencies) For example colleges in he Mid- Alanic have o be accredied by he Middle Saes Commission on Higher Educaion

o gain regional accrediaion while colleges in he Souh need o be accredied by he

Souhern Associaion o Colleges and Schools In general he vas majoriy o public

colleges have regional accrediaion as do all presigious nonprofi insiuions a

being said regional accrediors also accredi some privae or-profi colleges including

large naional chains such as he Universiy o Phoenix and Srayer Universiy16

Naional accrediaion is he second mos common ype o accrediaion Naional

accrediors are no limied o any given par o he counry bu end o have a more

specific ocus han regional accrediors For example some naional accrediors onlyapprove career colleges while ohers ocus on bible colleges or ar schools e majoriy

o schools wih naional accrediaion are privae or-profi colleges991252ofen hose ha

offer career-ocused programs17

Naional accrediors can fill he gaekeeper role or ederal suden aid in wo main

ways Some such as ACICS are able o perorm his uncion or any college Ohers

such as he Accrediing Bureau o Healh Educaion Schools or ABHES can only

gran a college access o ederal aid i i is a standalone college in heir field18 In oher

words ABHES can approve he Foley Alabama campus o Foris College or ederal

aid because i only ocuses on healh care bu i canno do so or Penn Foser College in

Scotsdale Arizona because i offers oher non-healh care programs as well19

Depending on he siuaion he ype o accrediaion boh does and does no ma-

er From he perspecive o ederal suden aid benefis i is no relevan Princeon

Universiy ges access o he same suie o grans and loans as Jayrsquos echnical Insiue a

Houson barber school From he collegesrsquo perspecive however i does mater20 Many

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 49

4 Center for American Progress | Up to the Job

regionally accredied colleges are relucan o accep credis rom naionally accredied

insiuions his is a leas parly due o concerns abou he qualiy o hose schools21 As

a resul sudens may atemp o ranser rom one college o anoher under he impres-

sion ha heir credis991252like heir loans991252will move reely only o find ha differing

accrediaion saus may mean his is no he case

CAPrsquos analysis looks at results for ACICS and the other four national accreditors that approve

entire colleges as well as the seven regional accreditors Performance data are drawn from

several federal data sources The US Department of Educationrsquos Postsecondary Education

Participants System or PEPS was used to identify the accreditor for higher education insti-

tutions that receive federal student aid dollars22 The analysis only includes an institutionrsquos

primary accreditormdashthe one whose approval is necessary to gain access to federal aid not

the one that only accredits a specific program These data were then matched with student

loan default rates from the Office of Federal Student Aid and with information on comple-

tions and borrowing which colleges reported to the Integrated Postsecondary Education

Data System or IPEDS23

In assigning an accreditor to each college the fact that IPEDS and federal student aid data

use different identifiers for colleges needed to be addressed The result is that one college

listed by the Office of Federal Student Aid may represent multiple branch campuses in

IPEDS Because accreditation data are tied to the Office of Federal Student Aid data this

analysis consolidated the multiple IPEDS campuses into a single figure The unavoidable

result of this data limitation is that if a branch campus has a different accreditation agency

than the main campus it is still treated as having the same accreditation agency

The analysis uses the number of credentials awarded for every 100 full-time-equivalent stu-

dents instead of a traditional graduation rate because the graduation rate does not count

part-time students or those who transfer in or out of the institutionmdashwhich are more likely

occurrences at the less selective colleges approved by national accreditors24 This measure

addresses both of these flaws by counting all credentials that a given college awards in a

single year and dividing it by a count of all students including those who attend part time

In general a good level of degrees awarded per every 100 full-time-equivalent students is

a number close to the percentage that a college is expected to graduate each year due to

completion Consider the following examples A college that grants four-year bachelorrsquos

degrees where everyone goes full time and graduates should have a rate of 25 degreesper every 100 full-time-equivalent students since that would mean that one-quarter of its

student body graduates each year At a two-year program with similar characteristics this

rate would be 50 degrees for every 100 full-time-equivalent students

About CAPrsquos analysis

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 59

5 Center for American Progress | Up to the Job

Results

able 1 shows he differences in deaul raes borrowing raes average loan amouns

and degrees per every 100 ull-ime-equivalen undergraduae sudens beween

regional and naional accrediors As illusraed he deaul rae or naionally accredied

colleges is subsanially higher han he deaul rae or regional accrediors o pu his

number in perspecive i regionally accredied colleges were o deaul a he same raeas naionally accredied colleges more han 293000 addiional sudens would be in

deaul each year han is currenly he case

TABLE 1

Results by type of accreditation agency

Accreditor

type

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per 100

full-time equivalent

undergraduates

(2012ndash13)

Share of

undergraduates who

borrowed federal

student loans

(2012ndash13)

Average amount of

debt a student

borrower takes out

in a single year

(2012ndash13)

Percent of

undergraduate

credentials that are

certificates

(2012ndash13)

Regional 12 23 39 $6856 16

National 20 46 60 $7405 78

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Similarly he colleges approved by naional accrediors are ar more likely o have su-

dens who borrow991252and borrow more is is parly due o he ac ha sudens atend-

ing naionally accredied colleges are generally lower income 62 percen o sudens anaionally accredied insiuions receive Pell Grans versus 38 percen o sudens a

regionally accredied insiuions Bu he borrowing difference should sill be concern-

ing because 78 percen o he credenials awarded per year a naionally accredied col-

leges are cerificaes Many o hese cerificaes do no lead o paricularly high incomes

and provide reurns well below he expeced resuls or bachelorrsquos degrees which make

up 56 percen o he credenials ha regionally accredied colleges award each year25

Borrowing more or lower-reurn programs means ha sudens may have more rouble

paying off heir suden loans

e one measure on which naional accrediaion agencies appear o perorm beter

is compleion is is due o he mosly shorer programs ha naionally accredied

colleges offer

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 69

6 Center for American Progress | Up to the Job

TABLE 2

Results by accreditation agency

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per

100 full-time

equivalent

undergraduates

(2012ndash13)

Share of

undergraduates

who borrow

federal student loans

(2012ndash13)

Average amount

of debt a student

borrower takes

out in a single year

(2012ndash13)

Percent of

undergraduate

credentials that

are certificates

(2012ndash13)

National accreditation agencies

Accrediting Council for

Continuing Education

and Training

21 76 64 $6214 99

Accrediting Commissionof Career Schools and

Colleges

19 45 65 $7338 80

Accrediting Council

for Independent Colleges

and Schools

21 37 73 $7960 51

Council on Occupational

Education20 65 28 $6528 98

National Accrediting

Commission of Career

Arts and Sciences

17 52 58 $6824 100

Regional accreditation agencies

Middle States

Commission on Higher

Education (Mid-Atlantic)

9 22 43 $6743 3

Higher Learning

Commission of the

North Central Association

of Colleges and Schools

(Midwest)

14 24 46 $6921 13

New England Association

of Schools and Colleges7 22 47 $6827 4

Northwest Commission

on Colleges and

Universities

11 24 37 $6794 14

Southern Association

of Colleges and Schools 13 24 39 $6842 16

Western Association

of Schools and Colleges10 22 20 $6875 15

Accrediting Commission

for Community and Junior

Colleges (West)

