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Contents:
  1. Rutgers University Press
  2. Making Reform Work The Case for Transforming American Higher Education
  3. In this Book
  4. Quality Assurance in U.S. Higher Education

Rutgers University Press

When implemented effectively, such a management-based approach weeds out the poorest performers, while motivating and facilitating other institutions to reexamine and improve their processes and results continuously. We draw examples from management-based quality assurance systems in other sectors and countries to illustrate features like the combined assessment of standardized outcomes and program-defined outcomes; monitoring of targeted quality improvement plans; frequent interaction between regulators and providers; and differentiated reviews, consequences, and ratings.

Applying a management-based approach to U. Many of these are subtle variations on the existing system, in some cases consistent with reforms already being piloted by accreditors; some are more significant departures. In general, our view is that the basic infrastructure of our current system of accreditation is consistent with a management-based approach.

Making Reform Work The Case for Transforming American Higher Education

Mainly what is needed are some changes to the focus, standards, and timing of review, and to consequences and reporting, as well as a more streamlined initial approval process. Notwithstanding their apparent modesty, the changes we suggest have the potential to open the door wider to innovative providers, while doing a better job than the current system of ensuring minimum standards and promoting ongoing improvement in quality.

Importantly, these design principles. Importantly, these design principles—and our broader focus on management-based quality assurance—are grounded in a theory of change that views institutional learning as the primary mechanism for sustained improvement. The goal of the process is not merely to ensure that minimum standards are met, or to enforce program designs and practices that fit a particular image of what postsecondary education should look like.

The paper proceeds as follows. We begin with an overview of the accreditation system and other quality assurance mechanisms for higher education in the United States, including their history, processes, and shortcomings. We review how some recent efforts to improve quality assurance that emphasize performance-based assessment have sought to overcome some of these shortcomings, but, ultimately, poorly accommodate institutional diversity and do little to support improvement.

We then introduce management-based regulation and offer a number of examples from the U. Drawing on these examples, we conclude by elaborating on our broad design principles for reforming the higher education quality assurance system in the U. S to make it more rigorous, consistent, and supportive of innovation and improvement.

More than 7, institutions of higher education exist in the United States today. Recognizing this diversity, government has historically taken a flexible approach to the regulation of higher education. Although states have sometimes been more prescriptive of the methods and processes by which institutions particularly public higher education institutions must operate, in general, higher education institutions have been given the flexibility to set their own goals and determine the methods by which they will achieve them.

The Higher Education Act of HEA , the law that created the current federal system of higher education finance, does not prescribe how institutions should teach, research, or provide service to the community. Accreditation has been around for more than a century.

In this Book

Before World War II, accreditation was a fully non-governmental initiative that provided a process for institutions to assess themselves, and it also served as a basis upon which institutions would allow students to transfer from one to another. Since the s, accreditation has taken on a second, somewhat conflicting, responsibility of assuring the government of institutional quality control.

Non-governmental accreditors help the federal government by certifying that institutions are worthy of participation in higher education financial programs. For example, the American Bar Association accredits schools of law. With some meaningful exceptions in the areas of finance and safety, where accrediting entities must follow federally prescribed inspection procedures, the regulation of higher education is flexible. Institutions set their own goals and measures that indicate progress toward them.

The initial accreditation process for a new institution is especially detailed—some would argue overly burdensome—and can take between five and ten years to complete. After initial accreditation, for most institutions, re-accreditation happens every ten years usually with a mid-term check on their operations, providing an opportunity for them to update their goals and methods and to work with a third party to evaluate themselves.


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Academic priorities are established internally, and institutions themselves assess whether they are successfully pursuing them. Supporters argue that the flexibility of the accreditation system allows it to be responsive to the diversity of higher education: the numerous different academic programs at different kinds of institutions that serve different kinds of students.

Despite this flexibility, if an accreditor finds that the organization has not met the basic requirements of financial stability and academic rigor, the institution is no longer eligible to participate in federal financial aid programs this happens rarely. For almost every institution, removal of an accreditation would be a death knell, so they work hard to ensure this does not happen. Because of the Title IV requirement that an institution be accredited in order for its students to receive federal financial aid, the federal government plays a large role in the higher education regulatory system.

