[House Hearing, 115 Congress] [From the U.S. Government Publishing Office] STRENGTHENING ACCREDITATION TO BETTER PROTECT STUDENTS AND TAXPAYERS ======================================================================= HEARING BEFORE THE COMMITTEE ON EDUCATION AND THE WORKFORCE U.S. HOUSE OF REPRESENTATIVES ONE HUNDRED FIFTEENTH CONGRESS FIRST SESSION __________ HEARING HELD IN WASHINGTON, DC, APRIL 27, 2017 __________ Serial No. 115-14 __________ Printed for the use of the Committee on Education and the Workforce [GRAPHIC NOT AVAILABLE IN TIFF FORMAT] Available via the World Wide Web: www.gpo.gov/fdsys/browse/ committee.action?chamber=house&committee=education or Committee address: http://edworkforce.house.gov __________ U.S. GOVERNMENT PUBLISHING OFFICE 25-136 PDF WASHINGTON : 2017 ---------------------------------------------------------------------------------------- For sale by the Superintendent of Documents, U.S. Government Publishing Office, http://bookstore.gpo.gov. For more information, contact the GPO Customer Contact Center, U.S. Government Publishing Office. Phone 202-512-1800, or 866-512-1800 (toll-free). E-mail, [email protected]. COMMITTEE ON EDUCATION AND THE WORKFORCE VIRGINIA FOXX, North Carolina, Chairwoman Joe Wilson, South Carolina Robert C. ``Bobby'' Scott, Duncan Hunter, California Virginia David P. Roe, Tennessee Ranking Member Glenn ``GT'' Thompson, Pennsylvania Susan A. Davis, California Tim Walberg, Michigan Raul M. Grijalva, Arizona Brett Guthrie, Kentucky Joe Courtney, Connecticut Todd Rokita, Indiana Marcia L. Fudge, Ohio Lou Barletta, Pennsylvania Jared Polis, Colorado Luke Messer, Indiana Gregorio Kilili Camacho Sablan, Bradley Byrne, Alabama Northern Mariana Islands David Brat, Virginia Frederica S. Wilson, Florida Glenn Grothman, Wisconsin Suzanne Bonamici, Oregon Steve Russell, Oklahoma Mark Takano, California Elise Stefanik, New York Alma S. Adams, North Carolina Rick W. Allen, Georgia Mark DeSaulnier, California Jason Lewis, Minnesota Donald Norcross, New Jersey Francis Rooney, Florida Lisa Blunt Rochester, Delaware Paul Mitchell, Michigan Raja Krishnamoorthi, Illinois Tom Garrett, Jr., Virginia Carol Shea-Porter, New Hampshire Lloyd K. Smucker, Pennsylvania Adriano Espaillat, New York A. Drew Ferguson, IV, Georgia Brandon Renz, Staff Director Denise Forte, Minority Staff Director ----------- C O N T E N T S ---------- Page Hearing held on April 27, 2017................................... 1 Statement of Members: Foxx, Hon. Virginia, Chairwoman, Committee on Education and the Workforce.............................................. 1 Prepared statement of.................................... 3 Scott, Hon. Robert C. ``Bobby'', Ranking Member, Committee on Education and the Workforce................................ 4 Prepared statement of.................................... 5 Statement of Witnesses: McComis, Mr. Michale S., Executive Director, Accrediting Commission of Career Schools and Colleges.................. 35 Prepared statement of.................................... 37 Miller, Mr. Ben, Senior Director for Post-Secondary Education, Center for American Progress.................... 24 Prepared statement of.................................... 26 Petrisko, Ms. Mary Ellen, President, Washington Association of Schools and Colleges, Senior College and University Commission................................................. 7 Prepared statement of.................................... 10 Pruitt, Dr. George A., President, Thomas Edison State University................................................. 13 Prepared statement of.................................... 15 Additional Submissions: Ms. Petrisko: WASC Senior College and University Commission............ 82 Article: Inside Higher Ed................................ 85 WASC Senior College and University Commission: WSCUC'S Graduation Rate Dashboard.............................. 89 Dr. Pruitt: Homeroom................................................. 92 Questions submitted for the record by: Chairwoman Foxx Roe, Hon. Phil, a Representative in Congress from the State of Tennessee Messer, Hon. Luke, a Representative in Congress from the State of Indiana....................................... 100 Rooney, Hon. Francis, a Representative in Congress from the State of Florida Response to questions submitted: Mr. McComis.............................................. 96 Ms. Petrisko............................................. 111 Dr. Pruitt............................................... 122 STRENGTHENING ACCREDITATION TO BETTER PROTECT STUDENTS AND TAXPAYERS ---------- Thursday, April 27, 2017 House of Representatives Committee on Education and the Workforce Washington, D.C. ---------- The Committee met, pursuant to call, at 10:00 a.m., in Room 2175, Rayburn House Office Building. Hon. Virginia Foxx [chairwoman of the committee] presiding. Present: Representatives Foxx, Roe, Thompson, Walberg, Guthrie, Messer, Byrne, Grothman, Stefanik, Allen, Lewis, Mitchell, Garrett, Smucker, Ferguson, Scott, Davis, Courtney, Polis, Bonamici, Takano, Adams, Norcross, Blunt Rochester, Krishnamoorthi, and Espaillat. Staff Present: Bethany Aronhalt, Press Secretary; Courtney Butcher, Director of Member Services and Coalitions; Emmanual Guillory, Professional Staff Member; Amy Raaf Jones, Director of Education and Human Resources Policy; Nancy Locke, Chief Clerk; Dominique McKay, Deputy Press Secretary; James Mullen, Director of Information Technology; Krisann Pearce, General Counsel; Jenny Prescott, Professional Staff Member; Alex Ricci, Legislative Assistant; Mandy Schaumburg, Education Deputy Director and Senior Counsel; Emily Slack, Professional Staff Member; Tylease Alli, Minority Clerk/Intern and Fellow Coordinator; Austin Barbera, Minority Press Assistant, Jacque Chevalier, Minority Director of Education Policy; Denise Forte, Minority Staff Director; Mishawn Freeman, Minority Staff Assistant; Christian Haines, Minority Senior Education Policy Counsel; Carolyn Hughes, Minority Deputy Director Health Policy/Senior Labor Policy Advisor; Veronique Pluviose, Minority General Counsel; Katherine Valle, Minority Education Policy Advisor; and Christopher Zbrozek, Minority Education Detailee. Chairwoman Foxx. A quorum being present, the Committee on Education and the Workforce will come to order. Good morning, and welcome to today's hearing. Earlier this year, the committee met to examine some of the challenges facing America's higher education system. Costs are rising at private and public institutions. Far too many individuals are failing to complete their education in a timely manner. Misguided rules are stifling innovation on campuses and creating new burdens on institutions across the country. At the same hearing, we discussed opportunities to help address these challenges, opportunities like empowering students to make informed decisions, simplifying student aid, and promoting innovation, access, and completion. Today, we continue our work to strengthen higher education by taking a closer look at another one of the key principles guiding our efforts, providing strong accountability for students and taxpayers. In higher education, one way we ensure accountability is the accreditation process. Accrediting agencies are voluntary private organizations made up