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A THESIS: Seth M. Porter The University of Alabama in Huntsville INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

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Page 1: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

 A THESIS: Seth M. PorterThe University of Alabama in Huntsville

INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

Page 2: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

OUTLINE Introduction Policy Theory: Literature Review Research Synthesis Methodology TRIAD: An Overview

o Higher Education Policyo Pre-1944o Post-1944

Accreditation: An Overviewo Historical Overviewo Structure & Processo Accreditation Governance

Accreditation Strengths & Weaknesseso Strengthso Weaknesses

The Proposalo Designo Implementationo Recommendations

References

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INTRODUCTION•Higher education accreditation is in need of reform.•The current form of accreditation was sufficient when low skilled and entry level jobs were easy to find and hold as they were for much of the 18th, 19th, and even early 20th centuries (Carnevale and Desrochers 2003). • However the economy evolved following WWII and particularly from the 1980’s forward from a labor based industrial economy, towards the global information economy centered on highly skilled technical careers. Carnevale and Descrochers (2003) describe the economic shift as a “dramatic switching point between the old blue-collar economy and the new knowledge economy” (4). And for individuals, states, and nations, economic competiveness depends on innovation and educational attainment on the macro level (Callan and Finney 2005, 206). • The economic shift is challenging for U.S. higher education as it faces new pressures in the 21st century, including, demographic changes enrollment patterns, rising cost, reduced state support, global competition, and a renewed focus on federal accountability measures

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INTRODUCTION• The proposal is focused on regional accreditation.• Chapter One is the literature review of the policy theory Libertarian Paternalism. • Chapter Two covers the research synthesis methodology of the policy proposal. • Chapter Three gives a brief introduction into the main accreditation policy actors titled the TRIAD, which is the Federal Government, State Government, and the Accrediting bodies. Chapter Three also provides a brief history of education policy and the changes in U.S. higher education. • Chapter Four gives a brief overview of the history of accreditation in U.S. higher education. Chapter Four also covers the accreditation structure and process, accreditation governance and an overview and analysis of the relationships between the three main policy actors involved known as the TRIAD. • Chapter Five covers the current strengths and weaknesses of U.S higher education accreditation.

• Chapter Six is the policy proposal. It gives a brief overview on the need for reform, and the libertarian paternalistic policy elements that guide the policy proposal. Chapter Six covers the design and implementation of the policy proposal.

Page 5: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

POLICY THEORY: LITERATURE REVIEW• Libertarian paternalism is a behavioral economics and public policy theory similar to asymmetrical paternalism (Camerer et al. 2003).• It argues that it is legitimate for institutions to create behavior while limiting restriction of individual freedom of choice (Thaler and Sunstein 2003).• Based on cognitive psychology and behavioral economics research showing that individual behavior and personal preference are often contradictory towards advantageous personal outcomes (Thaler and Sunstein 2003; Harkin 2006).

• Individuals often make choices that are not in their best interest for a number of reasons including information asymmetry; cognitive limitations; biases, cultural, religious, historical, or family beliefs; information overload; choice overload; availability heuristics; and apathy (Iyengar and Lepper 2000; Thaler and Sunstein 2003; Stone 2012; Kahneman 2013).

• The theory discards the economic notion of rational utility maximizer in the individual, and claims because of this rejection based on behavioral economic literature and cognitive psychology, individuals and institutions can be guided to improve services (Schlag 2010).

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POLICY THEORY: LITERATURE REVIEW• The design of libertarian paternalistic policy is termed Choice Architecture.• “Organization of the context in which people make decisions” (Thaler and Sunstein 2008)• Choice Architecture is also known as a nudge. • The theory attempts to nudge individuals or institutions into advantageous outcomes.

• E.G., Default setting in organ donation (Johnson and Goldstein 2003).

