Mr. Chairman and Members of the Subcommittee, thank you for the opportunity to testify about accreditation and its ability to ensure institutional accountability and quality for students and their parents. I am Arthur Keiser, Chancellor of the Keiser Collegiate System, which includes Keiser College, Keiser Career College, and Everglades University. The Keiser Collegiate System comprises 16 campuses in the State of Florida with over 7,000 students. Sixteen accrediting agencies review these institutions, including both national and regional agencies, as well as those that provide institutional and programmatic review. I am testifying here today on behalf of the Accrediting Commission of Career Schools and Colleges of Technology (ACCSCT or the Commission). I am completing my term as an ACCSCT Commissioner in July and I just completed a two-year term as Chairman.

ACCSCT is a private, non-profit independent accrediting agency recognized by the Secretary of Education since 1967. It is a national agency that accredits approximately 800 institutions with over 400,000 students throughout the country. ACCSCT-accredited institutions are both non-profit and for-profit, degree and non-degree granting. These institutions prepare students for trade and technical careers in many areas including computer programming, commercial art, culinary arts and medical technology, among others.

ACCSCT applauds you and the Subcommittee for holding this hearing today to ask the important question of how accreditation performs in providing accountability and quality control. Accreditation predates the Higher Education Act and has always been voluntary in nature. However, since the enactment of the Higher Education Act in 1965 accrediting bodies have held an important role in the regulatory process that determines whether institutions participate in Title IV. Without accreditation by an agency recognized by the Secretary, an institution may not access Title IV funds. For those institutions that participate, accrediting agencies have the important responsibility to ensure the quality and integrity of their programs. For those accrediting agencies that seek recognition from the Secretary, the Act currently contains a number of obligations that must be met with regard to accreditation review and operating procedures. ACCSCT believes that the accreditation community provides quality assurance and accountability for students and their parents. ACCSCT also shares your interest in strengthening that current role through passage of H.R. 4283’s provisions on accreditation.

In the testimony that follows, I would like to provide you with background regarding ACCSCT’s accreditation mission and process and then share the Commission’s view on what particular goals might be achieved through the reauthorization process to enhance accreditation’s consumer protection role. Specifically, I will discuss four topics: 1. how greater transparency in the accreditation process serves students and the public; 2. the role that accreditors can play in improving institutional accountability; 3. accreditation’s role in addressing problems raised by the arbitrary denial of transfers of credit; and 4. the enhanced role of accreditation in assessing distance education.

I. Overview of ACCSCT’s Accreditation Practices

The Commission has thirteen members: six are public members representing government, industry or the higher education community, and seven members represent the private career school sector. School members are elected by ACCSCT institutions, and public members are selected by the Commission after being recommended by ACCSCT’s nominating committee. Each commissioner serves for a maximum of four years.

The Commission is well suited to provide its perspective on whether accreditation, and ACCSCT specifically, assures students and parents institutional accountability and quality. We believe that the Commission’s focus in these areas provides protection for students’ investments in their educations. The Commission’s mission is to accredit career schools and colleges in the United States, its territories and abroad. Its mission has two primary goals: to assure students and the general public of the quality of education provided by institutions and their programs, and to assist institutions in continuously improving to better serve students.

The Commission has adopted detailed standards which ACCSCT-accredited institutions must meet in order to maintain their accreditation status. The standards define a model of accreditation that assesses the effectiveness of an institution by examining faculty, admission practices, facilities and equipment, financial and administrative capability and student services, as well as the performance outcomes of students, such as favorable completion and job placement rates, and pass rates on state licensing or national certification examinations. These standards reflect a concern for consumer protection and student satisfaction. For example, the Commission requires its institutions to disclose to prospective students before enrollment information regarding tuition, incidental costs and refund policies. The Commission also requires institutions to provide students copies of the complete enrollment agreement, including both the student’s and institution’s obligations. A copy of the Commission’s standards is included with this testimony.

