Statement of Jean Avnet Morse

Executive Director

Middle States Commission on Higher Education

on Behalf of the

Council of Regional Accrediting Commissions

(CRAC)

Before the

Committee on Education and the Workforce

Subcommittee on 21^st Century Competitiveness

United States House of Representatives

DIPLOMA MILLS

September 23, 2004

Mr. Chairman and Members of the Committee, I appreciate the opportunity to be here today to discuss the role of regional institutional accreditation in protecting the public against “diploma mills.”

THE ROLE OF REGIONAL AND OTHER ACCREDITORS

I head the Middle States Commission on Higher Education of the Middle States Association. The Commission has a membership of approximately 500 colleges and universities located in Delaware, Maryland, New Jersey, New York, Pennsylvania, the District of Columbia, Puerto Rico, and the U.S. Virgin Islands.

I am testifying on behalf of the Council of Regional Accrediting Commissions, known as C-RAC. It includes the seven U.S. regional accreditors that accredit over 3,000 institutions enrolling over 16,000,000 students. Regional accrediting agencies have assured the quality of higher education in the United States for over 100 years, providing self-regulation and shared assistance for improving education. For the past 50 years, these agencies have also served a unique role: when an agency is “recognized” by the U.S. Department of Education, the students of institutions accredited by that agency are eligible for federal grants and loans under Title IV of the Higher Education Act.

There are other types of accreditors.

Regional accreditors accredit entire institutions of all types, from community colleges through large research universities that are in their region. Specialized accreditors accredit specific programs, such as law or medicine. National accreditors usually accredit institutions of certain types. All three can be “recognized” by the U.S. Department of Education as Title IV “gatekeepers” and by the Council on Higher Education Accreditation, a private organization. There are also accreditors that are not recognized, either because they do not apply or do not meet the applicable requirements.

Regional accreditors are concerned about this issue and would support the efforts of the Congress, the U.S. Department of Education, state and federal enforcement agencies and others in addressing the problem.

DIPLOMA MILLS: WHAT ARE THEY AND WHOM DO THEY AFFECT?

Diploma mills are a growing problem. They affect students and employers in the U.S. and abroad. Setting up attractive websites is an easy lure. A 2002 study by the GAO documented that the federal government had hired applicants from degree mills and had paid for courses at degree mills for its employees.

According to some estimates, there are over 300 unaccredited universities operating, selling degrees for thousands of dollars, awarding as many as 500 Ph.D.s every month, and earning in the aggregate $200,000,000 per year [John Bear, “Diploma Mills,” University Business, March 2000]. Holders of fake degrees most frequently serve as teachers, police officers, counselors, medical administrators, expert witnesses and business managers [Alan Contreras, testimony to Senate Committee on Governmental Affairs, May 2004].

It is helpful to consider the different types of diploma mills, because they can be dealt with differently. The term has been applied to:

- Diplomas granted with no work by the student

- Diplomas granted without sufficient college-level course work that is normally required for a degree

- Good quality diplomas granted by institutions that are not accredited by a legitimate accreditor, so that it is difficult for the public to determine their quality. They may or may not be diploma mills.

- All on-line or other non-traditional degrees, regardless of whether they are granted by institutions accredited by legitimate accreditors, are sometimes labeled “diploma mills.” As discussed later, this is unfair to excellent institutions that deliver quality education through non-traditional means.

REGIONAL ACCREDITORS HAVE ASSURED THE QUALITY OF ACCREDITED INSTITUTIONS OF ALL TYPES

Regional accreditors can bring to the problem over 100 years’ experience in defining quality education, applying standards by using qualified peer reviewers, and changing as higher education has changed.

Regional accreditors have succeeded in assuring quality:

- We are experienced in applying standards to distance education, accelerated learning, proprietary institutions, and other “non-traditional” types of higher education. This is important because a few “bad apple” distance learning and other non-traditional providers may create the impression that none are good. In fact, many of the most innovative, practical, accessible, and effective providers are non-traditional, and it is important to use a quality control system that recognizes them. For example, Middle States accredits an institution that offers distance education to our troops here and abroad.

- I think it is fair to say that no diploma mills are accredited by one of the seven U.S. regional accreditors because of our high standards and careful processes. This is recognized by employers such as the federal government and others that require a degree from an accredited institution as a condition of employment.

It is safe to say that diploma mills arise from that subset of institutions that are not accredited by a U.S. Department of Education-recognized accrediting agency, but it is not accurate to say that all unaccredited institutions are diploma mills. To identify which institutions are diploma mills, each unaccredited institution would need to be examined individually.

HOW REGIONAL ACCREDITORS HAVE ADDRESSED DIPLOMA MILLS

Some of the ways that regional accreditation helps to prevent diploma mills include:

- Requiring all institutions to meet the high standards described later that would not be satisfied by a degree mill. This applies whether an institution is a community college or a large research university, whether its students are adults in continuing education programs or eighteen year-olds living on campus, and whether it delivers courses on-line or in accelerated format.