of members from accredited colleges and universities. These agencies work with their member institutions to develop standards and criteria to determine what constitutes a high quality higher education institution. Then through a non-governmental system of peer review, the agencies decide if an institution meets those standards. By giving their stamp of approval, accreditation agencies provide students and parents with an assurance that an institution meets certain standards when it comes to delivering a high quality education. Families rely on accreditors to hold schools accountable for the education they provide, and to ensure these schools are producing results for their students. Congress also relies on accreditors. Accreditation helps determine which schools are permitted to participate in Federal student aid programs. These important programs allow students at eligible schools to receive Federal funds, and we need to know these hard-earned taxpayer dollars are going only to institutions that are serving students well. The accreditation process is critical to providing accountability in the higher education system. However, like many aspects of higher education, accreditation is in need of improvement. It has never been and should never be the Federal Government's role to judge the quality of a school's education programs. Entrusting independent accrediting agencies with that responsibility protects academic freedom and student choice. However, in recent years, accreditors have been forced to focus on compliance rather than promoting academic integrity, undermining the process and its purpose. It is time for a better approach. We need to focus Federal accreditation requirements on academic quality and student learning. We need to ensure Federal rules are clear and easy to follow. We need to improve or do away with regulations that discourage or prevent innovation in higher education, and we need to make sure that the Administration, whether Democrat or Republican, does not have the power to recklessly second-guess the tough decisions accreditation agencies make. These are all things Congress can do to improve the accreditation process, but if we are going to see real change, accreditors have a job to do as well. It is not enough to refocus Federal rules. Accreditors must also embrace the commitment to high quality and improved outcomes. Students need an honest and accurate assessment when it comes to the quality of education a school provides. An accreditation agency's stamp of approval means something to those students, or at least it should mean something. Accreditors also need to be open to innovation and the opportunities it can create in higher education. If we are going to roll back rigid Federal requirements, it is up to accrediting agencies to take the flexibility we are working to provide and do something meaningful with it. By working together, Congress and accreditors, we can improve the accreditation system, ensuring a balance between flexibility for institutions and accountability for students and taxpayers. We are here today to gain a better understanding of the challenges facing the accreditation system, as well as how we can tackle those challenges. I look forward to hearing from our witnesses and advancing solutions that will provide greater accountability in higher education, and ensure the accreditation process serves the best interests of students, families, and taxpayers. With that, I yield to Ranking Member Scott for his opening remarks. [The information follows:] Prepared Statement of Hon. Virginia Foxx, Chairwoman, Committee on Education and the Workforce Earlier this year, the committee met to examine some of the challenges facing America's higher education system. Costs are rising at private and public institutions. Far too many individuals are failing to complete their education in a timely manner. Misguided rules are stifling innovation on campuses and creating new burdens on institutions across the country. At that same hearing we discussed opportunities to help address these challenges--opportunities like empowering students to make informed decisions; simplifying student aid; and promoting innovation, access, and completion. Today, we continue our work to strengthen higher education by taking a closer look at another one of the key principles guiding our efforts--providing strong accountability for students and taxpayers. In higher education, one way we ensure accountability is the accreditation process. Accrediting agencies are voluntary private organizations made up of members from accredited colleges and universities. These agencies work with their member institutions to develop standards and criteria to determine what constitutes a high- quality higher education institution. Then, through a non-governmental system of peer review, the agencies decide if an institution meets those standards. By giving their stamp of approval, accreditation agencies provide students and parents with an assurance that an institution meets certain standards when it comes to delivering a high-quality education. Families rely on accreditors to hold schools accountable for the education they provide and to ensure those schools are producing results for their students. Congress also relies on accreditors. Accreditation helps determine which schools are permitted to participate in federal student aid programs. These important programs allow students at eligible schools to receive federal funds, and we need to know those hard-earned taxpayer dollars are only going to institutions that are serving students well. The accreditation process is critical to providing accountability in the higher education system. However, like many aspects of higher education, accreditation is in need of improvement. It has never been and should never be the federal government's role to judge the quality of a school's education programs. Entrusting independent accrediting agencies with that responsibility protects academic freedom and student choice. However, in recent years, accreditors have been forced to focus on compliance rather than promoting academic integrity, undermining the process and its purpose. It's time for a better approach. We need to refocus federal accreditation requirements on academic quality and student learning. We need to ensure federal rules are clear and easy to follow. We need to improve--or do away with--regulations that discourage or prevent innovation in higher education. And we need to make sure the administration--whether Democrat or Republican--does not have the power to recklessly second-guess the tough decisions accreditation agencies make. These are all things Congress can do to improve the accreditation process, but if we are going to see real change, accreditors have a job to do as well. It's not enough to refocus federal rules. Accreditors must also embrace a commitment to high-quality and improved outcomes. Students need an honest and accurate assessment when it comes to the quality of education a school provides. An accreditation agency's stamp of approval means something to those students, or at least it should mean something. Accreditors also need to be open to innovation and the opportunities it can create in higher education. If we are going to roll back rigid federal