But states also play a meaningful role. Every institution must receive approval by their home state to operate, and an institution cannot receive funding without this approval. Many states have significant requirements such as proof of financial ability and a sound curricular program that institutions must meet to be approved, and most provide meaningful financial oversight of approved institutions. However, few states require that approved institutions meet academic benchmarks, and most have not have taken action against low-quality institutions.

This system has brought increasing complaints over the years. First, critics argue that the accreditation system has few teeth.

Institutions only need to share their plans with the third-party accreditor, and are not required to submit it to the government regulator. They are also not required to implement their plans, and there are no penalties if, for example, at reaccreditation the institution has not implemented the plans it established a decade before.

Accreditation decisions are enforced on a binary scale reaccredited or not reaccredited , and almost every institution is reaccredited, whether they are doing well or poorly. This lack of differentiation makes it difficult for students and regulators to determine which institutions provide a quality education and which ones should be avoided. Additionally, accreditation decisions are enforced on a binary scale reaccredited or not reaccredited , and almost every institution is reaccredited, whether they are doing well or poorly.

Critics also argue that, since an institution meeting minimum requirements gets the same access to funds as a high-performing one, this approach does not give incentives for institutions to improve. Department of Education ED to approve accreditors. While infrequent, this process is burdensome and costly, requiring the institution to dedicate thousands of person-hours and hundreds of pages to respond to self-study prompts and document requests.

Quality Assurance in U.S. Higher Education

Yet critics contend that the process still does little to help institutions improve processes or student academic outcomes. Over the past decade, policy makers have increasingly questioned the value of accreditation in the federal financial aid system.

A report by a commission appointed by then-Secretary of Education Margaret Spellings argued that accreditors needed to push institutions to focus more on student academic outcomes and that the system should be more transparent and accountable to public concerns. Critics also argue that accreditation serves as a barrier to entry for innovative new educational approaches.

Many argue that this approach, which calculates the total number of credits received using the number of hours the student is expected to spend in class, does not measure actual student learning. With some exceptions in experimental initiatives, competency-based approaches have struggled to achieve accreditation, and have not been able to compete for students desirous of financial support.

Federal regulations impose barriers to innovation, but critics also argue that accreditors themselves, which rely on volunteers from established institutions, also serve as obstacles to new approaches…. Federal regulations impose barriers to innovation, but critics also argue that accreditors themselves, which rely on volunteers from established institutions, also serve as obstacles to new approaches, and might be more open to innovation if experts from industry or other educational organizations were included in review.

Concerns about outcomes and efficiency often lead regulators to consider performance-based reforms. Performance-based approaches to regulation rely on measurable proxies of the desired outcomes to evaluate the regulated entity. This section describes some of the performance-based approaches to regulation and quality assurance that institutions and their regulators have adopted over the past decade.

It focuses, in particular, on the obstacles the Obama Administration faced in implementing an outcomes-based college rankings and federal financing system as indicative of the larger challenges inherent in using a performance-based quality assurance system for such a heterogeneous sector. At the same time, these efforts have pushed the debate around norms of transparency and coordination in quality assurance, laying the groundwork for potential future reforms that rely on common data and definitions.

Similarly, in , the American Association of Community Colleges launched the Voluntary Framework for Accountability VFA , which defines metrics for community-college-specific outcomes such as term-to-term retention rates, share of students who start in developmental courses, progress towards college level work, and data on transfers. The primary purpose of the data is to help institutions better understand how well they are serving their students, but the system was also designed to provide information to policymakers and the public.

These voluntary efforts have been accompanied by an increasing focus on outcomes in state-funding. Historically, states have allocated appropriations to higher education based on student enrollments. PBF models incentivize universities to achieve specific policy objectives based on the percentage of state funding that is appropriated to accomplish those objectives.

Currently, twenty-six states have PBF policies for their publicly-funded institutions, and many other states are considering this approach. Most PBF policies tend to emphasize outcomes such as graduation rates and retention rates, but states include many different objectives in their regulations. In Tennessee, the law rewards institutions that increase graduation rates overall and among selected groups that tend to graduate at lower rates.