21 19 4 $6138 40

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Breaking down he resuls by accrediaion agency reveals ha regional accrediors show

subsanial variaion in resuls which may be due o geographic differences such as New

Englandrsquos larger relaive share o privae nonprofi colleges wih high graduaion raes

compared o oher pars o he counry or he Wesrsquos larger communiy college sysems By

conras he naional accrediaion agencies all cluser around similar perormance levels

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 79

7 Center for American Progress | Up to the Job

able 2 shows jus how differen some o ACICSrsquo resuls are when compared wih oher

accrediaion agencies ACICS shows he highes rae o borrowing o any accredia-

ion agency considered 73 percen I is 8 percenage poins higher han Accrediing

Commission o Career Schools and Colleges or ACCSC he second larges naional

accredior I also has higher average deb and lower compleion figures han any

oher naional accredior Only one regional accrediaion agency991252he Accrediing

Commission or Communiy and Junior Colleges or ACCJC991252approaches ACICSrsquodeaul rae Bu only 4 percen o sudens a colleges accredied by ACCJC borrow

And ha agency has also been challenged or he qualiy o is work 26

Undersanding he scale involved also helps pu some o he ACICS resuls in conex

According o CAP analysis in 2011 approximaely 346000 sudens a ACICS col-

leges enered repaymen991252more borrowers han came rom our o he seven regional

accrediors individually O hose borrowers more han 73000 ulimaely deauled

is number is nearly one-hird higher han he number o deaulers or he Middle

Saes Commission on Higher Educaion which had slighly more han 54000 deaul-

ers despie having 234000 more borrowers han ACICS

Anoher way o inerpre he ACICS resuls is ha his accredior appears o be a srange

hybrid o naional and regional models e colleges ha i approves offer ar more

degrees han is naional peers which are ocused on cerificaes is makes i more like

a regional accredior and parly explains is lower number o degrees per every 100 ull-

ime-equivalen sudens A he same ime he ac ha is colleges offer higher-level

degrees does no appear o resul in lower deaul raes

As one o he larges naional accrediors ACICS is responsible or giving hundreds

o campuses access o billions o dollars in ederal suden aid In his role i has acili-aed he growh o several companies wih problemaic hisories including Corinhian

Colleges and he currenly embatled IT echnical Insiue27

In a ollow-up response o his esimony ACICS Execuive Direcor Gray noed ha

ldquohe primary role o ACICS is o assure qualiy and promoe excellencerdquo I looks like

he agency and is naional accrediaion peers have more work o do o make ha role

a realiy28

Conclusion

Accrediaion signals o sudens ha hey can expec a cerain level o qualiy in heir

higher educaion Is link o ederal aid also implies he US Deparmen o Educaionrsquos

imprimaur991252afer all why would a governmen agency le sudens borrow a a low-

qualiy college Bu i qualiy is no acually invesigaed and verified accrediors risk

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 89

8 Center for American Progress | Up to the Job

puting hundreds o housands o sudens in exremely precarious siuaions ha allow

hem o ake on ederal deb which has no saue o limiaions on collecions and is

almos impossible o discharge in bankrupcy

CAPrsquos analysis srongly suggess ha he curren accrediaion sysem does an insu-

ficien job o dealing wih qualiy991252a leas wih respec o he inersecion beween

suden deb and borrowersrsquo abiliy o pay i back when hey ener he workorce Fixinghis issue will require addressing several quesions such as which oucomes should

be considered when deermining qualiy who should conduc qualiy invesigaions

and wha kind o minimum sandards need o be in place o ensure qualiy ese are

all major issues ha mus be decided in order o ensure ha he possecondary sysem

acually provides sudens he resuls i promises

Ben Miller is the Senior Director for Postsecondary Education at the Center for

American Progress

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray

Page 3: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 39

3 Center for American Progress | Up to the Job

Accreditation and its types

Gaining access o he ederal suden aid programs is a mulisep process or colleges and

universiies In addiion o needing approval rom a sae and he US Deparmen o

Educaion hey also mus be accredied o become accredied an insiuion mus be

approved by 1 o he 37 agencies ha he Deparmen o Educaion recognizes o serve

as gaekeeper o ederal gran and loan program access14 Agencies are supposed o visicampuses and conduc in-deph invesigaions o hings such as eaching and learning

pracices aciliies aculy and a hos o oher issues15 In ha regard hey are expeced

o ake a much closer look a wha acually occurs in a given school wih respec o learn-

ing han any oher par o he higher educaion oversigh srucure

While approval rom any accrediaion agency auhorized o serve as a gaekeeper is

sufficien or a college o offer ederal loans and grans here are several differen ypes

o accrediors e larges are known as regional accrediors ere are seven regional

accrediors in he Unied Saes and each represens a specific geographic area (see

able 2 or ull lis o regional accrediaion agencies) For example colleges in he Mid- Alanic have o be accredied by he Middle Saes Commission on Higher Educaion

o gain regional accrediaion while colleges in he Souh need o be accredied by he

Souhern Associaion o Colleges and Schools In general he vas majoriy o public

colleges have regional accrediaion as do all presigious nonprofi insiuions a

being said regional accrediors also accredi some privae or-profi colleges including

large naional chains such as he Universiy o Phoenix and Srayer Universiy16

Naional accrediaion is he second mos common ype o accrediaion Naional

accrediors are no limied o any given par o he counry bu end o have a more

specific ocus han regional accrediors For example some naional accrediors onlyapprove career colleges while ohers ocus on bible colleges or ar schools e majoriy

o schools wih naional accrediaion are privae or-profi colleges991252ofen hose ha

offer career-ocused programs17

Naional accrediors can fill he gaekeeper role or ederal suden aid in wo main

ways Some such as ACICS are able o perorm his uncion or any college Ohers

such as he Accrediing Bureau o Healh Educaion Schools or ABHES can only

gran a college access o ederal aid i i is a standalone college in heir field18 In oher

words ABHES can approve he Foley Alabama campus o Foris College or ederal

aid because i only ocuses on healh care bu i canno do so or Penn Foser College in

Scotsdale Arizona because i offers oher non-healh care programs as well19

Depending on he siuaion he ype o accrediaion boh does and does no ma-

er From he perspecive o ederal suden aid benefis i is no relevan Princeon

Universiy ges access o he same suie o grans and loans as Jayrsquos echnical Insiue a

Houson barber school From he collegesrsquo perspecive however i does mater20 Many

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 49

4 Center for American Progress | Up to the Job

regionally accredied colleges are relucan o accep credis rom naionally accredied

insiuions his is a leas parly due o concerns abou he qualiy o hose schools21 As

a resul sudens may atemp o ranser rom one college o anoher under he impres-

sion ha heir credis991252like heir loans991252will move reely only o find ha differing

accrediaion saus may mean his is no he case

CAPrsquos analysis looks at results for ACICS and the other four national accreditors that approve

entire colleges as well as the seven regional accreditors Performance data are drawn from

several federal data sources The US Department of Educationrsquos Postsecondary Education