• Consider the difference in consent rates between two similar countries, Austria and Germany. In Germany, which uses an opt-in system, only 12 % give their consent; in Austria, which uses opt-out, nearly everyone, 99% does “(Thaler 2009).

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POLICY THEORY: LITERATURE REVIEW Critics:

Klein (2004) had a strong critique arguing that both Sunstein and Thaler are influenced by the status quo of paternal theory without considering libertarian literature or philosophy.

Becker and Posner (2007) argue that it restricts freedom of choice by enforcing paternalism under public policies designed by individuals who have the same limitation on bounded rationality.

Yanoff (2012) contends that it violates liberal principles, and is not distinct from paternal policy.

Public policy is not driven by complete individual choice, so the theory attempts to improve on and navigate in reality. Reality is the inevitability of policy mandates, so libertarian paternalism creates a choice architecture to improve public

policy when it is inevitable.

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RESEARCH SYNTHESIS METHODOLOGY

• A research synthesis is a qualitative research methodology in which multiple research studies are analyzed to summarize the outcomes of a specific research question (Gulmezoglu 2005).• The research synthesis is an environmental scan of 159 different sources.• All relevant literature, empirical peer-reviewed research, seminal monographs on accreditation, accountability, innovation, future of, and federal policy in higher education, government documents, reports, commissions, and research, think-tank policy reports, lobbyist policy reports, state higher education reports, higher education institutional reports, state websites, accrediting bodies websites, reports, and research literature, policy actors blogs, and subject specific popular literature e.g., The Chronicle of Higher Education.

• Timeline=1940-2016•Majority selected 2001-2016.

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RESEARCH SYNTHESIS METHODOLOGY

Accuracy•The information had to be accurate, reliable, correct, and from a respected source. It had to be supported by evidence, refereed when applicable, and verified by other sources or personal knowledge of content. •It also was required to be free of obvious bias and common grammatical mistakes.

Relevancy•The information had to be important to the specific research question and the relevant time frame.

Authority•The source of the information was required to be from an authority in the field. The author and publisher had to be qualified to write on the topic. •The author and organization credentials were required to be relevant to the topic and level of research.

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Source Type Criteria Check Percentage of Source

Peer reviewed AccuracyY

 36.3%

  RelevancyY

 

  AuthorityY

 

Policy Reports Accuracy Y 39.5%

  Relevancy Y

  Authority Y

Monographs Accuracy Y 12.9%

  Relevancy Y  

  Authority Y  

Popular Literature Accuracy Y 11.3%

  Relevancy Y  

  Authority Y/N  

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INFORMAL INTERVIEW The majority of the interview was not structured with formal questions; however, the beginning of the interview had three structured formal interview questions:

1. What do you see as the strengths of the current accreditation process?

2. What do you see as the weaknesses of the current accreditation process?

3. Tell me about your personal experience dealing with the accreditation process and the policy actors involved?

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RESEARCH SYNTHESIS METHODOLOGY Search Strategy:

• Exhaustive environmental scan of all relevant literature and resources.

• The process included using advanced searching techniques such as Boolean operators and keyword string theory, building blocks approach to literature analysis, pearl growing, controlled vocabulary and refined searching, data mining, and footnote chasing.

•Subject specific databases, Think-Tanks, Harvard Think-Tank Search Engine, Government Agencies, Accrediting Agencies.

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TRIAD: AN OVERVIEWFederal Government

Accrediting Agencies

State Government

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HIGHER EDUCATION POLICY Historically higher education policy was a responsibility reserved for the states.

However, there has been a progressive number of significant federal policies throughout the history of the United States.

The significant federal policies should be broken into two categories: Pre-1944 and Post-1944. The two different time periods are distinct arenas of federal influence in higher education and need to be treated as such.