As a result, to date, the impact of such approaches has been mixed, and studies have found only small changes in outcomes in states with this approach. In addition, some studies have found that PBF policies produce unintended consequences such as greater restrictions on student admissions, which lead to a decrease in the diversity of student populations.

While regional accreditors have not used statistical outcome measures or minimum standards for accreditation, most national and programmatic accreditors set threshold requirements for metrics like completion rates, exam pass rates, and employment rates. And some have incorporated assessments of more broadly defined competencies into accreditation—though not without pushback. For example, in a redesign, the Western Association of Schools and Colleges WASC incorporated into their standards a set of core competencies in five skill areas. The redesign effort was pared back after leaders at many institutions argued that the use of a common framework would lead to homogenization and increase the burden of compliance.

At the federal level, the Obama Administration undertook several performance-based reforms in the higher education sector. This rule responded to criticisms that too many students at for-profits schools take on unsustainable debt in exchange for degrees and certificates that carry limited value in the job market. Under the gainful employment regulations, programs whose graduates have annual loan payments greater than 12 percent of total earnings and greater than 30 percent of discretionary earnings in two out of any three consecutive years are no longer eligible for federal student aid for a minimum of three years.

In January , the Department of Education released data showing that more than programs had failed to meet accountability standards for the gainful employment rule. Ninety-eight percent of these programs were offered by for-profit institutions. The original rules were declared invalid by a federal district court, but so far, the revised rules have withstood legal attack.


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The Obama Administration also increased its enforcement activities against institutions in financial distress. And, in , the Department terminated its recognition of the Accrediting Council for Independent Colleges and Schools, which accredited institutions, most of which were for-profit including several Corinthian Colleges locations. Finally, the Obama Administration tried to promote transparency in the sector by providing more information to students and their families.


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The plan was to use these ratings to inform the allocation of federal funding, including financial aid, to institutions. The tortured development of this effort—and its ultimate outcome—is indicative of the challenges involved in performance-based regulatory approach for the higher education sector. Although the Obama Administration claimed that the proposal would distinguish among different types of schools, higher education leaders and their lobbyists expressed concerns that such a proposal would further exacerbate the divide between the elite schools—where students from mostly wealthy backgrounds graduate at high rates and secure well-paying employment—and the many institutions that provide open access and have lower graduation and employment outcomes.

Higher education leaders also questioned the ability of the government to gather and manage accurate data on these complicated factors. In the summer of , after more than two years of discussions with higher education institutions, educational advocates, and congressional leaders, the administration pivoted away from the idea of creating a rating system. Performance-based regulation reinforces—intentionally—competition among higher education institutions, exacerbating incentives for institutions to keep effective practices to themselves.

The college rating saga revealed both the growing push for outcome related transparency and accountability, as well as challenges inherent in performance-based regulation. Even if there is a general consensus on aspirations like accessibility, affordability, and quality, defining those goals concretely, measuring them meaningfully, and then applying them uniformly to the highly heterogeneous world of higher education creates its own kinds of problems—both technical and political.

Furthermore, absent oversight of process, institutions may seek to game a narrow set of high-stakes outcome metrics, while failing to advance the underlying goals for which they are a measurable proxy, or undermining other goals not captured by the metrics like broad and equitable access to higher education. Finally, performance-based regulation reinforces—intentionally—competition among higher education institutions, exacerbating incentives for institutions to keep effective practices to themselves. Across a number of domains, management-based regulation has emerged as a viable alternative to both input-focused, bureaucratic approaches and outcome-focused, performance-based approaches.

In a management-based system, the regulator establishes some threshold common metrics as well as a requirement that the regulated entities develop their own outcome targets and plans for achieving them. Oversight is focused on how the regulated entities have carried out their plans, progressed toward the self-determined targets, and achieved the common metrics.

Repeated failure to meet the targets, follow-through, or revise the plan can have more-significant consequences. Management-based regulation is grounded in the idea that regulation should reinforce organizational learning by the regulated entity.