requirements, it's up to accrediting agencies to take the flexibility we are working to provide and do something meaningful with it. By working together--Congress and accreditors--we can improve the accreditation system, ensuring a balance between flexibility for institutions and accountability for students and taxpayers. We are here today to gain a better understanding of the challenges facing the accreditation system, as well as how we can tackle those challenges. I look forward to hearing from our witnesses and advancing solutions that will provide greater accountability in higher education and ensure the accreditation process serves the best interests of students, families, and taxpayers. ______ Mr. Scott. Thank you, Madam Chair, and I would like to thank you for calling this hearing, and thank our distinguished witnesses for being with us today. The issue of quality in higher education is not one that we address often in Congress. The higher education system in the United States is one of if not the best in the world, and we frequently spend our time debating how to increase access to the system or how to make college more affordable, and not just in quality. While these are topics that I am sure we will continue debating, it is important to take a step back to determine if we are ensuring that our higher education system maintains its high level of quality across all sectors for all students. While the Federal Government and State authorizers both have important roles to play in assuring quality, independent accrediting bodies should be the true arbiters of quality in our higher education system. Their thoughtful peer review process is designed to ensure that institutions are living up to their educational mission, whether it is providing students with an education that will be the basis of lifetime learning, or preparing them to excel in a specific field or career. The title of this hearing alludes to the fact that while students depend on accreditors, taxpayers do as well. Over $150 billion in Federal student aid is disbursed every year, and it can only go to institutions of higher education that have been accredited by a federally recognized accreditor. As such, there are huge fiscal implications in the quality and rigor of the accreditation process. While the accreditation system works well for many schools, it must be improved. We know that there have been schools that were fully accredited up until the day they closed their doors, leaving students out in the cold and taxpayers holding the bag. We also know that there are schools that remain accredited while offering their students little chance to obtain a degree or get a credential that has little value in the marketplace. There is emerging research that shows that in some cases, the outcomes at some fully accredited schools are so poor that students would have been better off not going to school at all rather than attending those schools. The Federal Government has begun to respond to these problems in accreditation. The Federal Government has an interest in whether or not a school is accredited because of the billions of dollars in Federal aid, and if the accreditors aren't doing the job, the Federal Government has to do the job, and that is where programs like Gainful Employment and other measures have come up. To the extent that the accreditors fail, we are going to have to come up with those kinds of answers. Over the last two years, the Department of Education has proposed actions to make the accreditation system more transparent, and to provide more information on standards that accreditors use to rate schools. Last year, the National Advisory Committee on Institutional Quality and Integrity derecognized the Accrediting Council for Independent Colleges and Schools, putting other accreditors on notice that subpar standards and a documented history of turning a blind eye to bad actors would not be tolerated. It seems like many accreditors got the message, and we have seen proposed reforms from accreditors based on recommendations from the previous Administration. I know accreditors want to improve, and they want to ensure that their members still provide a top-notch education, but we are at a crossroads. There is no guarantee that the new Administration is going to take a critical view on the need to improve accreditation, and I worry that the improvements we have seen of late could falter without the oversight and pressure from the Federal Government. Accreditation can be a peer-based program designed to foster self-improvement and be responsive to data on student outcomes. It can meet the needs of vastly different institutions but still use common terms and measures. It can respect the internal decisions and choices of an institution and still be transparent. We can have the best accreditation system in the world for the best higher education system in the world, and hopefully, our witnesses today will provide the perspective on how we can do just that. Thank you, Madam Chair, and I yield back. Chairwoman Foxx. Thank you, Mr. Scott. Pursuant to Committee Rule 7(c), all members will be permitted to submit written statements to be included in the permanent hearing record. Without objection, the hearing record will remain open for 14 days to allow such statements and other extraneous material referenced during the hearing to be submitted for the official hearing record. [The information follows:] Prepared Statement of Hon. Robert C. ``Bobby'' Scott, Ranking Member, Committee on Education and the Workforce Good morning. I would like to thank Chairwoman Foxx for calling this hearing and I'd like to thank our distinguished witnesses for being here today. The issue of quality in higher education is one that we address often here in Congress. The higher education system in the United States is one of, if not the best in the world, and we frequently spend our time debating how to increase access to the system or how to make college more affordable. And while these are topics that I'm sure we will continue debating, it is important that we take a step back and determine if we are ensuring that our higher education system maintains its high level of quality across all sectors for all students. While the federal government and state authorizers both have important roles to play in assuring quality, accrediting bodies are the true arbiters of quality in our higher education system. Their thoughtful peer review process is designed to ensure that institutions are living up to their educational mission--whether it's providing students with an education that will be the basis for a lifetime of learning or preparing them to excel in a specific field or career. The title of this hearing alludes to the fact that while students depend on accreditors, taxpayers do as well. Over $150 billion in federal student aid is disbursed every year, and it can only go to institutions of higher education that have been accredited by a federally recognized accreditor. As such, there are huge fiscal implications to the quality and rigor of accreditation reviews. While the accreditation systems works well for many schools, it must be improved. We know that there were schools that were fully accredited up until the point that they closed their doors, leaving students out in the