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PRE-1944

1787

1862

1890

1914

1917

1933-

1938

The Northwest Ordinance

Morrill Land Grant Act

Morrill Land

Grant Act

Smith-Lever Act

Smith-Hughes

Act

New Deal Programs

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POST-19441944

1947

1958

1965

1981-

1983

1988-

1989

2001

2006

2008

G.I. Bill

Truman Commission

NDEA

HEA

National Commission on Excellence in Education

> A Nation at Risk

ESEA Reauthorization +

Charlottesville Education Summit

NCLB

Spellings Commission

HEOA

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ACCREDITATION: AN OVERVIEW For over a century accreditation has been the central tenement of accountability, quality assurance, and quality improvement in higher education (Wolff 2005).

Accreditation is a diverse, non-centralized and intricate system in U.S. higher education, much like U.S. higher education itself, and this non-centralized approach to higher education has created the greatest system of higher education in the world, with institutions with varied missions and strengths.

Because of the structure of higher education founded on competition, diversity, and the independence of institutions, accreditation has evolved in a unique tradition of accountability founded on self-regulation and volunteer peer review (Wolff 2005, 80).

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HISTORICAL OVERVIEW1885-

1895

1905-

1917

1936

1944

1952

1965

1983

1992

2011

Four regional agencies founded

“Certifying” or AccreditingStandards & Lists

Mission Based Accreditation

Abuse of G.I. Bill

Regional Accreditors given

recognition power

Accreditation tied to Title IV

Accountability Movement

Congress regulates Institution Initiatives

Credit Hour Regulations

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STRUCTURE & PROCESSRegional Accreditors

National Faith Related

National Career Related

Programmatic Accreditors

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REGIONAL ACCREDITORS• Higher Learning Commission• Western Association of Schools and Colleges and Colleges•Western Association of Schools, and Accrediting Commission for Community and Junior Colleges

•Middle States Commission on Higher Education• The New England Association of Schools and Colleges• Southern Association of Schools and Colleges• The Northwest Commission on Colleges and Universities (CHEA 2016).

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REQUIRED FEDERAL STANDARDS   1. Success with respect to student achievement (Standards may be established by the school and differ according to its mission.)

2. Curricula 3. Faculty 4. Facilities, equipment, and supplies 5. Fiscal and administrative capacity 6. Student support services 7. Recruiting and admissions practices 8. Measures of program length and objectives 9. Student complaints 10. Compliance with federal student aid program responsibilities (20 U.S.C. 1099b)

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PROCESS

2. Peer Review Site

visit

3. Peer Review Report

4. Agency Decision

1. Self-Evaluation

User
Need to add notes on proccess
Page 23: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

ACCREDITATION GOVERNANCE

Federal Government

Accrediting Agencies

State Government

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FEDERAL GOVERNMENT The U.S.D.E has the authority to recognize accrediting agencies. They do this through the National Advisory Committee on Institutional Quality and Integrity or NACIQI. The committee reviews accrediting agencies and makes recommendations to the Secretary of Education to recognize the accrediting agency.

The committee analyzes the standards of the accrediting agency for rigor and to see if they meet the standards of the U.S.D.E and are eligible to be an education authority. Following the review of the accrediting bodies’ standards and rigor, the NACIQI makes a recommendation to the Secretary of Education to either recognize or not to recognize the accrediting agency.

If the Secretary recognizes the accrediting agency the students enrolled in the institutions within the accrediting body are then eligible for more than $158 billion in federal funding annually (U.S. Department of Education 2016). To be recognized for accreditation is voluntary, but in reality an institution could not survive without the federal funding, and because of this incentive the federal government has vast influence in higher education accountability— including making changes in institutional planning and the curriculum.

Page 25: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

CREDIT HOUR Federal Accountability Increase• Carnegie Foundation definition = as “X contact hours of faculty-led instruction + Y hours of student work outside the classroom over Z weeks = N credit hours” (Craig 2015, 195).

• The final regulations established a federal definition of a credit hour (CHEA 2010).

•With this one stroke the federal government gained control over a vital piece of higher education curriculum and created more federal authority over accountability through higher education, and they did so through the accreditation process.