- Granting initial accreditation only to institutions that have been reviewed and visited multiple times by staff, by peers such as professors and presidents, and by consultants. Eligibility requirements include a legal charter to operate and grant degrees; approval of profiles and academic qualifications of all full-time, part-time and adjunct instructional staff; and review of all educational programs.

- Monitoring already accredited institutions regularly and following up on any problem areas.

- Publicizing the list of which institutions are accredited by regional accreditors, including on-line listings that are linked to other sources.

- Providing information to the general public about each accredited institution, including its history of accreditation actions. These actions may have required it to submit special reports or take other actions in specified areas such as finances or assessment of student learning.

- Considering all complaints about accredited institutions received from students, faculty, or others.

- Answering inquiries (which are frequent) about whether a specific institution is accredited, and by whom.

- Writing articles and giving presentations.

General “warning signs” of possible diploma mills have been published by the Council of Higher Education Accreditation. CHEA has also suggested general warning signs to identify the fake accreditors (“accreditation mills”) which allow an institution to say that it is accredited, even though its accreditor may not be reputable.

STANDARDS THAT ACCREDITED INSTITUTIONS MUST MEET

All regionally accredited institutions must prove that they meet all of an accreditor’s standards. These standards include:

- Integrity: this is a separate and very important accreditation standard; any violation can lead to disciplinary action

- Education for all students in oral and written communication, scientific and quantitative reasoning, critical analysis and reasoning, technological competency, and information literacy

- Assessment of the institution’s effectiveness and efficiency in light of its own mission

- Assessment of student learning

- Student support services

- Admissions policies with full disclosure and appropriate standards

- A curriculum with appropriate levels and coordination

- Long term planning linked to budgeting

- Financial data showing capacity to continue operations at an appropriate level

- Resources for learning appropriate to that institution, such as information technology, library, and buildings

- Appropriate governance structure

- Qualified faculty and administrators, and

- Evidence of long term strategic planning linked to assessment and budgeting.

CONTINUOUS MONITORING OF INSTITUTIONS

These standards are applied at many times. Accreditation is not just periodic reporting for compliance. It is a continuous process that emphasizes the institution’s capacity and plans for growth and improvement. This allows each institution to develop its own areas of expertise with help from the expert academics who consult with the institution about its processes and plans.

APPLICANT/CANDIDATE

It is extremely difficult to become accredited. This is one reason why institutions that are finally accredited do not lose accreditation immediately – they are already excellent institutions.

In order for a new institution to be accredited, it usually spends five years in pre-accreditation status. During this time, it is visited by consultants, staff, and teams of professional educators. The Commission must vote first to allow the institution to become a candidate, and then to grant it accreditation.

It is common for institutions to decide not to apply for accreditation once they understand the standards, or to withdraw from the process in order to avoid what they expect will be a negative decision. Even after it is accredited, the institution must submit its first full self-study within a shorter time period than accredited institutions.

SUBSTANTIVE CHANGES

The Commission reviews in advance certain “substantive changes” introduced by an institution, such as the introduction of a new degree level, offering new programs in distance learning, or opening branch campuses. Institutions are required to have prior approval before implementing these changes. Changes that are implemented but are not approved may endanger the accreditation of the entire institution.

FOLLOW-UP REPORTING AND VISITS

The accreditors monitor quality on an ongoing basis, using annual reports, news accounts, information provided by other accreditors or the U.S. Department of Education, complaints from students or other information to assure that an institution continues to meet accreditation standards. At any time, the Commission may impose on an institution requirements that it submit reports, have teams visit the institution, or even show cause why its accreditation should not be removed.

In Middle States, approximately 50% of institutions reviewed are asked for some type of follow-up. This means that institutions with problems are continuously monitored until the problem is solved.

ANNUAL REPORTING

All accredited institutions submit information annually. Such information includes financial data, as well as information on enrollment, graduation rates, faculty, and other areas.

FIVE YEAR COMPREHENSIVE REVIEW

In Middle States, an extensive report is submitted every five years. It must cover deficiencies noted during the previous comprehensive team evaluation, student learning, planning, and other areas. It is reviewed by the Commission, and the Commission votes on whether to continue accreditation, with or without conditions. Other regional accreditors require a similar review at the midterm of the comprehensive accreditation cycle.

COMPREHENSIVE REVIEW AND TEAM VISIT

Every 10 years in the Middle States Commission’s region (commissions vary in the periodicity of their comprehensive review from six to 10 years), an accredited institution spends two years gathering together all of its constituents to review itself in light of the Commission’s accreditation standards, and to determine what it should do to grow and improve, in addition to simply complying or minimally meeting accreditation standards. This process of self-review is called “self study.”

A team of peers such as professors and college presidents visits the campus to review the self-study, to comment on the institution’s plans, and to determine compliance with accreditation standards.