Through the self-evaluation process, an institution has the opportunity to assess its programs against ACCSCT’s established standards and to identify areas of strength and those that need improvement. Once an institution completes its self-evaluation report, a team visit is conducted by ACCSCT to verify the information submitted in the report and to determine the institution’s adherence to its stated objectives and compliance with the Commission’s standards of accreditation. These visiting teams generally include a team leader to review an institution’s administration, student services and financial position; an occupation specialist to evaluate the training and equipment for each discipline in which the institution provides instruction; and an education specialist from an accredited two- or four-year college or university for review of faculty, libraries and instruction. All teams include an ACCSCT staff member as well.

Once a team visit is complete, the team prepares a written report to which the institution has the opportunity to respond. The Commission then reviews these reports and comments before a decision on accreditation is made. In addition to these materials, the Commission may seek additional information from state and federal agencies, other accrediting agencies and the public. The institution may respond to these third party comments.

ACCSCT meets at least quarterly to conduct business related to school actions. The Commission can grant accreditation to an institution for up to five years. Shorter accreditation periods are granted in instances where the Commission sees the need to closely monitor an institution’s compliance. The Commission may take the following actions on an institution: accredit/reaccredit (with or without stipulation); defer action pending additional information; order the institution to Show Cause as to why accreditation should not be revoked; place an institution on probation; deny or fail to grant accreditation; and remove an institution from accreditation.

We strongly believe that the Commission’s standards and procedures provide the public with the assurance of quality and accountability. Can accrediting agencies do more to improve in this area? The Commission believes they can and early in the Reauthorization process, the Commission focused its attention on how the Act might be amended to provide more information to students and to the public regarding the quality of an institution’s programs, while at the same time preserving the integrity of the accreditation process.

The Commission believes H.R. 4283’s provisions strike the appropriate balance between assuring accountability and maintaining the confidentiality and integrity of the accreditation process. The bill would require accrediting agencies to provide both the Department and the public a summary of actions taken on an institution. The Commission supports the disclosure of information relating to final actions. In fact, at a minimum, accrediting agencies are already required to notify the Department of actions taken. In the case of a final decision to deny, terminate or suspend, accreditation agencies currently are required to provide a notice and summary of such actions to the Department. Such disclosures must be made available to the public upon request. The most significant change under the bill is with regard to the public disclosure of these summaries. The expansion of information required to be disclosed should not represent a dramatic change for accreditors or the institutions. These provisions simply enhance and clarify many of the current provisions of the Act.

The bill’s provisions also require public disclosure of accreditation team members, a description of accrediting agencies’ processes for selecting and training these individuals, as well as disclosure of the accreditor’s code of conduct. The Commission understands that the intent of these provisions is to assure the public that accrediting agencies and their representatives are qualified to review their institutions and ensure quality. With the significant number of evaluators used by all of the recognized accrediting agencies, we recommend that the bill require the disclosure of an updated list on an annual basis without disclosing the make-up of each specific site team.

ACCSCT has worked to examine ways in which both institutions and accrediting agencies can provide the student-consumer more information about the schools they attend or would like to attend. We believe that the bill’s provisions to create a "college consumer profile" take an important step forward in this area. In my capacity as Chancellor to the Keiser Collegiate System, I do not believe these provisions require institutions or accreditors to develop or disclose a significant amount of new data. Much of the information to be disclosed relates directly to the criteria already required to be reviewed under the Act’s provisions on accrediting agency standards. What is important and new about the development of the profile is that the information will be provided and disclosed to the public in a consistent manner by a single entity, the Department. Under the bill, accrediting agencies would have the role of ensuring that institutions comply with these requirements.