Page 26: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

ACCREDITING AGENCIES   The Council for Higher Education Accreditation is private non-governmental agency that advocates for self-regulation in higher education accountability through the process of accreditation (CHEA 2015). Essentially they represent and lobby for the different accrediting agencies; but CHEA also has the authority to recognize accrediting bodies.

They are the only nongovernment organization that has the authority to do so (CHEA 2015). Much like the U.S.D.E, CHEA creates criteria that must be met to be recognized. Unlike the U.S.D.E, CHEA’s emphasis is mainly on improved learning outcomes, quality assurance, and institutional improvement (Eaton 2012). But there is one key difference in the recognition process between CHEA and U.S.D.E, money. CHEA’s focus is on academic quality assurance, continuous improvement, and self-regulation of higher education accountability (Eaton 2012); while the U.S.D.E through NACIQI and the accreditation recognition process is focused on federal funding and accountability.

On the other hand many of their standards are similar. For example, they both determine whether an institution has quality academic programs, require select information to be made public, support improvement, and confirm financial stability of the institution (Gaston 2014, 16).Although they have many of the same goals the crucial difference comes back to funding. The recognition for accreditors by CHEA is not attached to eligibility for Title IV funding.

Page 27: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

STATE GOVERNMENT•Accountability has shifted from the states to the federal government

•Funding for higher education has increasingly dried up:

• Higher education is generally the largest discretionary item in states budget and they have continued to cut this budget line for that past 25 years with state funding to public institutions falling by 43 percent from 1990 to 2015— the federal role in accountability and accreditation has grown larger (Selingo 2013, 63; Farish 2016).

Page 28: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

STATE GOVERNMENT Due to this, accreditation essentially superseded states as the main drivers of assessment in the 1990’s (Ewell 2005).

Presently the relationship between state policy makers and accreditation in higher education is highly complex. For example, institutions must be accredited for operating permission within the states to receive federal funding (Burke 2005, 307). States can give institutions the authority to operate within their borders, but if they aspire to financial solvency they must obtain accreditation.

So even with state regulatory authority over institutional creation, the institutions and state policy makers must cede much of their authority to accrediting agencies and the U.S.D.E.

However, not all states have the same higher education responsibilities and regulations. As a result some institutions are then held accountable by restrictive state regulations as well as federal, and accrediting agencies, and some institutions by mainly federal and accrediting agencies (Studley 2012, 9).

Page 29: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

ACCREDITATION STRENGTHS & WEAKNESSES1) Efficiency: Efficiency is utilized through economic criteria. Specifically a cost-benefit

analysis of the accreditation process.

2) Effectiveness: Effectiveness is utilized to analyze the effect of accreditation on the institutions involved through improved institutional governance and learning outcomes.

3) Mission support of accreditation: Mission support of accreditation is utilized through an analysis of the stated goals of accrediting agencies mission compared towards their actions in the accrediting process.

4) Transparency: Transparency is utilized to analyze the accrediting agencies actions, results, and the process of communicating institutional quality assurance to the public.

 

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STRENGTHS

Enforced Accountabilit

y

Improved Transferabilit

y

Institutional Fraud

Regulation

Page 31: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

ENFORCED ACCOUNTABILITY

• The approval of a regional accreditor has some value as quality assurance to the public, such as, the institution has qualified faculty, financial stability, an appropriate curriculum, and mission driven processes (Gaston 2014).

• The process can also help diffuse best practices across higher education field identifying individual accomplishments (Gaston 2014).

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IMPROVED TRANSFERABILITY

• When transferring from one institution to another, the stamp of a regional accrediting body is usually the standard for accepting institutional credit. • In an environment with ever increasing costs to access higher education, transferability of previous credit is a value add to potential students and a key service of accreditation.

