For college accreditation, long-overdue changes are coming
Plus: Sending student loans to Treasury, and how states should approach Workforce Pell.
Negotiated rulemaking—the process where stakeholders work together to draft regulations related to higher education—is back. This time, college accreditation is the topic of the day.
Starting next week, the Accreditation, Innovation, and Modernization (AIM) committee will consider a 151-page proposed amendment to the current regulations governing college accreditors—those higher education watchdogs that rarely bite. The draft language can and will change as the committee considers it, but it’s likely that the Education Department will move forward with the core of the proposed rule.
The proposal represents a massive step forward for what has been, frankly, a broken form of college oversight. Summarizing all 151 pages here would use up too much ink. Instead, I’ll focus on four major provisions that stood out as particularly impactful:
Creating a smoother pathway for aspiring accreditors to gain recognition from the Education Department;
Discouraging accreditors from ratcheting up degree or credential requirements for licensed professions;
Requiring accreditors to look more keenly at student achievement outcomes at the colleges they oversee; and
Improving transferability of credit between accredited colleges.
Let’s dive into each of the four provisions in turn.
Smoother pathway for new accreditors
In the last several years, multiple agencies have formed seeking recognition as accreditors. Often, these organizations have new and innovative ideas about the best way to oversee colleges. The Commission for Public Higher Education seeks a more streamlined accreditation process tailored for state university systems. The Postsecondary Commission (where I serve on the technical advisory board) will evaluate colleges based on how well they advance economic mobility.
But the Education Department has been slow to consider aspiring accreditors’ applications for federal recognition; the Biden administration stopped accepting and reviewing applications entirely. The previous administration also made it significantly harder for colleges to change accreditors—a major obstacle for aspiring agencies that need institutions to accredit.
In contrast, the current proposal would accelerate the timeline for recognizing new accreditors. The Education Department would be required to respond to new accreditors’ applications for recognition within 120 days and finish review of complete applications within six months.
The rules also create a presumption that an institution changing accreditors or having multiple accreditors is reasonable unless the Department identifies a clear red flag. New accreditors cannot get off the ground unless existing institutions voluntarily switch to them. Those institutions must also hold dual accreditation until the new accreditor is officially recognized, otherwise their accreditation will lapse. A presumption that changes of accreditor and multiple accreditors are legitimate unless proven otherwise will reassure institutions wary that partnering with new accreditors could put them at regulatory risk.
Fighting credential inflation
Accreditors which oversee programs that provide professional training have a shameful history of ratcheting up credential requirements for certain licensed professions. In the past, physical therapists needed only a bachelor’s degree to get a license. But in 2016, the Commission on Accreditation in Physical Therapy Education (CAPTE) decreed that it would approve only doctoral programs in physical therapy; since graduation from a CAPTE-approved program is required for licensure, the minimum degree required for entry in this occupation effectively rose from a bachelor’s to a doctoral degree. Aspiring physical therapists must now spend seven years in school rather than four, significantly raising barriers to entry into this occupation.
The draft rules aim to prevent a repeat of this episode. Absent compelling evidence of necessity to protect the public, accreditors cannot “restrict access to employment in a profession, occupation, or vocation, including by taking steps to increase credentialing standards, to increase the cost or level of required education or training, or to decrease the availability of education or training.” This intends to prevent self-serving moves that boost credentialing requirements to protect incumbents in the profession.
The rules also strengthen the legal requirement that accreditors be “separate and independent” of related trade associations. Accreditors cannot share personnel or facilities with such associations. If an accreditor engages in anticompetitive conduct, such as inflating the credential requirements necessary for entry into a profession, such behavior can be considered a negative factor when the accreditor’s recognition by the federal government comes up for renewal.
Strong student achievement standards
Federal law requires accreditors to assess colleges’ “success with respect to student achievement.” But the Education Department has left that provision undefined and unenforced. As a result, accreditors often turn a blind eye to colleges under their purview with abysmal graduation rates or poor return on investment. When accreditors do take adverse action against institutions, it is rarely because the college has poor student outcomes.
The proposed regulations start by requiring accreditors to assess their member colleges’ outcomes at both the institution and program level. The latter is key, because some colleges that perform decently overall nonetheless offer some programs where outcomes are subpar.
The proposal also requires accreditors to “identify minimum expectations of student performance” (or at least explain why this isn’t feasible and develop an alternative way to evaluate student achievement). Accreditors should have minimum standards for graduation rates, job placements, standardized test scores, economic return on investment, and other metrics. The rules do not specify what the minimum thresholds should be—that is left up to the accreditors—but the agencies must set the standards and determine consequences for colleges that fail to meet them.
