Education Department Procedures

The National Association of Scholars upholds the standards of a liberal arts education that fosters intellectual freedom, searches for the truth, and promotes virtuous citizenship.

Introduction

The complex American accreditation system involves general and specialized accrediting bodies, and regional as well as state bodies. Accreditors ascertain whether higher education institutions possess financial integrity and stability, educational quality, and sufficient career preparation for their graduates. Whatever commitment to the public good they still uphold now generally is phrased in terms of progressive ideological goals. The regional accreditors play the largest role: they dominate the federal process by which a college or university is deemed eligible to receive federal disbursements, the most important of which are funds distributed through the Title IV student loan program.

The regional accreditors’ “gatekeeper” role undermines their ability to provide accurate assessments of the quality of colleges and universities. If they suspend or withdraw accreditation, that could mean the quick bankruptcy of a college or university—virtually all of which derive large portions of their revenues from federal funding. Accreditation has acquired such high stakes that accreditors typically shrink from their duty to evaluate rigorously the quality of colleges’ and universities’ academic programs.

While the regional accreditors shy from upholding meaningful academic standards, they are often eager to impose an ideological agenda in the guise of education criteria. These ideological standards have forced or given cover to colleges and universities to change general education requirements, create activist bureaucracies, and inhibit intellectual freedom and intellectual diversity.

The Department of Education’s own “peer review” process, meanwhile, has increasingly been compromised by higher education’s drift into ideological conformity and groupthink. The Secretary should be authorized to seek reviewers who possess genuinely independent minds, and who are willing to depart from the “peer review” consensus.

Congress should reform both the accreditation system and the system of “peer review.”

Policy Recommendations

Depoliticize Accreditation

Congress should prohibit accrediting agencies from including any implicitly or explicitly political criterion in their standards.

Legislative Language: Add to 20 U.S.C. §1099b. (Recognition of accrediting agency or association) a subsection which specifies:

  1. that no accreditation standard, implicitly or explicitly, can require an institution of higher education to commit (financially, programmatically, or otherwise) to concepts such as social justice, diversity, multiculturalism, or civic engagement; and
  2. that no accreditation standard, implicitly or explicitly, can require an institution of higher education to commit (financially, programmatically, or otherwise) to a concept that cannot be precisely defined, and which lacks a precise definition of how to assess progress toward that concept.

Protect Religious Freedom

Congress should ensure that accreditors do not trespass on the religious freedom of religious colleges and universities.

Legislative Language: Add to 20 U.S.C. §1099b. (Recognition of accrediting agency or association) a subsection which specifies:

  1. that any institution of higher education with a religious mission whose accreditation has been withdrawn, revoked, or terminated, or that has voluntarily withdrawn from its accrediting agency, may remain certified as an institution of higher education for a period sufficient to allow such institution to obtain alternative accreditation, if the Secretary determines that the withdrawal, revocation, or termination—
    1. is related to the religious mission or affiliation of the institution; and
    2. is not related to the accreditation criteria provided for in this section;
  2. that the term “religious mission” should be defined to include an institution’s religious tenets, beliefs, or teachings, and any policies or decisions related to such tenets, beliefs, or teachings (including any policies or decisions concerning housing, employment, curriculum, self-governance, or student admission, continuing enrollment, or graduation); and
  3. that an agency or association’s standard fails to respect an institution’s religious mission when the institution determines that the standard induces, pressures, or coerces the institution to act contrary to, or to refrain from acting in support of, any aspect of its religious mission.

Replace “Peer Review” with “Expert Review”

Congress should authorize the Department of Education to substitute “expert review” for “peer review.”

Legislative Language: Amend 20 U.S.C. § 1011g (Application of peer review process) to:

  1. replace “peer review” with “expert review” throughout. This change should be throughout the Higher Education Act, wherever relevant; and
  2. define “expert review” as “Review both by professionals within a field, known as ‘peer reviewers,’ and by professionals in other fields who are intellectually equipped to provide an informed assessment and critique.”