• Additionally, in significantly different demographic landscape of higher education than in the past, “only two in ten undergraduates attend a residential four year college full time” (Selingo 2013, 109); many students are collecting credits at multiple institutions on their way to completing a degree. • Therefore the quality assurance and the consistency of transferability is improved through accreditation.

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INSTITUTIONAL FRAUD REGULATIONThe institutional accountability for federal funding has greatly improved the non-proliferation of fraudulent institutions and diploma mills that was wide spread in the 1970’s and 1980’s before the regulations were put into place through reauthorizations of HEA (Gillen, Bennett, Vedder, 2010, 5).

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WEAKNESSESLimited

Transparency

Growing Federal

Influence

Cost Effectivenes

s

Standardized Institutional Framework

Radical Change in Higher Education

Suppresses Innovation

Limited Educational

Quality Assurance

Peer Review Problem

All or Nothing Accreditation

Page 35: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

LIMITED TRANSPARENCY

• The lack of transparency in the process and results of institutional accreditation leads to ineffective quality assurance to the public. As a consequence this creates information asymmetry between policy actors, the public, and the accreditors and institutions• Services are by their nature hard to define and they create information asymmetry; education is no different. Much like health care the consumer needs access to the product but cannot sufficiently judge the quality of the product (Zakaria 2015, 123).• Gatekeepers to federal funding and should be transparent.

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GROWING FEDERAL INFLUENCE

• Accountability focused policies has led to the “federalizing” of accreditation.

• Essentially, the federal government has continued to legislate requirements that accrediting agencies must follow to be recognized by the U.S.D.E.

• For example, the federal government has codified the definition of the academic credit hour, transfer of credit, distance learning, and enrollment growth (Eaton, 2011).

The federal codification of a historical higher education academic arena is a threat to institutional independence and a potential causal sequence towards homogenous institutions.

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COST EFFECTIVENESS

•Accreditation is extremely expensive for institutional compliance through direct and indirect costs. •The direct cost on institutional compliance through accreditation is on average over $300,000 over the ten year cycle, and for some of the larger research universities it is much higher (Woolston 2012). •For the entire community of higher education the cost is almost $700 million in direct cost, and some studies have it much higher. •For example, a study from Vanderbilt University claims that colleges and universities spend $27 billion on federal compliance, including $11.1 billion on regulations for regional and programmatic accreditation (Stratford 2015).)

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STANDARDIZED INSTITUTIONAL FRAMEWORK

•Accreditation is a one size fits all framework in a diverse landscape. A small regional public university has to hit the same metrics as a world class private liberal arts college. •A key tenant of regional accreditation is mission based institutional governance and goals, but their standard framework to measure all institutions does not align with this stated goal; and even the U.S.D.E has voiced their concern with the single framework for regional accreditation (Studley 2012).

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RADICAL CHANGE IN HIGHER EDUCATION

•When accreditation was founded it was created in the idea of matriculating 18 year olds to four year residential campuses. But this has changed. • The majority of students are part-time, community college, commuters, and online students (Selingo 2013). The demographics of the student body has also changed dramatically. Currently Hispanic and African American students comprise 27% of college students (Ewell 2015).

•The rise of online, blended programs, and additional avenues to learning like degree based MOOCs have created a paradigm shift in how students use information and obtain a college degree. Many take classes at multiple institutions, online colleges, and brick and mortar institutions with online programs (Ewell 2015). •The structure of the faculty has changed greatly as well. Adjunct faculty now make up more than one third of the teaching faculty across the country (Ewell 2015). The adjunct faculty with no real power in shared governance or institutional influence • This standard is on the U.S.D.E site, but not addressed.

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SUPPRESSES INNOVATION

• Creates a risk adverse culture• The current structure of regulating federal funding through recognition helps enforce a culture of non-innovation and experimentation in higher education because it could be a threat to their Title IV funding (Gillen, Bennett, Vedder, 2010, 20).

