Commonsense Bipartisan Accreditation Reform: Improving Quality and Accountability in Higher Education – American Enterprise Institute

Report on Reforming Higher Education Accreditation to Align with Sustainable Development Goals

Executive Summary

The United States’ federal oversight mechanism for higher education, known as the “program integrity triad,” is failing to adequately protect students and taxpayers. This report analyzes the systemic weaknesses within the accreditation process, a key pillar of this triad, and evaluates its misalignment with core principles of the Sustainable Development Goals (SDGs). The current framework frequently fails to hold institutions accountable for poor student outcomes, thereby undermining progress toward SDG 4 (Quality Education), SDG 8 (Decent Work and Economic Growth), SDG 10 (Reduced Inequalities), and SDG 16 (Peace, Justice and Strong Institutions). This report proposes a series of reforms to restructure the accreditation system, ensuring it serves as a reliable guarantor of quality, equity, and economic mobility.

Aligning Accreditation with SDG 4: Quality Education

The primary function of accreditation is to assure educational quality, a direct parallel to the objective of SDG 4 to “ensure inclusive and equitable quality education and promote lifelong learning opportunities for all.” However, the current system falls demonstrably short of this goal. A significant number of accredited institutions exhibit poor performance metrics, including low graduation rates and high student debt, yet maintain their accredited status. This indicates a systemic failure to enforce meaningful quality standards.

Key Failures in Upholding Quality Education

• Inadequate Focus on Outcomes: Many accrediting agencies permit institutions to remain in good standing despite low graduation rates and poor post-graduation earnings, directly contradicting the quality imperative of SDG 4. For example, 37 percent of accredited institutions have graduation rates below 50 percent.
• Lack of Rigorous Standards: Following a 2008 amendment to the Higher Education Act (HEA), the Department of Education was prohibited from prescribing specific student achievement standards for accreditors. This has resulted in a patchwork of inconsistent and often lenient standards, allowing institutions to define their own metrics for success and avoid accountability.
• Barriers to Lifelong Learning: An oversight gap exists for noncredit programs, which are often not included in an accreditor’s scope of review. As these programs are a growing component of lifelong learning (SDG 4), this lack of quality assurance exposes students to unvetted educational offerings and undermines the credibility of the institutions.

Addressing Economic and Social Disparities (SDG 8 & SDG 10)

A quality education system should be a catalyst for economic growth and a tool for reducing inequality. The failure of accreditation to ensure student success has profound negative implications for SDG 8 (Decent Work and Economic Growth) and SDG 10 (Reduced Inequalities).

Economic and Equity Implications

1. Undermining Decent Work and Economic Growth (SDG 8): When graduates of accredited programs earn less than high school graduates or are burdened with unmanageable debt, the higher education system fails to promote “full and productive employment and decent work for all.” Accreditors’ reluctance to sanction institutions with poor economic outcomes for students allows taxpayer funds to subsidize programs that do not lead to economic stability.
2. Masking and Perpetuating Inequality (SDG 10): The current system does not mandate the disaggregation of student outcome data by race, income, gender, or age. This lack of transparency makes it impossible to identify and address systemic inequities where certain student populations are being underserved. Without disaggregated data, accountability efforts cannot effectively target and reduce inequalities within the higher education system.

Strengthening Institutional Frameworks for Accountability (SDG 16)

SDG 16 calls for “effective, accountable and inclusive institutions at all levels.” The operational and structural flaws within the accreditation system represent a failure to meet this standard. Several barriers prevent accreditors from acting as effective and accountable oversight bodies.

Barriers to Effective and Accountable Institutions

• Weak and Inconsistent Enforcement: Data shows that accreditors rarely revoke accreditation. Between 2009 and 2014, only about 1 percent of all schools lost accreditation, indicating that sanctions are infrequent and often lack meaningful consequences.
• Structural Conflicts of Interest: Accreditors often operate as membership organizations funded by the institutions they oversee. Furthermore, a high percentage of agency commissioners have employment ties to an institution accredited by their agency, creating a conflict of interest that prioritizes institutional preservation over student protection and public accountability.
• Litigation Risk: The threat of costly lawsuits from institutions facing sanctions creates a “chilling effect,” discouraging accreditors from taking decisive action against underperforming colleges. This legal pressure undermines the enforcement of quality standards.