Participants System or PEPS was used to identify the accreditor for higher education insti-

tutions that receive federal student aid dollars22 The analysis only includes an institutionrsquos

primary accreditormdashthe one whose approval is necessary to gain access to federal aid not

the one that only accredits a specific program These data were then matched with student

loan default rates from the Office of Federal Student Aid and with information on comple-

tions and borrowing which colleges reported to the Integrated Postsecondary Education

Data System or IPEDS23

In assigning an accreditor to each college the fact that IPEDS and federal student aid data

use different identifiers for colleges needed to be addressed The result is that one college

listed by the Office of Federal Student Aid may represent multiple branch campuses in

IPEDS Because accreditation data are tied to the Office of Federal Student Aid data this

analysis consolidated the multiple IPEDS campuses into a single figure The unavoidable

result of this data limitation is that if a branch campus has a different accreditation agency

than the main campus it is still treated as having the same accreditation agency

The analysis uses the number of credentials awarded for every 100 full-time-equivalent stu-

dents instead of a traditional graduation rate because the graduation rate does not count

part-time students or those who transfer in or out of the institutionmdashwhich are more likely

occurrences at the less selective colleges approved by national accreditors24 This measure

addresses both of these flaws by counting all credentials that a given college awards in a

single year and dividing it by a count of all students including those who attend part time

In general a good level of degrees awarded per every 100 full-time-equivalent students is

a number close to the percentage that a college is expected to graduate each year due to

completion Consider the following examples A college that grants four-year bachelorrsquos

degrees where everyone goes full time and graduates should have a rate of 25 degreesper every 100 full-time-equivalent students since that would mean that one-quarter of its

student body graduates each year At a two-year program with similar characteristics this

rate would be 50 degrees for every 100 full-time-equivalent students

About CAPrsquos analysis

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 59

5 Center for American Progress | Up to the Job

Results

able 1 shows he differences in deaul raes borrowing raes average loan amouns

and degrees per every 100 ull-ime-equivalen undergraduae sudens beween

regional and naional accrediors As illusraed he deaul rae or naionally accredied

colleges is subsanially higher han he deaul rae or regional accrediors o pu his

number in perspecive i regionally accredied colleges were o deaul a he same raeas naionally accredied colleges more han 293000 addiional sudens would be in

deaul each year han is currenly he case

TABLE 1

Results by type of accreditation agency

Accreditor

type

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per 100

full-time equivalent

undergraduates

(2012ndash13)

Share of

undergraduates who

borrowed federal

student loans

(2012ndash13)

Average amount of

debt a student

borrower takes out

in a single year

(2012ndash13)

Percent of

undergraduate

credentials that are

certificates

(2012ndash13)

Regional 12 23 39 $6856 16

National 20 46 60 $7405 78

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Similarly he colleges approved by naional accrediors are ar more likely o have su-

dens who borrow991252and borrow more is is parly due o he ac ha sudens atend-

ing naionally accredied colleges are generally lower income 62 percen o sudens anaionally accredied insiuions receive Pell Grans versus 38 percen o sudens a

regionally accredied insiuions Bu he borrowing difference should sill be concern-

ing because 78 percen o he credenials awarded per year a naionally accredied col-

leges are cerificaes Many o hese cerificaes do no lead o paricularly high incomes

and provide reurns well below he expeced resuls or bachelorrsquos degrees which make

up 56 percen o he credenials ha regionally accredied colleges award each year25

Borrowing more or lower-reurn programs means ha sudens may have more rouble

paying off heir suden loans

e one measure on which naional accrediaion agencies appear o perorm beter

is compleion is is due o he mosly shorer programs ha naionally accredied

colleges offer

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 69

6 Center for American Progress | Up to the Job

TABLE 2

Results by accreditation agency

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per

100 full-time

equivalent

undergraduates

(2012ndash13)

Share of

undergraduates

who borrow

federal student loans

(2012ndash13)

Average amount

of debt a student

borrower takes

out in a single year

(2012ndash13)

Percent of

undergraduate

credentials that

are certificates

(2012ndash13)

National accreditation agencies

Accrediting Council for

Continuing Education

and Training

21 76 64 $6214 99

Accrediting Commissionof Career Schools and

Colleges

19 45 65 $7338 80

Accrediting Council

for Independent Colleges

and Schools

21 37 73 $7960 51

Council on Occupational

Education20 65 28 $6528 98

National Accrediting

Commission of Career

Arts and Sciences

17 52 58 $6824 100

Regional accreditation agencies

Middle States

Commission on Higher

Education (Mid-Atlantic)

9 22 43 $6743 3

Higher Learning

Commission of the

North Central Association

of Colleges and Schools

(Midwest)

14 24 46 $6921 13

New England Association

of Schools and Colleges7 22 47 $6827 4

Northwest Commission

on Colleges and

Universities

11 24 37 $6794 14

Southern Association

of Colleges and Schools 13 24 39 $6842 16

Western Association

of Schools and Colleges10 22 20 $6875 15

Accrediting Commission

for Community and Junior

Colleges (West)

21 19 4 $6138 40

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Breaking down he resuls by accrediaion agency reveals ha regional accrediors show

subsanial variaion in resuls which may be due o geographic differences such as New

Englandrsquos larger relaive share o privae nonprofi colleges wih high graduaion raes

compared o oher pars o he counry or he Wesrsquos larger communiy college sysems By

conras he naional accrediaion agencies all cluser around similar perormance levels

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 79

7 Center for American Progress | Up to the Job

able 2 shows jus how differen some o ACICSrsquo resuls are when compared wih oher

accrediaion agencies ACICS shows he highes rae o borrowing o any accredia-

ion agency considered 73 percen I is 8 percenage poins higher han Accrediing

Commission o Career Schools and Colleges or ACCSC he second larges naional

accredior I also has higher average deb and lower compleion figures han any

oher naional accredior Only one regional accrediaion agency991252he Accrediing

Commission or Communiy and Junior Colleges or ACCJC991252approaches ACICSrsquodeaul rae Bu only 4 percen o sudens a colleges accredied by ACCJC borrow

And ha agency has also been challenged or he qualiy o is work 26

Undersanding he scale involved also helps pu some o he ACICS resuls in conex

According o CAP analysis in 2011 approximaely 346000 sudens a ACICS col-

leges enered repaymen991252more borrowers han came rom our o he seven regional

accrediors individually O hose borrowers more han 73000 ulimaely deauled

is number is nearly one-hird higher han he number o deaulers or he Middle

Saes Commission on Higher Educaion which had slighly more han 54000 deaul-

ers despie having 234000 more borrowers han ACICS

Anoher way o inerpre he ACICS resuls is ha his accredior appears o be a srange

hybrid o naional and regional models e colleges ha i approves offer ar more

degrees han is naional peers which are ocused on cerificaes is makes i more like

a regional accredior and parly explains is lower number o degrees per every 100 ull-

ime-equivalen sudens A he same ime he ac ha is colleges offer higher-level

degrees does no appear o resul in lower deaul raes

As one o he larges naional accrediors ACICS is responsible or giving hundreds

o campuses access o billions o dollars in ederal suden aid In his role i has acili-aed he growh o several companies wih problemaic hisories including Corinhian

