26 May Forward Thinking with Accreditation
Flexibility is the new critical skillset. The U.S. Department of Education guidance on “temporary flexibilities” for regional accrediting bodies in light of COVID-19 makes that clear. In short, the document outlines accommodations that accreditors could accept to facilitate rapid shifts to online course delivery and site visits in the age of social distancing. Yet, somehow it seems that pairing the words — “accreditor” and “flexibility” — prompted a broader discussion on many campuses. This article offers senior leaders four items to consider that will help better position them to be forward thinking with accreditation efforts.
Flexibility Doesn’t Mean Last on the To-Do List
The institutional ‘to-do’ list was long before COVID, and is even longer now. As we adapt to the many changes in our daily lives, it’s only natural to want to postpone overwhelming and complex priorities, such as accreditation. Accreditation, whatever part you may be responsible for, is no easy task – even on a good day – let alone during a pandemic.
Managing accreditation in these uncertain times has become even more difficult, which is really saying something. Accreditation liaisons at various points along the spectrum of reaffirmation are challenged further by the misunderstanding of the flexibility extended by accreditors. Broad interpretation by some has been taken to suggest that all accreditation processes are flexible and therefore not a priority for institutions in the midst of COVID-19.
That interpretation couldn’t be more wrong – or short-sighted.
Let’s Consider if We Postponed Accreditation Efforts
I get it. Everyone is extremely busy. The pandemic caught institutions off guard and priorities from three months ago aren’t even on the radar anymore. We all are shuffling things around.
But, before we put all of our accreditation activities on hold for an undetermined amount of time, let’s consider the risk/benefits equation for a moment.
What does the institution as a whole gain from this “put accreditation off until after the pandemic” approach?
- Appreciation and good will from those individuals involved across campus, who are facing the additional strain of navigating to new tools, pedagogies, and balances.
Comparatively, what do we jeopardize by putting accreditation on the back burner?
- Failing to collect required documentation.
- Processes slipping off track.
- Fostering a perception that compliance is flexible (which is a slippery slope).
- Telegraphing that accreditation is not an institutional priority.
- Potential legal considerations might arise from lack of compliance (resource).
Expectations are Still Expected
Yes, there is flexibility. But, it is important to understand that the DOE-sanctioned guidance, as well as guidance published by the regional accrediting bodies themselves, promotes temporary flexibility focused on accommodating rapid shifts to online delivery and revising site visit procedures. This flexibility is not a “get out of jail free” card for wholesale accreditation.
That’s not to say that accreditors aren’t sympathetic to the situation institutions are experiencing. Accrediting agencies designed the current flexibilities to help institutions respond to COVID-19. Short-term distance learning flexibilities are incredibly helpful to ensuring the continuance of student learning. But they do not negate other institutional expectations for accreditation. The need to move forward and focus on accreditation planning is becoming increasingly important. In the May 2020 CHEA newsletter, Judith Eaton, president of CHEA, noted “we need to move from an emergency action mindset to a mindset of creativity and innovation for the long term.”
A recent Education Dive article suggested the lack of guidance provided to institutions on how they should be tracking changes in their processes and policies “could prove problematic later on.” This is further evidenced by the results of a survey conducted by CHEA on priorities of accrediting bodies during COVID-19. The survey found while accreditors are focused on providing flexibility to meet institutional distance learning needs, expectations remain that institutions adhere to all standards and policies. Of the 47 organizations responding to the survey, 80% indicated they “are requiring that institutions or programs continue to meet our standards, even as they operate remotely.” This point can’t be emphasized enough — given these expectations, it is critically important that institutions not postpone their accreditation activities.
Four Accreditation Action Steps
So, what should institutions be thinking about to ensure future accreditation efforts aren’t jeopardized by current actions?
#1 – Distance Education Approval
Those “temporary flexibilities” offered by the DOE to facilitate the rapid transition to online learning currently have an expiration date of December 31, 2020. As HLC noted in its Temporary Emergency Policy Related to COVID-19 statement, “once the public health emergency is no longer present, institutions are required, no later than the end of the applicable academic term, to operate within the distance education stipulations that were in effect immediately preceding the issuance of the waiver.”
This sentiment is echoed, with slight variances, by the other regional accrediting bodies. So, have your faculty and students unexpectedly fallen in love with an academic program in a new online format? Is your campus community wondering if some changes can be permanent? Institutions without existing approval – when needed – who anticipate distance education lingering beyond the COVID-19 period would be well advised to begin preparing official requests for ongoing approval. Accrediting bodies have advised institutions to connect with your accreditor and ask for guidance.
Developing a proposal for distance education may be the last thing you have time for at the moment. But if you suspect that online learning has taken root at your institution, preparing the proposal now will prevent a mad scramble later. Continuing to offer distance education without formal approval once COVID-19 flexibilities expire could risk an institution’s accreditation status and require return of Title IV funding.