cold and taxpayers holding the bag. We also know there are schools that remain accredited while offering their students little chance to obtain a degree, or a credential that has little value in the marketplace. There is emerging research that shows in the worst cases, the outcomes at some fully accredited schools are so poor that students would have been better off going to no school rather than attending. The federal government has begun to respond to these problems in accreditation. Over the last two years the Department of Education proposed actions to make the accreditation system more transparent, and provide more information on the standards that accreditors use to rate schools. Last year the National Advisory Committee on Institutional Quality and Integrity, (or NACIQI) derecognized the Accrediting Council for Independent Colleges and Schools (or ACICS), putting other accreditors on notice that subpar standards and a documented history of turning a blind eye to bad actors would not be tolerated. It seems like many accreditors got the message, and we have seen proposed reforms from accreditors based on recommendations from the previous administration. I know accreditors want to improve and they want to ensure that their members are still providing a top-notch education. But we are at a crossroads. There is no guarantee that the new Administration is going to take as critical a view on the need to improve accreditation, and I worry that the improvements that we've seen of late could falter without the oversight of the federal government. Accreditation can be a peer-based program designed to foster self- improvement and be responsive to data on student outcomes. It can meet the needs of vastly different institutions but still use common terms and actions. It can respect the internal decisions and choices of an institution and still be transparent. We can have the best accreditation system in the world for the best higher education system in the world, and hopefully our witnesses here today will provide perspective on how we can do just that. Thank you and I yield back the balance of my time. ______ Chairwoman Foxx. We now turn to introduction of our distinguished witnesses. Dr. Mary Ellen Petrisko is President of the Senior College and University Commission at the Western Association of Schools and Colleges. Dr. Petrisko has extensive experience in institutional academic leadership and regional accreditation and State policy. Dr. George Pruitt is President of the Thomas Edison State University. Dr. Pruitt has served in executive leadership positions at several postsecondary institutions, and is past chairman and a member of the Middle States Commission on Higher Education. Mr. Ben Miller is Senior Director for Postsecondary Education at the Center for American Progress. Mr. Miller's work focuses on postsecondary education accountability, affordability, and financial aid, as well as for-profit colleges and other issues. Dr. Michale McComis is Executive Director at the Accrediting Commission of Career Schools and Colleges. As the Executive Director, Dr. McComis manages the day-to-day operations of ACCSC's office and staff in overseeing the ACCSC accreditation process. I now ask our witnesses to raise your right hand. [Witnesses sworn.] Chairwoman Foxx. Let the record reflect the witnesses answered in the affirmative. Before I recognize each of you to provide your testimony, let me briefly explain our lighting system. We allow 5 minutes for each witness to provide testimony. When you begin, the light in front of you will turn green. When one minute is left, the light will turn yellow. At the 5 minute mark, the light will turn red, and you should wrap up your testimony. Members will each have 5 minutes to ask questions. I believe we are ready to begin. Dr. Petrisko, you are recognized for 5 minutes. TESTIMONY OF MARY ELLEN PETRISKO, PRESIDENT, WASHINGTON ASSOCIATION OF SCHOOLS AND COLLEGES, SENIOR COLLEGE AND UNIVERSITY COMMISSION Ms. Petrisko. Chairman Foxx, Ranking Member Scott, and members of the committee, thank you for the opportunity to be with you today to testify. As noted, I am the President of the WASC Senior College and University Commission, which is an accrediting body serving public and private higher education institutions throughout California, Hawaii, and the Pacific, and a limited number of institutions outside of the U.S. The first accreditor of colleges and universities was founded in this country in 1885, when there were just 36 States in the Union. Just as our country has grown and developed over the past 130 years, so, too, had accreditation changed to become what it is today, an outcomes-focused system of quality assurance that relies on voluntary peer review. The work of accreditation is grounded in standards aligned with those dictated by U.S. statute and regulations. Since 1952, related to the G.I. Bill, accreditors have been recognized as quality assurance agencies to protect the Federal Government's investment in higher education. Accreditation has traditionally existed as part of a quality assurance triad, in collaboration with State and Federal Government. Colleges and universities in the United States have an international reputation for exceptional quality, as does our system of accreditation. Indeed, many institutions outside of the United States aspire to be accredited by U.S. accreditors, but the fact that our accreditation system is a strong and much admired system does not mean that it and our larger quality assurance system triad are perfect. Today's hearing is focused on opportunities to improve accreditation. While I believe accreditors largely do a good job in protecting students, I also believe that steps could be taken in the reauthorization of the Higher Education Act to create a stronger accountability system and therefore better serve students. First, I'd like to tell you about some of the things we at WSCUC are doing to support student success and protect the public's investment in higher education. At WASC, we define ``student success'' as student learning and retention and completion. With regard to the latter, let me note that the Federal IPEDS data only measured completion for first time full-time students at an institution. In the WASC region, IPEDS covers only about 360,000 of our 900,000 undergraduate students, making more than 500,000 students invisible. To address the insufficiency of these data, WASC has developed what we call the ``Graduation Rate Dashboard,'' a tool that enables us to see how many students graduate from an institution, and importantly, no matter their enrollment status or time to degree. Given that the majority of our students fall outside the IPEDS' measure, this is an important development. The Dashboard can provide institutions with more complete and inclusive information regarding student success, shine light on enrollment, retention, and graduation patterns, and allow both WASC and the institution to better identify and address issues that affect student success. I've included additional information about this tool in my written testimony, as well as information about our work with the National Student Clearinghouse to expand our ability to assess institutional effectiveness. As student completion is important to all