Colleges and he currenly embatled IT echnical Insiue27

In a ollow-up response o his esimony ACICS Execuive Direcor Gray noed ha

ldquohe primary role o ACICS is o assure qualiy and promoe excellencerdquo I looks like

he agency and is naional accrediaion peers have more work o do o make ha role

a realiy28

Conclusion

Accrediaion signals o sudens ha hey can expec a cerain level o qualiy in heir

higher educaion Is link o ederal aid also implies he US Deparmen o Educaionrsquos

imprimaur991252afer all why would a governmen agency le sudens borrow a a low-

qualiy college Bu i qualiy is no acually invesigaed and verified accrediors risk

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 89

8 Center for American Progress | Up to the Job

puting hundreds o housands o sudens in exremely precarious siuaions ha allow

hem o ake on ederal deb which has no saue o limiaions on collecions and is

almos impossible o discharge in bankrupcy

CAPrsquos analysis srongly suggess ha he curren accrediaion sysem does an insu-

ficien job o dealing wih qualiy991252a leas wih respec o he inersecion beween

suden deb and borrowersrsquo abiliy o pay i back when hey ener he workorce Fixinghis issue will require addressing several quesions such as which oucomes should

be considered when deermining qualiy who should conduc qualiy invesigaions

and wha kind o minimum sandards need o be in place o ensure qualiy ese are

all major issues ha mus be decided in order o ensure ha he possecondary sysem

acually provides sudens he resuls i promises

Ben Miller is the Senior Director for Postsecondary Education at the Center for

American Progress

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray

Page 4: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 49

4 Center for American Progress | Up to the Job

regionally accredied colleges are relucan o accep credis rom naionally accredied

insiuions his is a leas parly due o concerns abou he qualiy o hose schools21 As

a resul sudens may atemp o ranser rom one college o anoher under he impres-

sion ha heir credis991252like heir loans991252will move reely only o find ha differing

accrediaion saus may mean his is no he case

CAPrsquos analysis looks at results for ACICS and the other four national accreditors that approve

entire colleges as well as the seven regional accreditors Performance data are drawn from

several federal data sources The US Department of Educationrsquos Postsecondary Education

Participants System or PEPS was used to identify the accreditor for higher education insti-

tutions that receive federal student aid dollars22 The analysis only includes an institutionrsquos

primary accreditormdashthe one whose approval is necessary to gain access to federal aid not

the one that only accredits a specific program These data were then matched with student

loan default rates from the Office of Federal Student Aid and with information on comple-

tions and borrowing which colleges reported to the Integrated Postsecondary Education

Data System or IPEDS23

In assigning an accreditor to each college the fact that IPEDS and federal student aid data

use different identifiers for colleges needed to be addressed The result is that one college

listed by the Office of Federal Student Aid may represent multiple branch campuses in

IPEDS Because accreditation data are tied to the Office of Federal Student Aid data this

analysis consolidated the multiple IPEDS campuses into a single figure The unavoidable

result of this data limitation is that if a branch campus has a different accreditation agency

than the main campus it is still treated as having the same accreditation agency

The analysis uses the number of credentials awarded for every 100 full-time-equivalent stu-

dents instead of a traditional graduation rate because the graduation rate does not count

part-time students or those who transfer in or out of the institutionmdashwhich are more likely

occurrences at the less selective colleges approved by national accreditors24 This measure

addresses both of these flaws by counting all credentials that a given college awards in a

single year and dividing it by a count of all students including those who attend part time

In general a good level of degrees awarded per every 100 full-time-equivalent students is

a number close to the percentage that a college is expected to graduate each year due to

completion Consider the following examples A college that grants four-year bachelorrsquos

degrees where everyone goes full time and graduates should have a rate of 25 degreesper every 100 full-time-equivalent students since that would mean that one-quarter of its

student body graduates each year At a two-year program with similar characteristics this

rate would be 50 degrees for every 100 full-time-equivalent students

About CAPrsquos analysis

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 59

5 Center for American Progress | Up to the Job

Results

able 1 shows he differences in deaul raes borrowing raes average loan amouns

and degrees per every 100 ull-ime-equivalen undergraduae sudens beween

regional and naional accrediors As illusraed he deaul rae or naionally accredied

colleges is subsanially higher han he deaul rae or regional accrediors o pu his

number in perspecive i regionally accredied colleges were o deaul a he same raeas naionally accredied colleges more han 293000 addiional sudens would be in

deaul each year han is currenly he case

TABLE 1

Results by type of accreditation agency

Accreditor

type

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per 100

full-time equivalent

undergraduates

(2012ndash13)

Share of

undergraduates who

borrowed federal

student loans

(2012ndash13)

Average amount of

debt a student

borrower takes out

in a single year

(2012ndash13)

Percent of

undergraduate

credentials that are

certificates

(2012ndash13)

Regional 12 23 39 $6856 16

National 20 46 60 $7405 78

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Similarly he colleges approved by naional accrediors are ar more likely o have su-

dens who borrow991252and borrow more is is parly due o he ac ha sudens atend-

ing naionally accredied colleges are generally lower income 62 percen o sudens anaionally accredied insiuions receive Pell Grans versus 38 percen o sudens a

regionally accredied insiuions Bu he borrowing difference should sill be concern-

ing because 78 percen o he credenials awarded per year a naionally accredied col-

leges are cerificaes Many o hese cerificaes do no lead o paricularly high incomes

and provide reurns well below he expeced resuls or bachelorrsquos degrees which make

up 56 percen o he credenials ha regionally accredied colleges award each year25

Borrowing more or lower-reurn programs means ha sudens may have more rouble

paying off heir suden loans

e one measure on which naional accrediaion agencies appear o perorm beter

is compleion is is due o he mosly shorer programs ha naionally accredied

colleges offer

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 69

6 Center for American Progress | Up to the Job

TABLE 2

Results by accreditation agency

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per

100 full-time

equivalent

undergraduates

(2012ndash13)

Share of

undergraduates

who borrow

federal student loans

(2012ndash13)

Average amount

of debt a student

borrower takes

out in a single year

(2012ndash13)

Percent of

undergraduate

credentials that

are certificates

(2012ndash13)

National accreditation agencies

Accrediting Council for

Continuing Education

and Training

21 76 64 $6214 99

Accrediting Commissionof Career Schools and

Colleges

19 45 65 $7338 80

Accrediting Council

for Independent Colleges

and Schools

21 37 73 $7960 51

Council on Occupational

Education20 65 28 $6528 98

National Accrediting

Commission of Career

Arts and Sciences

17 52 58 $6824 100

Regional accreditation agencies

Middle States

Commission on Higher

Education (Mid-Atlantic)

9 22 43 $6743 3

Higher Learning

Commission of the

North Central Association

of Colleges and Schools

(Midwest)

14 24 46 $6921 13

New England Association

of Schools and Colleges7 22 47 $6827 4

Northwest Commission

on Colleges and

Universities

11 24 37 $6794 14

Southern Association

of Colleges and Schools 13 24 39 $6842 16

Western Association

of Schools and Colleges10 22 20 $6875 15

Accrediting Commission

for Community and Junior

Colleges (West)