DISCIPLINARY ACTIONS

Institutions with serious problems may be placed on warning, probation, or “show cause.” Failure to cure the problems can result in removal of accreditation. Most commonly, problems are caught early and are corrected before this is necessary.

FEDERAL REGULATION OF REGIONAL ACCREDITORS

Under the Higher Education Act and regulations promulgated by the U.S. Department of Education to implement the Act, accrediting agencies must be recognized by the U.S. Secretary of Education of the Department after review by the National Advisory Committee on Institutional Quality and Integrity (NACIQI) in order to qualify as “gatekeepers” for funding under Title IV. Such recognition enables the students of institutions accredited by the gatekeeping accreditor to receive certain federal loans and grants.

The Department reviews regional accreditors at least every five years. The accreditor submits a petition that is reviewed by an assigned member of the U.S. Department of Education. The accreditor has an opportunity to respond to the Department’s analysis, and also to present its case at a NACIQI hearing. The NACIQI recommendation to the Secretary is based on the agency’s petition, its interview, the staff analysis, and any third party comments and agency rebuttals.

In order to be recognized, the regional accreditor must demonstrate compliance with federal regulations, a few of which are that the accreditor:

- has standards that are widely accepted in the U.S. by educators, licensing bodies, employers, practitioners, and others

- has accreditation as its principal purpose

- has voluntary members

- is not controlled by another body

- has the administrative and fiscal capability to carry out its activities

- uses qualified persons, including public members

- has controls against conflicts of interest

- maintains records

- has standards for accreditation that address the areas described earlier, including “success with respect to student achievement”

- has effective mechanisms to evaluate whether an institution complies with its standards, including requiring the institution to undergo the “self-study” process described earlier

- conducts on-site reviews

- demonstrates consistency in its decisions

- reviews its standards periodically

- maintains appropriate operating procedures

- monitors substantive changes such as branch campuses, changes in ownership, and teach-out agreements

- gives appropriate notification of its decisions, and

- does not accredit institutions that lack legal authority or is in disciplinary proceedings by a state or another accreditor.

POSSIBLE APPROACHES TO CONTROLLING DIPLOMA MILLS

Past attempts to prevent diploma mills, additional suggestions made to the Senate Committee on Governmental Affairs in May 2004, and suggestions from C-RAC offer possible approaches:

A national listing of all institutions that have been approved by an accrediting agency recognized by the U.S. Department of Education on a public website would provide a simple, straightforward way for the public to determine whether or not an institution has been the subject of a comprehensive outside review of its academic programs.

Usually only serious, legitimate institutions will go through the trouble of being accredited by an agency approved by the U.S. Secretary of Education.

As noted earlier, each regional accreditor publishes on-line a list of all of the institutions that it accredits, together with information about the institution and its accreditation history. These sites are linked to each other, and through the Council of Higher Education Accreditation’s listings. The websites of the regional accreditors receive frequent “hits” on the directory listings.

A national list of all of the 6,200 schools that are accredited by one of the approximately 40 regional, specialized, and national accrediting agencies that the Secretary recognizes was recently given by The American Council on Education to the Department of Education to enable federal agencies to identify legitimate colleges, universities and trade schools when federal employees seek to enroll in taxpayer funded education and training.

Such a national list might have a much broader use if it were publicized widely and accessibly. It might link to the websites of regional accreditors for additional information on the accreditation history of the institution. Congress and the Department might look into ways to make such a list widely available.

The FBI initiative of the 1980s by agent Allen Ezell in closing down several degree mills could be renewed. Evidence from the IRS and postal service was often useful.

States can prosecute fraud and can pass special legislation. According to Alan Contreras, Oregon law requires users of fake or substandard degrees to cease using them. The law applies to any employment within the state, regardless of the location of the employer. Both the institution and students who knowingly use a fake degree may be liable.

State licensing requirements could be raised and coordinated. They vary enormously, and states with more lax requirements are used by diploma mills to obtain their charters to grant diplomas.

The FTC is authorized to regulate the use of the word “accredited.”

Protection against litigation by diploma mills is needed. This is a serious problem for those who have identified specific institutions as diploma mills or have refused to accept their degrees as qualifications for employment, and have been forced to defend themselves in expensive litigation.

Advertising boycotts by legitimate institutions against media that advertise degree mills has been suggested by John Bear.

Mr. Contreras has suggested that the U.S. Department of Education establish standards for use of degrees as credentials for employment that require degrees to be from: a U.S. institution accredited by a federally recognized accreditor; a U.S. institution approved by USDE; or a foreign institution found by USDE to use similar standards. The Oregon standards address faculty qualifications, program length, content of curriculum, requirements for the award of credit, and admissions standards. Additional standards would apply to foreign providers.

One suggestion discussed has been to require the U.S. Department of Education to maintain a list of diploma mills.

There are also private websites that list degree mills, but these are voluntary and informal.

The above suggestions would assist in determining the quality of alleged diploma mills. Thank you for the opportunity to discuss these issues. I would be happy to answer any questions you have.

---

Top