Revised Regulations on Accreditation (and Astrology)

The Department of Education just released its new revision of accreditation regulations. You can find the changes and commentary here. I'm most interested in the assessment standards, which seem not to have changed much. You can find them in sections 602.16 (general student achievement) and 602.17 (program outcomes). Here's a summary comment about the changes for the latter.

Application of Standards in Reaching an Accrediting Decision (§ 602.17)

Comments: One commenter opposed the changes to § 602.17, arguing that the Department has made the requirements an agency must meet when applying its standards to accreditation decisions less rigorous. The commenter argued that the Department has failed to provide adequate justification for the proposed changes. 

Discussion: These regulations remain largely unchanged with respect to the requirements an agency must meet when applying its standards to accreditation decisions. We are revising the requirements of § 602.17(a)(3) to provide for the consideration of academic standards that are equivalent to those that are commonly accepted to facilitate the implementation and evaluation of pilot programs. The negotiators recognized that flexibility was required to allow agencies to consider their standards through a lens that fosters innovation, and we reiterate that this alternative approach is not a less rigorous approach.

And here's the new language for that section that applies to programs. It seems to be unchanged with respect to program objectives.

§ 602.17 Application of standards in reaching accreditation decisions.

The agency must have effective mechanisms for evaluating an institution's or program's compliance with the agency's standards before reaching a decision to accredit or preaccredit the institution or program. The agency meets this requirement if the agency demonstrates that it— 

(a) Evaluates whether an institution or program— 

(1) Maintains clearly specified educational objectives that are consistent with its mission and appropriate in light of the degrees or certificates awarded; 

(2) Is successful in achieving its stated objectives at both the institutional and program levels; and 

(3) Maintains requirements that at least conform to commonly accepted academic standards, or the equivalent, including pilot programs in § 602.18(b);

This regulation leaves most of the responsibility for quality in the hands of the accreditor. Notice that the agency must have effective mechanisms not for determining whether something is true or not, but in determining whether or not it meets agency standards. If those standards are out of touch with reality, as is the case with student learning assessment, there is no corrective mechanism. Agencies just have to evaluate the items on the list and see if they conform to their internal standards.

Aside from assessment, this seems to work well. For example, if a team reviews faculty credentials to see if they appear to be qualified to teach their courses, there's grounding in the lived experience of the team members, plus some general rules like "a terminal degree in the field is enough for undergraduate courses." When reviewing financial standards, the reviewers are CFOs who have direct experience with the reality of having enough money or not enough money, and there are professional organizations like NACUBO and specialized ones (e.g. accountancy) to keep reviewers tethered to reality.

But assessment of learning for accreditation has created a self-sustaining culture of practice and review that is related to reality in the same way that astrology is--reality provides symbols that are used within an ideology, with arcane language to fool outsiders into thinking that there's something empirical going on. Mostly there is not. Given the cost of assessment offices, consultants, and software for SLO bookkeeping, it would be cheaper and more effective to use astrologers to identify program improvements.

For example, at astrology.com we find today's outlook for a Taurus:

NOV 1, 2019: Your heart and soul need exposure to a higher level of art. Take a chance and turn the dial to the classical station for the day. Let your mind process music in a new way. Visual art will be very stimulating, and your aesthetic sensibilities are tightly in tune with your intellect. If you widen your creative interests, you'll increase your curiosity for sophisticated things.

This is a sign that the conditions are good to develop students's learning outcome of "Artistic Appreciation" or "Creative Thinking" or "Lifelong Learning."  There is just as much evidence for this as can be found in 90%+ of assessment reports, which rely on tiny samples of noisy data and call it measurement. The two methods are equally remote from what we might call objective reality, but the astrology method is much cheaper and more efficient than the methods preached by assessment's orthodoxy.