December 18, 2009 « Outdated Approach by Department of Ed »
Here we go again!
For 30 years, reasonable minds in higher education have hammered nails into the coffin of seat time and the Carnegie Unit as measures of learning. Irrelevant to some venues and unreliable proxy to others, educators have pointed out that treating temporal measures of processes as evidence of learning outcomes and educational quality have been obviated by modern learning sciences and technology. Yet, so many still teach the way their great grand-professors taught.
Employing seat time as a proxy measure of educational quality worked, more-or-less, when higher education was a small niche market occupied by the smart and the rich. The stakes have changed. Twenty-first Century higher education is defined by multiple mass and niche markets, delivered to 80% of the ability curve. In 2010, the idea of seat time is vitiated by platforms and pedagogies, each driven by modern learning sciences, none of which were envisioned by the Victorian ideal of a Carnegie unit. Asynchronous online education now represents a significant and growing portion of the total credit award in higher education.
It is especially relevant to this Briefing to note that contemporary research, including the U.S. Department of Education’s own research, continues to find that online learning outcomes are equivalent or superior to those of comparable classroom-based education.
No argument here, right?
Enter the U.S. Department of Education's Inspector General with a chilling and we suspect sinister denouncement of the Higher Learning Commission of the North Central Association of Colleges and Schools (HLC). This week, the inspector recommended that the secretary of education go so far as to terminate the HLC's authority!
To quote Eric Kelderman in today’s (12/18/2009) Chronicle of Higher Education eLetter,
The unusual action is in response to the Office of Inspector General's examination of the commission's standards for measuring credit hours and program length . . . In a heavily redacted memorandum released on Thursday, Wanda A. Scott, an assistant inspector general, questioned the Higher Learning Commission's decision to approve accreditation of American InterContinental University, a for-profit college owned by the Career Education Corporation.
Consequential
This is not a minor issue. The behavior of the Inspector General's office raises questions about its ethical conduct. It certainly raises questions about the office's rationality and objectivity. It raises questions about the rights of college administrators to expect that federal bureaucrats will keep themselves apprised of modern scientific findings and will follow agreed-upon policy and regulations.
What position should colleges and universities take with respect to the behavior of a Janus-headed Department of Education?
On the one hand, the Department exhorts, even threatens schools to assess narrowly defined Level II (cognitive) learning as the only legitimate evidence of learning and institutional effectiveness. On the other hand, the Department's inspector general wants to terminate the authority of a regional accrediting body that is, if anything, too slow in aligning itself with good science, science that requires deemphasizing seat time in favor of more valid and useful measures of learning, institutional effectiveness, etc.
I urge you to read the inspector general's report. You will first notice that the report fails to meet reasonable standards for composition and logical flow, the kind of thing you would want in a freshman composition paper. Perhaps we should ignore this and focus only on the core issues. Yet, for some reason, I am not inclined to be that generous. I believe we have a right to expect that these "leaders" in higher education will set an example that rises above the standards of the institutions they find wanting. As one professor/reader reported in another venue, I would fail the inspector general's report on composition grounds alone. What should we say to Ms. Scott for producing unprofessional to say nothing of scientifically unsound recommendations?
Then there are policy issues. The inspector general's office has acted beyond its authority in ways that are neither consistent with its directives nor with common sense. This branch of the Department is overstepping and should be held accountable for its actions.
Finally, we have seen the sacrifice of logic and science in this recommendation. It is against these losses that we should speak out.
The inspector general issued a global criticism of HLC, questioning its right to exist, based on one exchange with one institution.
This is not rational, responsible behavior. Its is certainly not leadership.
Moreover, the HLC provided the facts and detailed analyses of the questionable institution's shortcomings that the inspector general then used against the HLC. How tacky!
From what I have been able to learn, the HLC listed several important shortcomings in the operating procedures of the institution it was accrediting. Following its own policy, the HLC gave the institution a short but reasonable period to time to address the shortcomings at which time it will revisit the issue and make a determination as to whether accreditation should remain in place. Assuming the HLC sticks with its commitments, does anyone see anything wrong with this approach? The HLC has its own policies and agreed upon practices to follow. Unlike the inspector general's office, the HLC appears to adhere to its agreements.
A Call to Action
The nation’s college presidents may consider speaking as one to denounce the behavior of the inspector general's office. A signature page in the New York times would not be an unreasonable action on their part.
I am not recommending a reflexive defense of the accrediting body or the educational institution in question. Accrediting bodies face serious challenges to relevance in the 21st Century. Some of them, the HLC most notable, was until recently working to become more relevant and useful to the challenges that face modern higher education. Additionally, the educational institution in question has a history of unresolved "quality" issues with accrediting bodies -- first SACS, now HLC. These problems and their resolution are between HLC and the institution; they should remain between them.