#2 – Documentation
A little documentation now will go a long way later. Institutions should document key decisions, process changes, and policy exceptions stemming from COVID-19 changes. In the midst of a global crisis, the rationale for significant and immediate changes was understood without explanation. If we jump ahead two years, odds are you’ll find yourself searching for documentation and contextual explanations to justify the changes that lingered in curriculum, delivery method, and student policies. So, take time now to document them. What might seem the least of your concerns now will quickly become a monumental challenge when your accreditation report due date is fast approaching.
On the bright side, what you take the time to document now will serve you well in a number of ways. What better evidence is there of the strength and resiliency of an institution? You can demonstrate that institutional processes are so strongly embedded and integrated in the culture that an event as significant as COVID-19 does not make them falter. This documentation becomes even more important as we consider changes likely to result from impending budget reductions, furloughs, and layoffs. As institutions are stretched financially and face uncertain budget situations, documentation is critical. Arguably, in this new scenario, accreditation is MORE important given the state of uncertainty facing many institutions. For what is accreditation but a review of what you do well and what you could do better?
These questions guide the fundamental concept of accreditation. And they provide a foundation for deeper institutional discussions about budgeting, program vitality, and resource allocation. Every decision made by an institution to implement new processes, policies, and procedures in response to COVID-19 is made to ensure safety and continuation of learning experiences. These actions represent an institution’s commitment to continuous improvement, even in trying circumstances. Failing to document these examples of institutional strength and commitment to students, faculty, and staff is a lost opportunity.
#3 – Assessment
Speaking of documentation and continuous improvement…Yes. Assessment cycles are expected to continue. Repeat ad nauseam in response to questions from campus constituents. This question has come up so much, accreditors have taken to adding it to their FAQs.
Of course, institutions will not be able to complete some assessments as anticipated this year. This is completely understandable to accreditors. In those situations, ask programs to document what they were and weren’t able to accomplish as planned. This is especially important for institutions with looming reaffirmations and/or undeveloped assessment processes.
#4 – Future Data Needs
While documenting what is happening now is critical, we must also think ahead and identify gaps or concerns likely to stem from institutional responses to COVID-19. Data and comparisons you relied on before may no longer be suited for illustrating your institutional compliance. Forward thinking prompts us to think bigger and broader. What if the metrics we’ve typically relied upon are no longer valid or available?
To this end, institutions should proactively conduct an audit of the data sources typically used as part of their accreditation reporting. For each source, consider potential roadblocks that may prevent you from collecting the data you need. For example, do you rely on a national survey to provide evidence of student engagement gains over time? Budget cuts could prohibit administration of the survey. Or your results could be limited due to online survey fatigue.
If such challenges will likely prevent you from collecting necessary data, you might develop an in-house survey. This would allow you to collect some related data points for use in reporting. Will budget cuts prevent you from participating in the Delaware Cost Study for faculty comparisons? Consider re-framing your analysis to rely on peer faculty data and instructional cost from IPEDS.
What happens to our retention and graduation rate trend data if our institutions are radically different in Fall 2020? Changes in delivery, housing, and social aspects will likely result in retention rates below typical expectations.
- Is it sufficient to simply put an asterisk next to the Fall 2020 retention rate as a reminder that this figure simply shouldn’t be compared to prior years?
- Or do we need to think bigger and take this opportunity to re-examine what student success looks like at our institutions?
- Sure, retention may be down. But perhaps a higher percentage of students who did return participated in undergraduate research than last year. Or maybe a higher number signed up to serve as peer mentors.
If our institutional scenarios are different, we need to think differently in contextualizing our institutional successes.
And Fall 2020 will likely be very different for most institutions, which prompts another data consideration. Those established peer institution comparisons and benchmarks you’ve used for years may no longer serve you well. Institutions that may have looked like yours last year may look completely different in Fall 2020. Some institutions may have closed. Others may remain partly or entirely online.
These types of comparisons often serve as a backbone for accreditation reports. It is important to take the time to think through the viability of these comparisons given the changes institutions are experiencing. Institutions may be better advantaged by using broader groupings, such as Carnegie Classification, for comparison rather than specific institutions due to the unprecedented changes taking place within institutions.
These suggestions provide some broad guidance for leaders to consider in planning ahead for successful accreditation reporting. You may wonder how to get started or think – “This makes sense, but now what?”
For more granular insights on the extent to which COVID-19-prompted changes might impact your accreditation reporting, spend some time skimming through your last reaffirmation report. Now, circle anything that makes you cringe. Especially if you think, “How are we going to do/show THAT if we’re providing distance education, using an abbreviated academic calendar, or hiring adjuncts?” Take time to identify and think through these potential issues now. It will save hours of time and stress as you prepare your next accreditation report.