21 19 4 $6138 40

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Breaking down he resuls by accrediaion agency reveals ha regional accrediors show

subsanial variaion in resuls which may be due o geographic differences such as New

Englandrsquos larger relaive share o privae nonprofi colleges wih high graduaion raes

compared o oher pars o he counry or he Wesrsquos larger communiy college sysems By

conras he naional accrediaion agencies all cluser around similar perormance levels

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 79

7 Center for American Progress | Up to the Job

able 2 shows jus how differen some o ACICSrsquo resuls are when compared wih oher

accrediaion agencies ACICS shows he highes rae o borrowing o any accredia-

ion agency considered 73 percen I is 8 percenage poins higher han Accrediing

Commission o Career Schools and Colleges or ACCSC he second larges naional

accredior I also has higher average deb and lower compleion figures han any

oher naional accredior Only one regional accrediaion agency991252he Accrediing

Commission or Communiy and Junior Colleges or ACCJC991252approaches ACICSrsquodeaul rae Bu only 4 percen o sudens a colleges accredied by ACCJC borrow

And ha agency has also been challenged or he qualiy o is work 26

Undersanding he scale involved also helps pu some o he ACICS resuls in conex

According o CAP analysis in 2011 approximaely 346000 sudens a ACICS col-

leges enered repaymen991252more borrowers han came rom our o he seven regional

accrediors individually O hose borrowers more han 73000 ulimaely deauled

is number is nearly one-hird higher han he number o deaulers or he Middle

Saes Commission on Higher Educaion which had slighly more han 54000 deaul-

ers despie having 234000 more borrowers han ACICS

Anoher way o inerpre he ACICS resuls is ha his accredior appears o be a srange

hybrid o naional and regional models e colleges ha i approves offer ar more

degrees han is naional peers which are ocused on cerificaes is makes i more like

a regional accredior and parly explains is lower number o degrees per every 100 ull-

ime-equivalen sudens A he same ime he ac ha is colleges offer higher-level

degrees does no appear o resul in lower deaul raes

As one o he larges naional accrediors ACICS is responsible or giving hundreds

o campuses access o billions o dollars in ederal suden aid In his role i has acili-aed he growh o several companies wih problemaic hisories including Corinhian

Colleges and he currenly embatled IT echnical Insiue27

In a ollow-up response o his esimony ACICS Execuive Direcor Gray noed ha

ldquohe primary role o ACICS is o assure qualiy and promoe excellencerdquo I looks like

he agency and is naional accrediaion peers have more work o do o make ha role

a realiy28

Conclusion

Accrediaion signals o sudens ha hey can expec a cerain level o qualiy in heir

higher educaion Is link o ederal aid also implies he US Deparmen o Educaionrsquos

imprimaur991252afer all why would a governmen agency le sudens borrow a a low-

qualiy college Bu i qualiy is no acually invesigaed and verified accrediors risk

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 89

8 Center for American Progress | Up to the Job

puting hundreds o housands o sudens in exremely precarious siuaions ha allow

hem o ake on ederal deb which has no saue o limiaions on collecions and is

almos impossible o discharge in bankrupcy

CAPrsquos analysis srongly suggess ha he curren accrediaion sysem does an insu-

ficien job o dealing wih qualiy991252a leas wih respec o he inersecion beween

suden deb and borrowersrsquo abiliy o pay i back when hey ener he workorce Fixinghis issue will require addressing several quesions such as which oucomes should

be considered when deermining qualiy who should conduc qualiy invesigaions

and wha kind o minimum sandards need o be in place o ensure qualiy ese are

all major issues ha mus be decided in order o ensure ha he possecondary sysem

acually provides sudens he resuls i promises

Ben Miller is the Senior Director for Postsecondary Education at the Center for

American Progress

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray

Page 5: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 59

5 Center for American Progress | Up to the Job

Results

able 1 shows he differences in deaul raes borrowing raes average loan amouns

and degrees per every 100 ull-ime-equivalen undergraduae sudens beween

regional and naional accrediors As illusraed he deaul rae or naionally accredied

colleges is subsanially higher han he deaul rae or regional accrediors o pu his

number in perspecive i regionally accredied colleges were o deaul a he same raeas naionally accredied colleges more han 293000 addiional sudens would be in

deaul each year han is currenly he case

TABLE 1

Results by type of accreditation agency

Accreditor

type

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per 100

full-time equivalent

undergraduates

(2012ndash13)

Share of

undergraduates who

borrowed federal

student loans

(2012ndash13)

Average amount of

debt a student

borrower takes out

in a single year

(2012ndash13)

Percent of

undergraduate

credentials that are

certificates

(2012ndash13)

Regional 12 23 39 $6856 16

National 20 46 60 $7405 78

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Similarly he colleges approved by naional accrediors are ar more likely o have su-

dens who borrow991252and borrow more is is parly due o he ac ha sudens atend-

ing naionally accredied colleges are generally lower income 62 percen o sudens anaionally accredied insiuions receive Pell Grans versus 38 percen o sudens a

regionally accredied insiuions Bu he borrowing difference should sill be concern-

ing because 78 percen o he credenials awarded per year a naionally accredied col-

leges are cerificaes Many o hese cerificaes do no lead o paricularly high incomes

and provide reurns well below he expeced resuls or bachelorrsquos degrees which make

up 56 percen o he credenials ha regionally accredied colleges award each year25

Borrowing more or lower-reurn programs means ha sudens may have more rouble

paying off heir suden loans

e one measure on which naional accrediaion agencies appear o perorm beter

is compleion is is due o he mosly shorer programs ha naionally accredied

colleges offer

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 69

6 Center for American Progress | Up to the Job

TABLE 2

Results by accreditation agency

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per

100 full-time

equivalent

undergraduates

(2012ndash13)

Share of

undergraduates

who borrow

federal student loans

(2012ndash13)

Average amount

of debt a student

borrower takes

out in a single year

(2012ndash13)

Percent of

undergraduate

credentials that

are certificates

(2012ndash13)

National accreditation agencies

Accrediting Council for

Continuing Education

and Training

21 76 64 $6214 99

Accrediting Commissionof Career Schools and

Colleges

19 45 65 $7338 80

Accrediting Council

for Independent Colleges

and Schools

21 37 73 $7960 51

Council on Occupational

Education20 65 28 $6528 98

National Accrediting

Commission of Career

Arts and Sciences

17 52 58 $6824 100

Regional accreditation agencies

Middle States

Commission on Higher

Education (Mid-Atlantic)

9 22 43 $6743 3

Higher Learning

Commission of the

North Central Association

of Colleges and Schools

(Midwest)

14 24 46 $6921 13

New England Association

of Schools and Colleges7 22 47 $6827 4

Northwest Commission

on Colleges and

Universities

11 24 37 $6794 14

Southern Association

of Colleges and Schools 13 24 39 $6842 16

Western Association

of Schools and Colleges10 22 20 $6875 15

Accrediting Commission

for Community and Junior

Colleges (West)