I am suggesting that call on the Department for guidance that is, first, logical (one doesn't generalize principles leading to governmental action from an 'n' of one) and, second, congruent with the last 50 years of learning sciences. Seat time is dead as a measure of educational quality.
I suspect that the Inspector General's office has ulterior motives in this action. We should attempt to learn them.
What do you think?
Robert W. Tucker
President & CEO
InterEd, Inc.
Reader Comments (3)
We all know that accreditation doesn't work very well, and we know that the US DOE OIG is overstepping its mandate. Nothing new here.
But what really intrigues me is the idea that "Virtually all of the learning sciences that underwrite modern educational methods and delivery methods did not exist in Carnegie’s time" and supercede such measures as "seat-time" and faculty qualifications.
I realize immediately that I am stepping off a pier into shark-infested waters when I admit that I have no knowledge of "learning sciences" and what body of knowing they encompass; and when I admit that my epistemological background as a constructivist makes it impossible for me to be a positivist (which I assume is necessary to be a "learning scientist").
Still, I want to hear more about Rasch's separability theorem, and the future of IRT -- if this is what is meant.
Obviously, if things are to change from "Bowler hat" days in HE, a new paradigm is necessary. Could it be the "learning sciences"?
Mr. Tucker,
An interesting point of view, I would ask that you follow up with your explanation to the following point:
Virtually (95%) all for-profit institutions of higher learning are accredited by HLC.
I'm trying to determine where I made this comment Tom. My guess is that it came from an early version of this Briefing, one made while we were still gathering evidence related to the Department of Education's actions.
Nonetheless, I think the 95% estimate is in the ballpark, especially so with respect to institutions that have been around long enough to demonstrate a little lasting power. The estimate is even more accurate, perhaps even conservative with respect to market share. On the other hand, my estimate may now or soon be high because of start-ups of the many retired Apollo executives who were lulled into a false sense of confidence by the Apollo magic; they think all they need do is replicate what seemed so easy inside Apollo. Most of these start-ups will be history in 36 months or less.
If you have more to suggest, let me know and I'll look at it. Meanwhile, here is an elaboration of my thinking.
When I contemplate all regionally accredited, degree-granting institutions, the HLC accredited schools that come immediately to mind include Apollo/UOP/WIU, DeVry/Keller, EDMC/Argosy, Capella, Career Education/AIU, National American, Grand Canyon, Walden, a handful of smaller names, and a growing list of wannabes (e.g., a start-up medical school in Colorado working on HLC accreditation. When I contemplate the other regionals, I think of Strayer (accredited with Middle States). A step down from there are a few successful and growing smaller institutions such as your school, TUI (now accredited with SACS, formerly with Middle States), which readers may not know is a spin-off and reorganization emerging from Touro. Then, there are the anomalies such as the small number of awkward for-profit shells run by state universities. The true management structure of these few institutions resembles for-profit in name only. Also, we have a few institutions that predominately serve the career school market with national accreditation but have mounted program(s) that have or are seeking regional accreditation (mostly HLC). I haven't tracked these institutions so long as their dominate programming is nationally accredited career education. Corinthian is an example of the latter. Finally, we have some for-profits limping along under DETC accreditation that are also working on securing regional accreditation. The last time I looked at these schools, all were seeking HLC accreditation.
The larger point of my 95% estimate is to call attention to the fact that the HLC, until its recent change in leadership, led the way in taking the risks necessary to encourage innovation in regionally accredited higher education. Other regionals, as they have since their inception, function largely as faculty employment guilds. Their idea of quality is defined by fundamental notions of conformity.
The HLC, on the other hand, has prospered under the culture of managed experimentation created in the 1970's under the leadership of Ted Manning. Ted was certain that higher education needed to innovate, and the sooner the better. In his early interactions with the University of Phoenix, Ted made it clear that his goal was to facilitate experimentation by accrediting innovative start-ups and then watching them closely . . . very closely. In time, Ted's influence on the HLC culture was assimilated and extended by his successor, Steve Crow, who oversaw and was a student of the rise of UOP, Capella, Argosy, National American, Walden, and other innovators, not all of them for-profits. It remains to be seen if the HLC will retain or abandon its culture of supporting divergence and innovation. As was the case with previous leadership, the new leadership faces a steep learning curve in coming to understand the growth and quality issues pertinent to each unique case of innovation. That said, initial indications are worrisome. The HLC may be re-joining the other accrediting bodies in defining quality in terms of conformity to structural and functional antiquity. If this tergiversation persists, it will be a loss for higher education. I would predict the exodus of some of the HLC's important but less visible innovators. HLC's ultimate position with respect to innovation is ultimately only a minor issue. Innovation travels in only one direction.
I hope this helps. Let me know if I have missed a growing for-profit presence under one of the other regionals.