•Restricts international & Online Growth.• Accreditation restricts U.S. online higher education abroad, so this limits U.S. institutions from competing in that growing market (Craig 2015, 156).

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LIMITED EDUCATIONAL QUALITY ASSURANCE

• Minimal Educational Quality Assurance• For example, both the University of Phoenix with a 9 percent graduation rate for their

undergraduate degree programs, and Kaplan Colleges with a 69 percent dropout rate, are regionally accredited (Morgan 2011). • Many non-profit four year colleges have similar outcomes:• The University of District of Colombia 7.7 percent graduation rate• Louisiana State University- Alexandria 11.1 percent graduation rate

• Focus is mostly on financial stability:• A GAO analysis found that from October 2009 through March 2014, schools with weaker student

outcomes were, on average, no more likely to have been sanctioned by accreditors than schools with stronger student outcomes. Researchers have reported that assessing multiple student outcomes could shed light on the quality of education provided by schools. Such outcomes are characteristics that Education and researchers consider important indicators of educational quality, but which accreditors are not necessarily required to use. On the other hand, accreditors were more likely to have sanctioned schools with weaker financial characteristics than those with stronger ones. With regard to academic quality. (GAO-15-59, 1).

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PEER REVIEW PROBLEM

• Peer review is very rarely peer review. • For example, often small regional public universities or liberal arts colleges will review major international research institutions or vice versa. They have an understanding of how the different institutions operate but their expertise is in a different type of institutional administration. Because of this many institutions do not value the feedback unless it comes from a similar institution (Murray-Rust 2016).

• ‘you scratch my back and I’ll scratch yours’ (Ewell, 2008, 77). • Fraternal nature limits quality assurance and institutional improvement. • Status quo bias• The process is focused towards the reviewers’ understanding of what higher education is supposed to be and this can hinder innovation. This happens because the peer review team is usually made up of late career administrators who have a framework of what a successful institution should be doing and how it should be organized

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ALL OR NOTHING ACCREDITATION

•Binary outcome

• Institutions either obtain accreditation or they lose or get denied their accreditation, and losing accreditation is a death blow to institutions because of the loss of federal funding (Ewell 2015; Gillen, Bennett, Vedder, 2010). And because of this it rarely happens, and when it does 80 percent of the time the institution is for-profit (GAO-15-59).

• The mark of accreditation to differentiate two different institutions to the public is of little use when a for-profit institution like the University of Phoenix with a very low graduation rate has the same mark of quality assurance that the University of Arizona.

Page 44: Thesis: INNOVATIONS IN ACCOUNTABILITY AND HIGHER EDUCATION ACCREDITATION: A LIBERTARIAN PATERNALISM POLICY PROPOSAL

THE PROPOSAL

Innovations in Accountability and Higher Education

Accreditation: A Libertarian Paternalism Policy Proposal

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DESIGN•Accountability through accreditation in higher education is inevitable, and the federal government is not going to relinquish control of Title IV funding completely. For that reason libertarian paternalism is the appropriate theory to design the recommendations for higher education accreditation reform due to its choice architecture of driving choice through the creation of policies to guide individuals and institutions without controlling every step of the process and creating a paternal backlash. Much of the literature of libertarian paternalism illustrates the success of transparency and non-paternal policy structure, and this is aligned with the culture of higher education shared governance and democratic decision making. In •Libertarian paternalism argues it is legitimate to guide behavior because of cognitive limitations in individual and institutional decision making (Thaler and Sunstein 2003). However, the theory should be seen as a set of principles to guide policy design founded in choice architecture that nudges decision making while still allowing for individual freedom of choice whenever possible.