Ensuring transferability of credit
Universities can be snobby—especially about transfer credit. Four-year schools often reject credits that transfer students earn at community colleges. One student profiled by the Associated Press had to retake several classes after transferring from a community college to California State University-Bakersfield—at a cost of $20,000—because the university deemed the community college classes “less rigorous” and capped the number of credits that could be transferred. Transfer students lose around half their credits on average, according to the Government Accountability Office.
The proposed rules have no time for snobbery. Accreditors must ensure their member institutions have standards that “presume the transferability of credits earned at another institution accredited by a nationally recognized accrediting agency count towards general education requirements or electives,” absent a written rationale specific to the courses in question. In other words, accreditors must ensure that universities accept transfer credits unless they can give a satisfactory reason why not—and that explanation must be specific to the courses that each transfer student has taken.
But making the changes stick will require follow-through
The proposed regulations push accreditors in the right directions—against credential inflation and toward better student outcomes. However, the rules also maintain flexibility for accreditors: if they don’t want to set minimum achievement standards for institutions, for instance, they must provide a convincing explanation and an alternative.
Flexibility is good, as regulators cannot foresee all unintended consequences. But it also means that the Education Department cannot simply rely on accreditors to adhere to the spirit of the regulations. Black-letter language is not enough; Department staff must ensure that accreditors do not rely on flimsy excuses to sidestep the intent of the rules. It would be helpful for policymakers to explain what constitutes “compelling evidence” that raising credential requirements is necessary, for instance. Hopefully they will make clear that this bar is high.
The Department has put forward an excellent package of reforms. It must also follow through. American students deserve a more effective accreditation system that upholds high standards of student outcomes, resists credential inflation, and welcomes innovative models of oversight. The regulatory changes are promising—but they will remain words on paper without keen enforcement.
What I’m writing
Sending student loans to the Treasury Department makes sense. DC folk are skeptical of the Education Department’s latest interagency agreement, which will shift responsibility for some of the student loan portfolio to the Treasury Department. But I think it’s a good idea—Treasury already collects other federal debts, and it can easily add student loans to its remit. Plus, it’s a first step towards integrating student loan repayment into the tax withholding system, as it works in many other countries.
States should consider earnings outcomes for Workforce Pell programs. Short-term workforce education programs could qualify for Pell Grants this year—but only if they produce strong outcomes. I argue states should consider what graduates of short-term programs earn before putting any of these programs forward for Workforce Pell. The Education Department can help by offering guidance to states on how to assess program outcomes—and make sure that this new stream of federal money flows only to the highest-quality courses.
Graduate school is riskier than you think. Two new reports from the Postsecondary Education and Economics Research (PEER) Center say you should be careful with graduate schools. Outside of professional degrees like law and medicine, many grad programs offer only the barest returns. And completion rates are stunningly low for many popular master’s degrees.
Are low-quality colleges making a comeback? Last year, I documented that almost all the decline in college enrollment has occurred at low-quality institutions—a phenomenon I termed “a correction, not a crisis.” I’ve updated the analysis with 2024 data, and found that enrollment has started to tick back up at some of those schools with poor outcomes. It’s too soon to call it a comeback, but I’ll be keeping an eye on this.
How Congress can deregulate low-interest student loans. Federal student loan limits are coming this fall. The University of Kansas law school has launched a new low-interest student loan program to help out students who want to borrow above the new $50,000 federal cap. The school, not the taxpayer, will take on the risk that students won’t repay. Federal law creates barriers for other schools that want to set up similar programs—but a bipartisan bill introduced last month aims to fix that.
What I’m reading
Jon Marcus looks at the bipartisan roots of higher education reform for Washington Monthly.
Why the ATM didn’t kill bank teller jobs, but the iPhone did—a helpful framework for thinking about the impact of AI on labor markets.
Beth Akers explores three ways colleges can and should adjust to new federal loan limits for RealClearEducation.
Remote learning during Covid led to a significant decline in college enrollment, according to new causal research published at NBER.
The essential overview of what the research tells us about the return on investment of a bachelor’s degree, by economists Doug Webber and Celeste Carruthers.
The accreditor for naturopathic medicine schools may lose its federal recognition, reports Inside Higher Ed.
What I’m doing
On April 23, I’m interviewing Under Secretary of Education Nicholas Kent on the Education-Treasury interagency agreement and what it means for the future of student loans. You can attend in person at AEI (lunch will be served!) or watch online. Register here.
DC is experiencing one of its two annual spells of Good Weather, so I made a trip to the Tidal Basin to see the cherry blossoms.
I’ll be in San Diego next week for ASU/GSV, where I’m speaking on two panels—one on accreditation and the other on higher ed accountability. Stop by and say hello if you’ll be around.