Recommendations for a Sustainable and Equitable Accreditation System

To realign the U.S. higher education system with the Sustainable Development Goals, a series of targeted reforms to the accreditation process is necessary. These reforms focus on establishing clear standards, enhancing transparency, and strengthening institutional integrity.

H3: Establish Clear, Baseline Standards for Student Outcomes

To meet the objectives of SDG 4 and SDG 8, Congress should amend the HEA to require that accreditors assess all institutions against federally defined baseline standards for student outcomes.

1. Define mandatory metrics such as completion rates, post-graduation earnings, and student loan repayment rates.
2. While allowing for mission-specific flexibility, ensure no institution receiving federal aid falls below this essential quality floor.

H3: Mandate Data Transparency to Advance Equity (SDG 10)

Accountability requires reliable and comprehensive data. Reforms should focus on data integrity and public reporting to identify and eliminate disparities.

• Require the use of reliable, publicly available federal data (e.g., College Scorecard) for evaluating student outcomes.
• Mandate that all student outcome data be disaggregated by race, income, gender, and age to make inequities visible and hold institutions accountable for serving all student populations.

H3: Reinforce Institutional Integrity and Enforcement (SDG 16)

To build more effective and accountable institutions, structural barriers to oversight must be removed.

1. Require Timely Action: Cap the maximum time an institution can be out of compliance with standards to two years or the length of its longest program.
2. Ensure Independent Governance: Strengthen conflict-of-interest rules to ensure public members on accrediting commissions are truly independent and unaffiliated with the institutions being overseen.
3. Provide Legal and Financial Support: Create a federal fund to support accreditors in litigation when they act in good faith to enforce standards, and provide statutory legal protections to shield them from retaliatory lawsuits.

H3: Expand Oversight to All Lifelong Learning Opportunities (SDG 4)

To fully align with SDG 4, quality assurance must extend to all educational offerings.

• Require accrediting agencies to include noncredit programs within their scope of recognition and review, assessing their curriculum, quality, and student outcomes.

Analysis of Sustainable Development Goals in the Article

1. Which SDGs are addressed or connected to the issues highlighted in the article?

   SDG 4: Quality Education

   • The article’s central theme is the failure of the US higher education accreditation system to ensure academic quality and protect students. It critiques institutions with poor student outcomes, such as low graduation rates and high debt, directly addressing the goal of providing inclusive and equitable quality education.

   SDG 10: Reduced Inequalities

   • The article advocates for disaggregating student outcome data by race, income, gender, and age. This recommendation is aimed at identifying and addressing disparities in educational outcomes among different student populations, which is a core component of reducing inequalities.

   SDG 16: Peace, Justice and Strong Institutions

   • The article extensively discusses the weaknesses of the “program integrity triad” (US Department of Education, states, and accreditors). It highlights issues like weak enforcement, structural conflicts of interest, fear of litigation, and a lack of accountability and transparency. These points directly relate to the goal of developing effective, accountable, and transparent institutions.

   SDG 8: Decent Work and Economic Growth

   • The analysis connects the quality of education to economic outcomes for graduates. It points out that graduates from low-performing programs often have weak earnings and unmanageable debt, which hinders their ability to secure decent work and achieve economic stability. The call to measure outcomes like earnings and loan repayment links educational quality to sustainable economic growth.

2. What specific targets under those SDGs can be identified based on the article’s content?

   SDG 4: Quality Education

   • Target 4.3: By 2030, ensure equal access for all women and men to affordable and quality technical, vocational and tertiary education, including university. The article’s focus on holding colleges accountable for poor outcomes (low graduation rates, high debt) is directly aimed at ensuring the “quality” aspect of tertiary education provided to students.
   • Target 4.4: By 2030, substantially increase the number of youth and adults who have relevant skills, including technical and vocational skills, for employment, decent jobs and entrepreneurship. The discussion on including noncredit programs in accreditation reviews and measuring outcomes like post-graduation earnings aligns with ensuring education provides relevant skills for employment.