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Choice Architecture •The policy recommendations follows the libertarian paternalism theory of designing a set of advantageous choices for individuals or institutions, because individuals and institutions often make choices that are not in their best outcomes. •The policy recommendation follows this theory through mandated choice of carefully designed policies in multiple sections of the recommendation. Within the mandated choice the institution can opt-out

Inevitable Regulations •The policy recommendation follows the libertarian paternalism theory that some public policy decisions and regulations are inevitable. Careful choice architecture that implements inevitable policy but restricts paternal mandates and values freedom of choice is an important part of the theory and design. •Accountability in higher education is inevitable and through the implementation and proposal of the recommendation it reflects this core function of libertarian paternalism.

Default Policy Design •The policy recommendations will follow the theory of improved outcomes through default choice architecture in adoption of the policy implementation. •The choice architecture will nudge accrediting bodies and institutions into default adoption of the recommendation policy innovations, however, they can opt-out. This maintains freedom of choice but will improve accrediting outcomes through choice architecture

Transparency

•The policy recommendation is grounded in the libertarian paternalism tenement that encourages individuals or institutions to make choices transparent. •Transparency creates information symmetry and expands individual freedom of choice. Adopting the policy proposal will reflect libertarian paternalism through careful choice architecture of transparency in accreditation.

Simple Design

•The policy recommendation follows the theory of libertarian paternalism through simple design in the choice architecture. As detailed in the literature review information overload can affect cognitive decision making. The policy design recognizes this and keeps the proposal simple and easy to follow and implement.

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CHEA • The policy recommendation will be the standards adopted by CHEA• All accrediting agencies must meet the CHEA standards to be

recognized

NACIQI• NACIQI recommends to the secretary of education to adopt the

industry standard • NACIQI recommends to the secretary that CHEA has the sole power

to recognize accrediting agencies • NACIQI will recommend to the secretary that institutions that choose

to opt out of the CHEA standard can continue under the current accreditation process, but regulated by the federal government instead of the regional accreditors

U.S.D.E• The U.S.D.E impliments CHEA standards as the recognized

framework to access Title IV funding• The U.S.D.E still has general influence over acceditation through the

reccomendations of NACIQI but the framework was created non-paternally and implimented through democratic channels

• The policy is self-regulated through the market mechanisms with overarching control still in the hands of the U.S.D.E but no influence over institutional decision making and governance unless the institution opts out of the CHEA standard

Implemented following a reauthorization of the Higher Education Opportunity Act

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RECOMMENDATIONSHigher Education

Transparency Index

Common Purpose

Accreditation

Educational Continual

ImprovementDemocratic Peer Review

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HIGHER EDUCATION TRANSPARENCY INDEX

Transparency

All reports will be filed to the Higher Education Transparency Index database which will make available all relevant information about each institutions review to the public and all required information through this policy proposal. This will include the self-study, notes and reports from the peer-review process, financial audit, Continual Improvement Plan, Credits for Innovations—these will be detailed below— and any information relevant to the review including sanctions and probations.

Database

The database, much like SEC Edgar, will be searchable by institution name, state, and accrediting agency, tier level-grade, and institutional type. Each institution, and accrediting agency will be required to have a web presence and link to the Higher Education Transparency Index, with a tutorial on how to access and understand the information.

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COMMON PURPOSE ACCREDITATION

Diversity in Higher Education

• Throughout the policy literature the most common problem with regional accreditation is the standard framework for review and analysis regardless of the institutional type (Spellings 2006; Ewell 2015).

• Types: two year junior colleges, public regional universities, liberal arts colleges, private research universities, public research universities, specialized mission colleges such as historically black colleges, religiously affiliated institutions, for-profit institutions, vocational and technical colleges, arts colleges, single sex colleges—which may also be liberal arts or research universities.

Institutional Type

• The policy recommendation is to keep the regional accrediting organizations intact, but to have each regional accrediting agency be further divided into institutional type within the region. Doing so will make the accrediting agencies more flexible, and less standard; given that forcing every type of institution into one framework damages the diversity of higher education.

Change• If an institution desires

to change institution classification they will be reviewed under their desired classification so they can understand the framework and standards to meet. For example, if a small public regional university has ambitions to become major research institution, it will apply to its regional accreditor to be analyzed under that desired classification with full knowledge of the accreditation difference and potential areas that will be lacking if it moves into a different classification.