21 19 4 $6138 40

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Breaking down he resuls by accrediaion agency reveals ha regional accrediors show

subsanial variaion in resuls which may be due o geographic differences such as New

Englandrsquos larger relaive share o privae nonprofi colleges wih high graduaion raes

compared o oher pars o he counry or he Wesrsquos larger communiy college sysems By

conras he naional accrediaion agencies all cluser around similar perormance levels

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 79

7 Center for American Progress | Up to the Job

able 2 shows jus how differen some o ACICSrsquo resuls are when compared wih oher

accrediaion agencies ACICS shows he highes rae o borrowing o any accredia-

ion agency considered 73 percen I is 8 percenage poins higher han Accrediing

Commission o Career Schools and Colleges or ACCSC he second larges naional

accredior I also has higher average deb and lower compleion figures han any

oher naional accredior Only one regional accrediaion agency991252he Accrediing

Commission or Communiy and Junior Colleges or ACCJC991252approaches ACICSrsquodeaul rae Bu only 4 percen o sudens a colleges accredied by ACCJC borrow

And ha agency has also been challenged or he qualiy o is work 26

Undersanding he scale involved also helps pu some o he ACICS resuls in conex

According o CAP analysis in 2011 approximaely 346000 sudens a ACICS col-

leges enered repaymen991252more borrowers han came rom our o he seven regional

accrediors individually O hose borrowers more han 73000 ulimaely deauled

is number is nearly one-hird higher han he number o deaulers or he Middle

Saes Commission on Higher Educaion which had slighly more han 54000 deaul-

ers despie having 234000 more borrowers han ACICS

Anoher way o inerpre he ACICS resuls is ha his accredior appears o be a srange

hybrid o naional and regional models e colleges ha i approves offer ar more

degrees han is naional peers which are ocused on cerificaes is makes i more like

a regional accredior and parly explains is lower number o degrees per every 100 ull-

ime-equivalen sudens A he same ime he ac ha is colleges offer higher-level

degrees does no appear o resul in lower deaul raes

As one o he larges naional accrediors ACICS is responsible or giving hundreds

o campuses access o billions o dollars in ederal suden aid In his role i has acili-aed he growh o several companies wih problemaic hisories including Corinhian

Colleges and he currenly embatled IT echnical Insiue27

In a ollow-up response o his esimony ACICS Execuive Direcor Gray noed ha

ldquohe primary role o ACICS is o assure qualiy and promoe excellencerdquo I looks like

he agency and is naional accrediaion peers have more work o do o make ha role

a realiy28

Conclusion

Accrediaion signals o sudens ha hey can expec a cerain level o qualiy in heir

higher educaion Is link o ederal aid also implies he US Deparmen o Educaionrsquos

imprimaur991252afer all why would a governmen agency le sudens borrow a a low-

qualiy college Bu i qualiy is no acually invesigaed and verified accrediors risk

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 89

8 Center for American Progress | Up to the Job

puting hundreds o housands o sudens in exremely precarious siuaions ha allow

hem o ake on ederal deb which has no saue o limiaions on collecions and is

almos impossible o discharge in bankrupcy

CAPrsquos analysis srongly suggess ha he curren accrediaion sysem does an insu-

ficien job o dealing wih qualiy991252a leas wih respec o he inersecion beween

suden deb and borrowersrsquo abiliy o pay i back when hey ener he workorce Fixinghis issue will require addressing several quesions such as which oucomes should

be considered when deermining qualiy who should conduc qualiy invesigaions

and wha kind o minimum sandards need o be in place o ensure qualiy ese are

all major issues ha mus be decided in order o ensure ha he possecondary sysem

acually provides sudens he resuls i promises

Ben Miller is the Senior Director for Postsecondary Education at the Center for

American Progress

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray

Page 6: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 69

6 Center for American Progress | Up to the Job

TABLE 2

Results by accreditation agency

Share of borrowers

who default within

three years of leaving

an institution

(2011 cohort)

Degrees per

100 full-time

equivalent

undergraduates

(2012ndash13)

Share of

undergraduates

who borrow

federal student loans

(2012ndash13)

Average amount

of debt a student

borrower takes

out in a single year

(2012ndash13)

Percent of

undergraduate

credentials that

are certificates

(2012ndash13)

National accreditation agencies

Accrediting Council for

Continuing Education

and Training

21 76 64 $6214 99

Accrediting Commissionof Career Schools and

Colleges

19 45 65 $7338 80

Accrediting Council

for Independent Colleges

and Schools

21 37 73 $7960 51

Council on Occupational

Education20 65 28 $6528 98

National Accrediting

Commission of Career

Arts and Sciences

17 52 58 $6824 100

Regional accreditation agencies

Middle States

Commission on Higher

Education (Mid-Atlantic)

9 22 43 $6743 3

Higher Learning

Commission of the

North Central Association

of Colleges and Schools

(Midwest)

14 24 46 $6921 13

New England Association

of Schools and Colleges7 22 47 $6827 4

Northwest Commission

on Colleges and

Universities

11 24 37 $6794 14

Southern Association

of Colleges and Schools 13 24 39 $6842 16

Western Association

of Schools and Colleges10 22 20 $6875 15

Accrediting Commission

for Community and Junior

Colleges (West)

21 19 4 $6138 40

Source Center for American Progress assigned an accreditor to each college based upon data from the Postsecondary Education Participants System ldquoData Extractsrdquo available at httpswww2edgovofficesOSFA

PEPSdataextractshtml (last accessed August 2015) Student loan default rate data are for borrowers entering repayment in fiscal year 2011 and are drawn from Office of Federal Student Aid ldquoThree-year Official

Cohort Default R ates for Schoolsrdquo available at httpwww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessed August 2015) Completion and borrowing data are for the 2012ndash13 school year and

drawn from the Integrated Postsecondary Education Data System ldquoIPEDS Data Centerrdquo available at httpsncesedgovipedsdatacenter (last accessed August 2015)

Breaking down he resuls by accrediaion agency reveals ha regional accrediors show

subsanial variaion in resuls which may be due o geographic differences such as New

Englandrsquos larger relaive share o privae nonprofi colleges wih high graduaion raes

compared o oher pars o he counry or he Wesrsquos larger communiy college sysems By

conras he naional accrediaion agencies all cluser around similar perormance levels

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 79

7 Center for American Progress | Up to the Job

able 2 shows jus how differen some o ACICSrsquo resuls are when compared wih oher

accrediaion agencies ACICS shows he highes rae o borrowing o any accredia-

ion agency considered 73 percen I is 8 percenage poins higher han Accrediing

Commission o Career Schools and Colleges or ACCSC he second larges naional

accredior I also has higher average deb and lower compleion figures han any

oher naional accredior Only one regional accrediaion agency991252he Accrediing

Commission or Communiy and Junior Colleges or ACCJC991252approaches ACICSrsquodeaul rae Bu only 4 percen o sudens a colleges accredied by ACCJC borrow