Public disclosure of student achievement would also improve institutional accountability. As recently demonstrated by the Education Trust, graduation rates are disturbingly low at many American institutions. ACCSCT believes it is increasingly important that institutions participating in Title IV programs demonstrate the benefits that students will receive from institutions’ educational programs. It is important for institutions to be more accountable with regard both to student completion rates and other appropriate outcomes that demonstrate student achievement and learning. In order to accomplish this goal, ACCSCT believes that Congress, through Reauthorization, should place a greater emphasis on the use of meaningful performance measures to affect institutions’ participation in student aid programs, including placement, completion and retention rates.

ACCSCT, like other national accrediting agencies, already assesses student outcomes and each accredited institution’s performance in this regard. Our standards require reasonable and acceptable levels of completion, placement and pass rates on licensure and certification examinations. We have collected extensive hard data on these and other measures of institutional performance. The statutorily mandated recognition criteria for accrediting agencies have included assessment of institutions’ student achievement since 1992. In 1998, Congress increased the emphasis on accrediting agencies’ assessment of student achievement by placing it as the first criterion to be considered in recognition reviews of accrediting agencies. ACCSCT has developed an equation in response that requires institutions to calculate completion and job-placement rates and to maintain rates that are within one standard deviation of the average for comparable programs or schools. ACCSCT’s ability to collect important completion-rate and job-placement data on its institutions provides its institutions with clear bright-line goals to meet. In 2002, the average completion rate for all programs at ACCSCT-accredited institutions was 68.6%; the overall job placement rate as 84.3%.

A recent article in the New York Times highlighted that a significant majority of all students seek a higher education in order to improve their career opportunities. According to a survey conducted by the Center for Survey Research and Analysis at the University of Connecticut, 64 percent of students surveyed indicated that the primary purpose of a college education is to prepare students for specific careers. The article provides an overview of efforts made by traditional institutions to accommodate this purpose.

H.R. 4283’s provision to amend the student achievement standards required for accrediting agencies reflects the consumer interest in outcomes, retention, completion and job placement. The bill’s provision accomplishes this in a manner that is deferential to the ability of institutions and accrediting bodies to determine the appropriate measures of student academic achievement based on an institution’s mission and the learning objectives of individual programs. As mentioned above, ACCSCT and many other national accrediting agencies have required a review of such data for a number of years and believe that all institutions, and their accrediting agencies, should be capable of collecting and reviewing such data as a way of strengthening programs and holding them accountable for meeting their objectives, as they define them.

ACCSCT shares the desire of the Chairman and many on the Committee to eliminate unnecessary burdens on students and on the Federal Treasury. One important way in which to do this is to improve students’ ability to transfer credits. The ability of students to transfer credit between institutions is a critical component to ensuring the efficiency and effectiveness of Title IV funding.

According to one study performed by the Institute for Higher Education Policy, over 50 percent of 1996 baccalaureate graduates attended at least two colleges and universities. With the increased number of adult students and the increased desire and need to continue or expand one’s education, this trend is expected to continue. Barriers to the transfer of credit seriously affect the cost, time and the student initiative needed to complete a higher education program. In many cases, students that rely on Title IV student loans are forced to retake courses for which credit is denied. This situation puts an unnecessary financial strain on both individual students and on our Title IV student aid system. At a time when the postsecondary student population is increasing, unduly restrictive transfer policies burden the already stretched capacity of the postsecondary education system.

Barriers to the transfer of credit are particularly prevalent when students attempt to transfer credits from nationally accredited institutions to regionally accredited institutions. The study described above reviewed the established Transfer Credit Practices directory (TCP), which surveys the transfer policies of major receiving institutions throughout the U.S., and found that the vast majority of regionally accredited institutions are included in the directory as acceptable institutions of transfer, while most nationally accredited institutions are not. The standards for recognition by the Secretary, however, are identical for both national and regional accrediting agencies. Thus, national accreditation is not provided the same status as regional accreditation for transfer purposes despite the equivalency of their quality assessment standards for the purposes of recognition by the Department of Education.