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EDUCATIONAL CONTINUAL IMPROVEMENT• Two simultaneous

goals, reaffirmation of accreditation, and improved institutional processes.

• The policy recommendation is for each regional to have institutions adopt a version the AQIP plan that is focused on continual improvements and can also meet the standards of the regional accreditors.

• Each regional can create the AQIP plan to match their agencies mission, history, and culture. It will be flexible and non-paternal. The only mandate is they must build it along the same standard vision with continual improvement at its core, and a focus on learning outcomes and institutional improvement.

• AQIP will create a process for Continual improvement and innovation.

The Academic

Quality Improvemen

t Program (AQIP)

Adoption of an AQIP

Regional focused

AQIP

Continual Improveme

nt

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DEMOCRATIC PEER REVIEW

Peer Review Outside Policy Actors

Creates Transparency &

Democratic Decision Making

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ECONOMICALLY EFFICIENT ACCREDITATION

Agencies Adopt their own Plan

Accrediting Agency Adopt AQIP of CBA

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TIERED ACCREDITATION A •The institution has completed the necessary review and has shown complete compliance to the standards as well as continual improvement within the institution and evident assessment of financial solvency and assessment and improvement in learning outcomes (CHEA 2016).

•The institution has a detailed, successful AQIP plan that fits its mission and learning outcomes.

B •The institution has completed the necessary review and shown complete compliance to the standards. The institution also has show evident assessment of financial solvency and institutional process for a desire for improved learning outcomes (CHEA 2016).•The institution has evidence of a AQIP plan.

C •The institution has not met one or more standards for accreditation and is given a warning (CHEA 2016.•The institution has little evidence of a AQIP plan.

D •The institution has not met one or more standards for accreditation and is put on probation (CHEA 2016). •The institution is asked to show cause order on why it should not have its accreditation withdrawn.

F •The institution has its accreditation withdrawn.

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CREDITS FOR INNOVATION•The policy recommendation is institutions that have their accreditation reaffirmed with ranking of an A or B will receive Credits for Innovation that they can spend with little regulation on new innovative education pedagogies, information delivery mechanisms, and program formats like innovation in distance education, adaptive learning, mining big data for learning patterns, personalized instruction through virtual reality, competency based learning, hybrid ideas, MOOCs with credit attached, stackable degrees through credentials, general education reform, and potential innovations that have not been discovered yet.

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A •Institutions that receive an A ranking will have Credits for Innovation that grants them complete institutional control over potential innovation with only one rule. The learning must be assessed and reported within the AQIP plan. The credit hour will not be measured. The Credits for Innovation is about improving higher education and not being attached to historical standards. •Each institution that receives an A ranking has four Credits for Innovation to use before the next reaffirmation. Each credit will be used by a different departmental program. Each institution will decide on which departments will receive the innovation credits through their own decision making process. The credit can be used in any way they see fit as long as it is related to institutional or programmatic innovation.

B •Institutions that receive a B ranking will follow the same process as institutions with an A ranking, however they have more accountability measures built in. Each institution with a B ranking will have four credits for innovation, but the historical credit hour will stay intact, each class must have a capstone project to measure learning outcomes, or if not a capstone project a proctored exam.

Incentive •While there are more rules for the credits for innovation with the B ranking institutions they will still have room for innovation, and it will also be an incentive to become an A ranking institution through the accreditation process; but it will not be forced, because they can still pass accreditation without earning credits. It is the institution’s choice to opt in or out by their own processes. Each institution must assess their innovative project and post the assessment and outline of the project on their portfolio in the Higher Education Transparency Index, so that successful projects can diffuse to other institutions. •Institutions that receive a C, D, or F will have more of an incentive to buy into accreditation because of the freedom of doing it successfully.

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