And ha agency has also been challenged or he qualiy o is work 26

Undersanding he scale involved also helps pu some o he ACICS resuls in conex

According o CAP analysis in 2011 approximaely 346000 sudens a ACICS col-

leges enered repaymen991252more borrowers han came rom our o he seven regional

accrediors individually O hose borrowers more han 73000 ulimaely deauled

is number is nearly one-hird higher han he number o deaulers or he Middle

Saes Commission on Higher Educaion which had slighly more han 54000 deaul-

ers despie having 234000 more borrowers han ACICS

Anoher way o inerpre he ACICS resuls is ha his accredior appears o be a srange

hybrid o naional and regional models e colleges ha i approves offer ar more

degrees han is naional peers which are ocused on cerificaes is makes i more like

a regional accredior and parly explains is lower number o degrees per every 100 ull-

ime-equivalen sudens A he same ime he ac ha is colleges offer higher-level

degrees does no appear o resul in lower deaul raes

As one o he larges naional accrediors ACICS is responsible or giving hundreds

o campuses access o billions o dollars in ederal suden aid In his role i has acili-aed he growh o several companies wih problemaic hisories including Corinhian

Colleges and he currenly embatled IT echnical Insiue27

In a ollow-up response o his esimony ACICS Execuive Direcor Gray noed ha

ldquohe primary role o ACICS is o assure qualiy and promoe excellencerdquo I looks like

he agency and is naional accrediaion peers have more work o do o make ha role

a realiy28

Conclusion

Accrediaion signals o sudens ha hey can expec a cerain level o qualiy in heir

higher educaion Is link o ederal aid also implies he US Deparmen o Educaionrsquos

imprimaur991252afer all why would a governmen agency le sudens borrow a a low-

qualiy college Bu i qualiy is no acually invesigaed and verified accrediors risk

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 89

8 Center for American Progress | Up to the Job

puting hundreds o housands o sudens in exremely precarious siuaions ha allow

hem o ake on ederal deb which has no saue o limiaions on collecions and is

almos impossible o discharge in bankrupcy

CAPrsquos analysis srongly suggess ha he curren accrediaion sysem does an insu-

ficien job o dealing wih qualiy991252a leas wih respec o he inersecion beween

suden deb and borrowersrsquo abiliy o pay i back when hey ener he workorce Fixinghis issue will require addressing several quesions such as which oucomes should

be considered when deermining qualiy who should conduc qualiy invesigaions

and wha kind o minimum sandards need o be in place o ensure qualiy ese are

all major issues ha mus be decided in order o ensure ha he possecondary sysem

acually provides sudens he resuls i promises

Ben Miller is the Senior Director for Postsecondary Education at the Center for

American Progress

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray

Page 7: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 79

7 Center for American Progress | Up to the Job

able 2 shows jus how differen some o ACICSrsquo resuls are when compared wih oher

accrediaion agencies ACICS shows he highes rae o borrowing o any accredia-

ion agency considered 73 percen I is 8 percenage poins higher han Accrediing

Commission o Career Schools and Colleges or ACCSC he second larges naional

accredior I also has higher average deb and lower compleion figures han any

oher naional accredior Only one regional accrediaion agency991252he Accrediing

Commission or Communiy and Junior Colleges or ACCJC991252approaches ACICSrsquodeaul rae Bu only 4 percen o sudens a colleges accredied by ACCJC borrow

And ha agency has also been challenged or he qualiy o is work 26

Undersanding he scale involved also helps pu some o he ACICS resuls in conex

According o CAP analysis in 2011 approximaely 346000 sudens a ACICS col-

leges enered repaymen991252more borrowers han came rom our o he seven regional

accrediors individually O hose borrowers more han 73000 ulimaely deauled

is number is nearly one-hird higher han he number o deaulers or he Middle

Saes Commission on Higher Educaion which had slighly more han 54000 deaul-

ers despie having 234000 more borrowers han ACICS

Anoher way o inerpre he ACICS resuls is ha his accredior appears o be a srange

hybrid o naional and regional models e colleges ha i approves offer ar more

degrees han is naional peers which are ocused on cerificaes is makes i more like

a regional accredior and parly explains is lower number o degrees per every 100 ull-

ime-equivalen sudens A he same ime he ac ha is colleges offer higher-level

degrees does no appear o resul in lower deaul raes

As one o he larges naional accrediors ACICS is responsible or giving hundreds

o campuses access o billions o dollars in ederal suden aid In his role i has acili-aed he growh o several companies wih problemaic hisories including Corinhian

Colleges and he currenly embatled IT echnical Insiue27

In a ollow-up response o his esimony ACICS Execuive Direcor Gray noed ha

ldquohe primary role o ACICS is o assure qualiy and promoe excellencerdquo I looks like

he agency and is naional accrediaion peers have more work o do o make ha role

a realiy28

Conclusion

Accrediaion signals o sudens ha hey can expec a cerain level o qualiy in heir

higher educaion Is link o ederal aid also implies he US Deparmen o Educaionrsquos

imprimaur991252afer all why would a governmen agency le sudens borrow a a low-

qualiy college Bu i qualiy is no acually invesigaed and verified accrediors risk

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 89

8 Center for American Progress | Up to the Job

puting hundreds o housands o sudens in exremely precarious siuaions ha allow

hem o ake on ederal deb which has no saue o limiaions on collecions and is

almos impossible o discharge in bankrupcy

CAPrsquos analysis srongly suggess ha he curren accrediaion sysem does an insu-

ficien job o dealing wih qualiy991252a leas wih respec o he inersecion beween

suden deb and borrowersrsquo abiliy o pay i back when hey ener he workorce Fixinghis issue will require addressing several quesions such as which oucomes should

be considered when deermining qualiy who should conduc qualiy invesigaions

and wha kind o minimum sandards need o be in place o ensure qualiy ese are

all major issues ha mus be decided in order o ensure ha he possecondary sysem

acually provides sudens he resuls i promises

Ben Miller is the Senior Director for Postsecondary Education at the Center for

American Progress

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray

Page 8: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 89

8 Center for American Progress | Up to the Job

puting hundreds o housands o sudens in exremely precarious siuaions ha allow

hem o ake on ederal deb which has no saue o limiaions on collecions and is

almos impossible o discharge in bankrupcy

CAPrsquos analysis srongly suggess ha he curren accrediaion sysem does an insu-

ficien job o dealing wih qualiy991252a leas wih respec o he inersecion beween

suden deb and borrowersrsquo abiliy o pay i back when hey ener he workorce Fixinghis issue will require addressing several quesions such as which oucomes should

be considered when deermining qualiy who should conduc qualiy invesigaions

and wha kind o minimum sandards need o be in place o ensure qualiy ese are

all major issues ha mus be decided in order o ensure ha he possecondary sysem

acually provides sudens he resuls i promises

Ben Miller is the Senior Director for Postsecondary Education at the Center for

American Progress

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray

Page 9: Up to the Job?: National Accreditation and College Outcomes

8202019 Up to the Job National Accreditation and College Outcomes

httpslidepdfcomreaderfullup-to-the-job-national-accreditation-and-college-outcomes 99

9 Center for American Progress | Up to the Job

Endnotes

1 Accrediting Council for Independent Colleges and SchoolsldquoStaff Directoryrdquo available at httpwwwacicsorgcontactcontentaspxid=1440 (last accessed August 2015)