accreditors, the Council of Regional Accreditors, or C-RAC, recently launched a nationwide effort to place increased emphasis on graduation rates as part of our ongoing review of colleges and universities. Each accrediting body will use at a minimum a 15 percent IPEDS' graduation rate for two year institutions, and a 25 percent rate for four year institutions--those numbers are about half the national average--as triggers to more closely examine institution's student success and plans for improvement. Let me conclude by making three recommendations for the strengthening of our system of accountability related to innovation, transparency, and appropriate levels of regulation. First and foremost, I believe it is critical that the HEA reauthorization support the innovation necessary to serve current and especially future students, and that it will allow accreditors the flexibility to review and approve innovations in a safe zone as is allowed by current experimental sites. As our regional undergraduate population shows, the majority of students today do not go to one institution full- time or finish within four years. I hope that the reauthorization will keep these changing student demographics in mind. Secondly, whatever steps are taken to provide greater transparency should ensure that students can access accurate and relevant information on our institutions. Currently available data from the College Navigator and College Scorecard are sometimes inaccurate, sometimes in conflict with one another, and limited due to their reliance on IPEDS. Better information can help students make better choices and promote enhanced accountability. Understanding this, we at WASC have published all of our team reports and Commission action letters since July of 2012. Finally, I hope that excessive regulations, such as those related to substantive change and credit hour, will be addressed and moderated. Such regulations inhibit innovation, add costs and burden to institutions, and do not add value. Chairman Foxx, Ranking Member Scott, thank you very much for the opportunity to testify. I look forward to answering your questions. [The statement of Ms. Petrisko follows:] [GRAPHICS NOT AVAILABLE IN TIFF FORMAT] Chairwoman Foxx. Thank you very much. Dr. Pruitt, you are recognized for 5 minutes. TESTIMONY OF GEORGE A. PRUITT, PRESIDENT, THOMAS EDISON STATE UNIVERSITY Mr. Pruitt. Thank you. Madam Chairwoman and members of the committee, in December, I completed three successive terms as Chair of the Middle States Commission on Higher Education. Prior to that, I served for almost 19 years, under five Secretaries of Education, under three Presidents of both parties, as a member of the National Advisory Committee on Institutional Quality and Integrity, otherwise known as NACIQI, but today I come before you to provide an institutional perspective. Thomas Edison State University is a specialty university. We were created with the mission of providing flexible, high quality collegiate learning opportunities for self-directed adults. The average age of our student body is approximately 40, and we do not regularly admit students under the age of 21 unless they are community college graduates or active duty military. With an enrollment of 17,500 students, we are the third largest college or university in the State of New Jersey. We were among the first institutions in creating what is now known as ``prior learning assessment.'' We were one of the first regionally accredited colleges or universities in the United States to offer complete degree programs online. While we are noted for our innovation in the serving of adult learners, we are proudest of the recognition we receive for the quality and integrity of our academic work. Regionally accredited institutions value their participation as members of quality assurance communities. While reasonable Federal oversight over the use of public funds is important and necessary, we believe that peer affirmation of quality tested against agreed upon standards promulgated by recognized academic authorities, has been essential in producing the finest set of academic institutions in the world. There are four basic things we would all like to see from our accreditors. First, standards that respect the rich diversity and institutional mission and the different student populations we serve through a process of self-study and peer review. Ten miles down the road from us is Princeton University, one of the finest institutions in the world, yet our two universities could not be more different. Both of high quality, but with very different missions serving two very different populations that require different analytics to understand us. Second, accreditation focused on objectively demonstrable student learning outcomes. Third, accreditation conclusions about institutional effectiveness that are based on objective evidence, appropriate metrics, and where possible, third party validation. The emphasis should be on appropriate metrics that are aligned with the individual mission of the institution, and not a one-size-fits-all template, using misplaced data, such as graduation rates. If graduation rate is the wrong metric, then what are some of the right ones? For example, Thomas Edison State University graduates achieved the highest pass rate of all New Jersey institutions on the National Public Accountancy Exam for three of the last five years. In 2012 and 2014, the graduates of our Accelerated Baccalaureate Nursing Program earned a 100 percent pass rate on the State licensure exam. In fiscal 2016, 77 percent of our graduates were admitted to graduate schools, and only 7 percent of the students that stopped out of our institution did so for academic reasons. The vast majority of students enrolled in American higher education today are over the age of 25 and attend college part- time. The traditional 18-year-old going to college full-time expecting to graduate in four years is a shrinking piece of the higher education pie. Accordingly, the metrics of accountability to be of any value must reflect this new reality. You'll never get the right answer to the wrong question. Finally, accreditors should continue to oppose the substitution of compliance for quality assurance that is stemming from well-intentioned but misguided regulation by the Department of Education. I believe that Middle States and the other regional accreditors are meeting these four benchmarks. We all understand that there have been some well publicized examples of institutions that have lost their way, compromised the public trust, misused public resources, and hurt the students that were enlisted into their care. While these institutions should be held accountable by their accreditors, regulators, and consumers, the broad system of accreditation is fundamentally sound, but we must always be involved in a process of continuous improvement. Accreditation should not be expected to prevent the failure of institutions. Instead, it should be the proverbial canary in the coal mine, identifying weak institutions, strengthening them where possible, and alerting the regulators and protecting students when institutions become severely challenged. However, in our effort to improve the system, we must not impose remedies that do more harm than the maladies they