   SDG 10: Reduced Inequalities

   • Target 10.3: Ensure equal opportunity and reduce inequalities of outcome… The article’s recommendation to “ensure student outcomes data are disaggregated and publicly reported to protect all students” is a direct strategy to achieve this target. By analyzing data broken down by race, income, and gender, institutions can be held “accountable for delivering equitable outcomes.”

   SDG 16: Peace, Justice and Strong Institutions

   • Target 16.6: Develop effective, accountable and transparent institutions at all levels. The entire article is a critique of the current accreditation system’s lack of effectiveness and accountability. Recommendations to set clear standards, require timely action from accreditors, and eliminate conflicts of interest are all aimed at building a more accountable and effective institutional framework for higher education oversight.

   SDG 8: Decent Work and Economic Growth

   • Target 8.6: By 2020, substantially reduce the proportion of youth not in employment, education or training. Although the target date has passed, the principle is relevant. The article addresses this by highlighting the problem of students leaving college with “no degree, low earnings, or unmanageable debt,” which prevents them from productively participating in the economy. Improving educational quality is presented as a way to ensure graduates are prepared for decent work.

3. Are there any indicators mentioned or implied in the article that can be used to measure progress towards the identified targets?

   Indicators for SDG 4 and SDG 8

   • Completion/Graduation Rates: The article explicitly mentions “low graduation rates” as a key problem, citing that “37 percent of accredited institutions have graduation rates below 50 percent.” This is a direct indicator of educational quality and attainment.
   • Post-Graduation Earnings: The text refers to “weak earnings” and notes that “graduates of low-performing programs often earn less than high school graduates.” This is a suggested metric to measure the economic value and relevance of the education provided.
   • Student Loan Repayment/Debt Levels: The article points to “high student debt” and “unmanageable debt” as signs of institutional failure. Student loan repayment rates are proposed as a measure of student success.
   • Job-Placement Rates: This is mentioned as a metric that “some [accreditors] require,” implying its use as an indicator of successful transition from education to employment.

   Indicators for SDG 10

   • Disaggregated Outcome Data: The article strongly recommends that all student outcome measures (completion, earnings, debt) be “disaggregated… by race, income, gender, or age.” This creates a set of indicators to measure equity and identify which student groups are being “left behind.”

   Indicators for SDG 16

   • Rate of Sanctions and Loss of Accreditation: The article uses data on how few institutions are sanctioned or lose accreditation as an indicator of “weak and inconsistent enforcement.” For example, it states that “only about 1 percent of all schools lost accreditation” despite compliance issues, implying that a more effective system would have a higher rate of enforcement against failing institutions.
   • Independence of Oversight Bodies: The article implies an indicator related to conflicts of interest, noting that “67 percent of agency commissioners have a potential conflict of interest.” Reducing this percentage would indicate progress toward a more independent and accountable institutional structure.

4. Create a table with three columns titled ‘SDGs, Targets and Indicators” to present the findings from analyzing the article.

   SDGs	Targets	Indicators
   SDG 4: Quality Education	4.3: Ensure equal access to affordable and quality tertiary education. 4.4: Increase the number of youth and adults with relevant skills for employment.	Completion and graduation rates Job-placement rates Inclusion and review of noncredit and vocational programs
   SDG 8: Decent Work and Economic Growth	8.6: Reduce the proportion of youth not in employment, education or training.	Post-graduation earnings levels (compared to a benchmark like high school graduates) Student loan repayment rates Levels of student debt upon graduation
   SDG 10: Reduced Inequalities	10.3: Ensure equal opportunity and reduce inequalities of outcome.	Student outcome data (completion, earnings, debt) disaggregated by race, income, gender, and age
   SDG 16: Peace, Justice and Strong Institutions	16.6: Develop effective, accountable and transparent institutions.	Rate of sanctions and accreditation removal for non-compliant institutions Percentage of public members on accrediting commissions without conflicts of interest Timeliness of enforcement actions against failing institutions

Source: aei.org