2 US Senate Health Education Labor and Pensions Com-mittee ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qual ityrdquo June 17 2015available at httpwwwhelpsenategovhearingsreautho-

rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

3 Sen Elizabeth Warren ldquoCorinthian Colleges Education Com-mittee Hearingrdquo available at httpswwwfacebookcomsenatorelizabethwarrenvideosvb131559043673264483510328478132type=2amptheater (last accessed August 2015)Stephanie Gleason ldquoCorinthian Colleges Files for Chapter 11Bankruptcyrdquo The Wall Street Journal May 4 2015 availableat httpwwwwsjcomarticlescorinthian-colleges-files-for-chapter-11-bankruptcy-1430746291 US Departmentof Education ldquoUS Department of Education HeightensOversight of Corinthian Collegesrdquo June 19 2014 availableat httpwwwedgovnewspress-releasesus-department-education-heightens-oversight-corinthian-colleges

4 The exchange starts at 11755 in the following video USSenate Committee on Health Education Labor and Pen-sions ldquoReauthorizing the Higher Education Act EvaluatingAccreditationrsquos Role in Ensuring Qua lityrdquo June 17 2015

available at httpwwwhelpsenategovhearingsreautho-rizing-the-higher-education-act-evaluating-accreditations-role-in-ensuring-quality

5 Accrediting Council for Independent Colleges and SchoolsldquoForm 990 Return of Organization Exempt from Income Taxrdquo (2012) p 1 available at httpwwwguidestarorgFinDocuments20135218292013-521829463-0a19249e-9pdf

6 Andrea Fuller and Douglas Belkin ldquoThe Watchdogs ofCollege Education Rarely BiterdquoThe Wall Street Journal June17 2015 available at httpwwwwsjcomarticlesthe-watchdogs-of-college-education-rarely-bite-1434594602

7 Albert Gray ldquoLetter to Chairman Lamar Alexander and Rank-ing Member Patty Murrayrdquo June 30 2015 available at httpwwwacicsorgWorkArealinkitaspxLinkIdentifier=idampItemID=6471amplibID=6456

8 Molly Hensley-Clancy ldquoLower Educationrdquo Buzzfeed

November 13 2014 available at httpwwwbuzzfeedcommollyhensleyclancylower-educationycP6Z40k0 AlanPyke ldquoThe Inside Story Of How A For-Profit College Hood-winked Students And Got Away With I trdquo ThinkProgress February 28 2015 available at httpthinkprogressorgeconomy201502283628028whats-the-deal-with-government-helping-corinthian

9 Michael Stratford ldquoDebt Relief Unveiledrdquo Inside Higher Ed

June 9 2015 available at httpswwwinsidehigheredcomnews20150609us-will-erase-debt-corinthian-students-create-new-loan-forgiveness-process

10 Andrew Leonard ldquoAmericarsquos Worst Collegesrdquo Salon June 52012 available at httpwwwsaloncom20120605ameri-cas_worst_educators

11 Sen Elizabeth Warrenrdquo Corinthian College Education Com-mittee Hearingrdquo

12 US Department of Education ldquoNational Student LoanDefault Ratesrdquo (2014) available at httpwwwifapedgoveannouncementsattachments2014OfficialFY20113YRCDRBriefingpdf

13 Sen Marco Rubio ldquoMaking Higher Education AffordableAgainrdquo Remarks as Prepared for Delivery at Miami-DadeCollege February 10 2014 available at httpwwwrubiosenategovpublicindexcfmpress-releasesID=a24acd97-025e-4ed7-9672-7a84eb76606b

14 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo available at httpwww2edgovadminsfinaidaccredaccreditation_pg9html (last accessedAugust 2015)

15 US Department of Education ldquoAccreditation in the USrdquoavailable at httpwww2edgovadminsfinaidaccredac-creditation_pg2html (last accessed August 2015)

16 University of Phoenix ldquoAccreditations and Licensuresrdquo avail-able at httpwwwphoenixeduabout_usaccreditationhtml (last accessed August 2015) Strayer University ldquoTheStrayer Experiencerdquo available at httpwwwstrayeredustrayer-experience (last accessed August 2015)

17 US Department of Education ldquoAccrediting Agencies Recog-nized for Title IV Purposesrdquo

18 Ibid

19 Fortis College ldquoFortis College in Foleyrdquo available at httpswwwfortiseducampusesalabamafoley200-east-laurel-avenue-foley-alaspx (last accessed August 2015) PennFoster College ldquoPenn Foster College Programsrdquo available athttpwwwpennfostereduprograms-and-degreescollegeaspx (last accessed August 2015)

20 Jayrsquos Technical Institute ldquoJayrsquos Technical Instituterdquo available

at httpjtisitewixcomjaysbarberandbeauty (last accessedAugust 2015)

21 Accrediting Council for Independent Colleges and SchoolsldquoTransfer of Creditrdquo available at httpwwwacicsorgstudentscontentaspxid=2084 (last accessed August2015) Stephanie Chen ldquoFor-Profit College Risk Huge DebtQuestionable Degreerdquo CNN September 2 2010 available athttpwwwcnncom2010LIVING0902forprofitcollegedebt

22 Postsecondary Education Participants System ldquoDataExtractsrdquo available at httpswww2edgovofficesOSFAPPEPSdataextractshtml (last accessed August 2015)

23 Office of Federal Student Aid ldquoThree-year Official CohortDefault Rates for Schoolsrdquo available at httpw ww2edgovofficesOSFAPdefaultmanagementcdrhtml (last accessedAugust 2015) Integrated Postsecondary Education DataSystem ldquoIPEDS Data Centerrdquo available at httpsnces

edgovipedsdatacenter and httpsncesedgovipedsdatacenterDefaultaspx (last accessed August 2015)

24 American Council on Education ldquoCollege Graduation RatesBehind the Numbersrdquo (2010) p 8 available at httpwwwacenetedunews-roomDocumentsCollege-Graduation-Rates-Behind-the-Numberspdf

25 Ben Miller ldquoWhat the Washington Post Gainful Employ-ment Fact Check (and the Original Stat) Missrdquo EdCentralBlog April 13 2014 available at httpw wwedcentralorgwashington-post-gainful-employment-fact-check Bureauof Labor Statistics ldquoEarnings and Unemployment Rates byEducational Attainmentrdquo available at httpwwwblsgovempep_chart_001htm (last accessed August 2010)

26 Inside Higher Ed ldquoTrouble for an Accreditorrdquo August 312014 available at httpswwwinsidehigheredcomnews20150831californias-community-colleges-may-seek-new-accreditor

27 US Senate Health Education Labor and Pensions Commit-tee ldquoTestimony of Albert C Gray President amp CEOrdquo June 172015 available at httpwwwhelpsenategovimomediadocGray2pdf Paul Fain ldquoProblems Deepen for ITTrdquo InsideHigher Ed May 13 2015 available at httpswwwinside-higheredcomnews20150513sec-charges-itt-fraud-over-student-loan-programs

28 Gray ldquoLetter to Chairman Lamar Alexander and RankingMember Patty Murray