seek to cure. Thank you. [The statement of Dr. Pruitt follows:] [GRAPHICS NOT AVAILABLE IN TIFF FORMAT] Chairwoman Foxx. Thank you, Dr. Pruitt. Mr. Miller, you are recognized for 5 minutes. TESTIMONY OF BEN MILLER, SENIOR DIRECTOR FOR POSTSECONDARY EDUCATION, CENTER FOR AMERICAN PROGRESS Mr. Miller. Thank you, Chairwoman Foxx and Ranking Member Scott for the opportunity to testify today. Every year, students and taxpayers invest billions of dollars in higher education, seeking better lives and a stronger economy. We trust a triad of States, the Federal Government, and accreditation agencies to ensure those investments pay off. The triad is failing us. While no part of the triad is blameless, accreditors have either stood by or acted with molasses-like speed while taxpayer dollars and student dreams got wasted. Every campus of Corinthian Colleges maintained accreditation until the day it closed or was sold, even as allegations of falsified job placement rates, altered grades, and inadequate education piled up. There are many schools of all types today that can proudly advertise their accreditation status while producing high levels of borrowing, low completion rates, and poor repayment outcomes. Do accreditors know about these problems? Yes. They wag their fingers and sometimes issue threats. They rarely pull the plug. Everyone in this room pays for this inaction. As taxpayers, we all pay when Federal loans are forgiven due to fraud or aid does not become a degree. Today, we are fortunate to hear from two of the most forward thinking accreditation agencies, but remember, the good things they are doing are voluntary. Many other agencies have not followed their lead. For example, WASC has required the publication of accreditation team reports for nearly a half decade. No other accreditor has done so. ACCSC requires independent verification of outcomes data. The other large national agency blew off the need for this action until its existence was threatened. And, just as the accreditation system contains WASC and ACCSC, so, too, did it have the Accrediting Council for Independent Colleges and Schools. ACICS served as a safe haven for troubled colleges fleeing scrutiny from other accreditors. Its quality assurance work was literal box checking. ACICS' results were grim. It approved over a dozen schools that faced Federal or State investigations for wrongdoing. Those schools received $5.7 billion in Federal aid over just three years. 90 times ACICS named one of those campuses to its Honor Roll for an excellent understanding of the accreditation process. These problems persist because we have created a system of quality assurance that says success means doing the things you said you'd do, not the actual results achieved. So, what can Congress and accreditors do? First, Congress should make the system much more outcomes focused. Accreditors should judge schools primarily on the results of their students, and the Federal Government in turn should judge accreditors by how well they do, not just whether they have mandated standards in place. Second, the system needs to get a lot tougher on lower performing colleges. Institutions with abysmal completion rates or no evidence of learning need stricter scrutiny. They should pay much more up front for their reviews, giving accreditors resources needed for deeper dives. A greater focus on the bottom should also come with an easier approval process for schools at the top. Third, we need new alternative approaches to quality assurance that allow new providers with verifiably outstanding performance to access Federal aid. Here is the Center for American Progress's idea for how that could work. Private third parties would propose indicators of student outcomes and financial health a program would have to meet in order to access Federal aid. Only the best should be able to clear the bars. The Federal Government would then verify whether the programs seeking aid meet those standards and take action to approve or deny a program accordingly. This approach marries the best elements of the current system while fixing many of its flaws. It preserves a role for third parties that have experience judging programs. It solves conflicts of interest by separating out who sets standards from who determines eligibility, and it leverages data the Federal Government already holds on earnings and loan outcomes to minimize the need for additional data collection. A high quality college education can unlock a lifetime of benefits, but low quality programs can cause financial ruin, especially if Federal student loans are involved. Students and taxpayers today trust accreditation as a stamp of quality that their money will be worth it. We have a ways to go to ensure that is true. Thank you very much, and I look forward to your questions. [The statement of Mr. Miller follows:] [GRAPHICS NOT AVAILABLE IN TIFF FORMAT] Chairwoman Foxx. Thank you. Dr. McComis, you are recognized for 5 minutes. TESTIMONY OF MICHALE S. McCOMIS, EXECUTIVE DIRECTOR, ACCREDITING COMMISSION OF CAREER SCHOOLS AND COLLEGES Mr. McComis. Good morning, Madam Chair, Ranking Member Scott, and members of the committee. My name is Dr. Michale McComis, and I'm the Executive Director of the Accrediting Commission of Career Schools and Colleges. I'm honored to appear before the committee this morning to discuss accreditation, the contributions it makes to the quality of education in this country, and the ways it might be improved. Accreditation has been relied upon for educational quality assessment purposes by the Federal Government for over six decades. Although accreditation has come under increased scrutiny by policymakers, accreditation can and should continue to serve in its gatekeeping capacity, albeit in a strengthened form. Accreditation employs a collaborative approach within a peer review network that identifies best practices and assesses how well an institution meets those best practice standards. It is not nor can it be a one-size-fits-all system with rudimentary metrics that do not take into account diverse objective and qualitative elements of an institution's operations and success. Accreditation derives its strength from four essential pillars that are built upon a foundation of peer review, standards or best practices, self-evaluation, ongoing institutional improvement, and accountability. Accreditation serves a myriad of institutions accredited by agencies with different standards and expectations of student outcomes. This is both appropriate and necessary, and should be viewed as a strength to our system. But Congress should consider changes to the Higher Education Act that will strengthen accrediting agencies, however, without injecting undue Federal intrusion into the learning process or that might serve as a barrier to innovation. Judgments regarding the effectiveness of accreditation should not lose sight of the fact that the oversight of higher education is a shared responsibility amongst the triad partners, accreditors, States, and the Federal Government, working together, which strengthens the existing oversight system. So then, how can accreditation be strengthened through the Higher Education Act? The following are some suggestions that I hope the committee might consider. Outcomes. Outcome measures are not