I am personally familiar with the obstacles that some of my institutions’ students have faced. One student’s story demonstrates the problem. This student is a graduate of a bachelor’s degree program at one of the nationally-accredited Keiser schools, Everglades University. Early last year, he sought admission to Nova Southeastern University, a regionally-accredited institution, to receive a master’s degree in computer information systems. His admission was denied because he did not receive his bachelor’s degree from a regionally-accredited institution. This denial was made in spite of Everglades’ membership in Florida’s common course numbering system. NSU recommended to the student that he retake two years’ worth of courses in order to receive a second bachelor’s degree from NSU before advancing to the master’s program. Many other students attending ACCSCT-accredited institutions have faced similar obstacles and we have provided specific examples to the Committee with this testimony.

Receiving institutions should not be permitted to deny the transfer of credits based on the transferring institution’s type of accreditation. The Keiser Collegiate System is comprised of both regionally and nationally accredited institutions. Although they differ in processes, expectations and standards, I can attest from experience that the national accrediting agencies are as effective and comprehensive in reviewing institutional quality and integrity as the regional accrediting agencies, if not more so.

The Commission supports H.R. 4283’s provisions to alleviate these transfer of credit concerns. We believe that the bill strikes an appropriate and needed balance between the federal government’s responsibility to protect against waste and undue burdens tied to Title IV funds with the need to protect the autonomy of institutions to make appropriate transfer decisions based on course equivalency and student proficiency. The bill accomplishes this by requiring that both institutions and accrediting agencies adopt policies prohibiting the denial of the transfer of credits based solely on accreditation, if the institution from which the student is transferring is accredited by an agency recognized by the Secretary. The bill explicitly protects the rights of institutions to consider course equivalency and student proficiency and explicitly states that the Department shall not interpret these provisions to allow regulation in the area of institutional curricula. Finally, the Commission believes the bill’s provisions to require that public disclosure of institutional transfer practices by both institutions and the accrediting agencies will assist in reducing arbitrary transfer decisions and will give students critical information as they plan for higher education.

During the last decade, the development of distance education has provided an increasingly important means to achieve a postsecondary education. The growth of online education is particularly important to working adults and the more diverse circumstances of students. Today, 43% percent of the undergraduate population is over the age of 25. Many of these adults are attempting to work and raise families while earning their degrees. An online education provides opportunities to many students who otherwise would not be able to earn a degree. Over 250,000 students have enrolled for an online degree to date, and enrollment is expected to reach one million by 2010.

In expanding access to higher education, ACCSCT has emphasized that one area in which accreditation could play an enhanced role in ensuring quality is in removal of the 50 percent rules, which currently serves as a barrier to distance education. Everglades University is a small institution offering both campus-based programs and distance education programs. Despite our success in distance education and a separate rigorous and successful accreditation review process by ACCSCT of our distance education programs, Everglades is limited by the 50 percent rules in its ability to expand in this area.

The College Access & Opportunity Act takes important steps by removing the 50 percent rules barrier. In doing so, the bill requires accrediting agencies to have, within the scope of their recognition from the Secretary, the evaluation of distance education programs. ACCSCT strongly supports the bill’s reliance on accrediting agencies’ ability to review and monitor the quality of distance education. ACCSCT has already supplemented its own standards of accreditation to include specific provisions and principles for distance education review and is currently recognized by the Department as having distance education within its scope of recognition. Whether accrediting agencies choose to rely on separate standards or existing standards to review distance education, we believe that the legislation should focus on the accrediting agencies’ capabilities to review these institutions or programs with as much rigor as they do campus-based institutions, while also recognizing their special attributes.

In conclusion, the Commission strongly believes that accreditation, and in particular national accreditation, provides a strong assurance of quality for higher education in the United States. The Commission also believes that Reauthorization of the Higher Education Act presents an opportunity for Congress and the higher education community to strengthen accreditation and to increase public disclosure of information that is so important in determining the quality of our higher education institutions. I thank you again for this opportunity to testify before the Subcommittee.