a one-size-fits-all solution and should not be mandated by Congress or the U.S. Department of Education. However, accreditors must define the right set of measures and metrics to evaluate institutional and student success. At ACCSC, we measure rates of graduation, employment, licensure, and required learning and competency assessment. Transparency. Accreditors should be expected to provide useful disclosures of the accreditation actions taken that can help the general public make informed decisions about the quality of an institution or program. Differentiation. Allow for differentiated levels of accreditation which could place schools in different categories and move beyond binary decisions regarding quality. Credit hour definition. Seat-time requirements for funding programs do not preserve academic integrity nor promote competency-based assessment, and as such, the Federal definition of a ``credit hour'' and the complex clock hour conversion formulas should be removed from the Federal regulations. Accreditation area of focus. It may be useful to expect accreditors to focus more narrowly on the types of institutions accredited in order to ensure a strong peer review foundation and solid measures related to outcomes and accountability. Transfer of credit. Accreditors should be expected to have and enforce standards that prevent institutions from unfairly or unjustifiably denying credit transfers. Change of accreditors. Institutions that have been subject to a monitoring sanction from one accreditor should not be allowed for Federal financial aid purposes to seek a new accreditor for some set period of time after the sanction has been lifted. Lastly, indemnification. Given the high stakes associated with the loss of accreditation and the ensuing loss of access to Title IV student financial aid funding, the Federal Government should consider affording accreditors some protection as a means to prevent specious and costly lawsuits from being brought against accrediting agencies. I've also included other areas for the committee to consider within my written testimony, and I hope the committee finds these recommendations useful as it goes about its work, and I'm happy to provide additional details regarding each. Thank you for the opportunity to testify before the committee this morning, and I look forward to continuing the dialogue on ways in which we can work together to strengthen our accreditation system. Thank you. [The statement of Mr. McComis follows:]22-32 [GRAPHICS NOT AVAILABLE IN TIFF FORMAT] Chairwoman Foxx. Thank you very much. You win the prize for coming in under time. I want to thank all of you for your testimony and your written testimony is even more expansive, and I am grateful for that. I will begin the questioning. Dr. Petrisko and Dr. McComis, I believe very strongly in ensuring accountability for hard- working taxpayer dollars. Right now, you and your colleagues are responsible for ensuring $128 billion the Federal Government sends out in student aid every year, is flowing only to high quality institutions. Can you explain to the committee how the current system of accreditation with the competing roles of quality assurance and continuous self-improvement is able to accurately measure and assure institutional quality and protect the taxpayer investment at the same time? Why should Congress, and more importantly, students and parents, continue to rely on your agencies as reliable authorities for the quality of institutions of higher education? Dr. Petrisko, I will start with you, and then come to Dr. McComis. Ms. Petrisko. Thank you. It is certainly true that accreditors balance all the time in our decisions compliance with our standards and improvements at the institutions. As we do that, we are very keenly aware of the fact that many students have no other institution to attend if they are not able to attend the one where they are currently enrolled. So, we want to keep institutions strong, make them stronger, address the issues of non-compliance or weakened areas of compliance with a range of actions, not pulling the plug automatically, but with special reports, visits, and sanctions when necessary, that carry a real threat of loss of accreditation, but it is to maintain operations of those institutions that are supporting students and strengthening them at the same time. Chairwoman Foxx. Thank you. Dr. McComis? Mr. McComis. I'll echo what Dr. Pruitt said along the lines of the many successes that we can point to, even amidst some of the failures that are present as well. Insofar as measuring quality, that is a difficult aspect to bring about, so the richness and the diversity, the types of institution, and the peer review network that brings about individuals coming together to establish those best practice standards, the key being really from there setting and establishing those outcome measures that really set to reflect what quality can or should be. So, for example, again with my agency, because we predominately work with vocational and career oriented institutions, we can look to measures like graduation rates. We can look to measures like employment rates. We can look to measures like licensure rates. But also, at the same time, acknowledging that in order for a welder really to graduate, they need to be competent. So, competency assessment measures as well. So, all of that woven together into a system that brings about a highly qualified graduate that can contribute to a highly qualified workforce is really the main aim here. Chairwoman Foxx. Thank you very much. Dr. Pruitt, I agree with you that Thomas Edison is a special university and applaud the work your institution has done to serve adult learners. Can you discuss how a one-size-fits-all system of Federal accountability might jeopardize the crucial work your institution and other institutions like yours are doing to serve contemporary students? Why is it so important that accreditors have the flexibility to determine appropriate outcome metrics for ensuring the quality of institutions? Mr. Pruitt. Thank you, Madam Chairwoman. It is crucially important that metrics be mission sensitive. In the absence of that, metrics tend to assess the demographics of the student body and not the quality of the institution. I come back to my favorite subject about the graduation rates. I saw eyebrows raised from my colleague when we had a talk about graduation rates in the 20 something percent range, and everyone looked like, well, that's too low. Well, it is too low if your assumption is that you're going to college full-time and expect to graduate in four years. None of the 17,500 students in my institution--none of them go full- time, none of them expect to graduate in four years. My colleague institution down the street, Princeton, all of them expect to go full-time and graduate in four years. So, to create one metric that you try to apply across the board to different institutions without regard to the individual mission of the institutions or the constituents that they are serving, distorts the picture of both institutions. So, the dreaded template never works for diverse institutions serving diverse populations. It actually misleads the public and looks for false indicators of quality that kind of confuses the conversation. That's why it's so important to have these indicators referenced to the specific mission of that particular institution against similar institutions and peers. You can do that. We have a track record of doing that. That's the way it should be done, and not the dreaded template. Thank you. Chairwoman Foxx. Thank you very much, Dr. Pruitt. Mr. Scott, you are recognized. Mr. Scott. Thank you, Madam Chair. Dr. Petrisko, should the cost of the institution be a factor in accreditation? Ms. Petrisko. Should the cost of the institution be a factor in accreditation? I want to say a couple of words about costs. There's a lot of misunderstanding about costs in higher education because a lot of people take a look at the sticker price as opposed to the net price. There is a recent publication of the Association of Governing Boards, which I will be happy to put into the record, that talks about the reality of what the real costs are of education and what the rise in those costs have been. So, for example, at the four year institution level publicly, over the last 26 years, this is the highest rate of increase, the rate of increase of the net price has been about 3.7 percent. For community colleges, it's been about 1 percent a year, and for the private institutions, it's been less than 1 percent a year. That's the net price. There's a vast difference because of a lot of discounting at the private institutions to ensure that there is some flexibility in pricing schedules to allow students who would not have the wherewithal to pay the sticker price to attend that institution. So, there is a lot of misinformation out there and it's a complicated issue, but the costs are not what some people might think they are. Mr. Scott. Basically, if two schools of equal quality, one charging two, three times more than the other, should that be a factor in accreditation? Ms. Petrisko. I would say no, it depends on how the students are supported to pay for those costs, and they are supported in different ways, by loans, grants, and institutional aid. Mr. Scott. Should false advertising be a factor in accreditation? Some schools promise that if you go to their school, you'll get a job. Others, if you come to school, you'll get a good education, but you may not be able to get a job. Ms. Petrisko. Absolutely. There is a form that our evaluators use to make sure that institutions are giving their students correct information about costs, what it really costs, what their job prospects are, and that their recruiting materials are accurate and true. So, we do require that be reviewed. Mr. Scott. I visited Dr. Pruitt's school, and enjoyed the visit, Dr. Pruitt. He indicated it is inappropriate to judge a school's outcomes without recognizing the difference in the demographics of the student body. One could have everybody coming from the top one percent, others could have high Pell- eligible . Can you have a student outcome measure that does not recognize the diversity in the student body demographics? Ms. Petrisko. I do not think so. The 20 percent rate that Dr. Pruitt referred to, which is an IPEDS rate, when I talked about the Council of Regional Accrediting Bodies, we have examples at our institutions where the IPEDS rate goes 30 percent, and the actual rate, not taking enrollment into consideration, and not taking time to degree into consideration through this Dashboard that I've talked about in my testimony, the actual rate of one institution in the California State system with a very high percentage of part-time students and students taking a very long time to get their degrees is more like 60 percent. So, it absolutely is relevant, who the students are, what their paths to degrees are, and how long those paths take. Just seeing a certain percentage of an IPEDS rate, the national available rate, may be an indicator, it's a trigger, as I said, to look further, but if that percentage, as was the case with one of the institutions I looked at in our region recently, if that percentage represents 4 percent of the student population or for some institutions, like Western Governors, 0 to 1 percent, that is not giving you very good information, and judgments should not be made about the quality of the institution based on that data. Mr. Scott. How do you value the--how do you assess the value of a four year on-campus private liberal arts degree where most of the value in fact doesn't even come from the classroom but from the college experience? Ms. Petrisko. We expect every institution to state what its learning outcomes are. Institution learning outcomes, program learning outcomes, and if they provide evidence of the assessment of and the achievement of those outcomes. So, outcomes can be very large, very broad outcomes. We do expect at the institutions if they state those are outcomes for their students, that they show us how those students meet those outcomes. Mr. Scott. Finally, should we be assessing on a pass/fail basis or a relative basis throughout the spectrum? Because the question that we are addressing is whether you participate in financial aid or not. Should we have a pass/fail or have an assessment that differentiates all the way through the spectrum? Ms. Petrisko. There are differentiations across the accreditors: status of accreditation, how long, in our case, a reaffirmation, it could be six, eight, or 10 years, depending on the strength of the institution, whether there is interim reporting, whether there are special visits in between those reaffirmation periods. But I would say for Federal aid purposes, I wouldn't want to see differentiation there because the students are taking different paths to their degrees, and they should all have access to that support to be able to do so. Chairwoman Foxx. Thank you, Mr. Scott. Mr. Byrne, you are recognized for 5 minutes. Mr. Byrne. Thank you, Madam Chairwoman. This was great. All your testimony was very helpful. Mr. Miller's testimony hit some points that I think all of us would agree we need to talk about, honestly. I was a Chancellor for Postsecondary Education for Alabama, and my relationship with our accreditor was, I would call ``appropriate,'' which meant sometimes it was uncomfortable. For those of you who know Dr. Belle Whelan, you know she is very nice about making things uncomfortable, but she needed to make my life uncomfortable from time to time, and that is okay, so I value that about it. We have had some failures in our accreditation agencies. So, the question for us is do we come in with a more heavy handed Federal approach to get accreditors to do what they need to do, or is there a way for us to turn to the accreditors themselves and say value your independence, which I think is one of your great strengths, but at the same time tell you we have to police ourselves better, because there have been some key instances where we have not done our job right. I thought I would like throw it out to any one of you that want to jump in on that. I am really looking to the other three, because you sort of laid the critique out there. I would like for you to respond to that. Do you think the Federal Government playing a heavier hand is going to help, or is there something we can do within ourselves, all of us, to make it work better? Ms. Petrisko. I think it's very important that accreditors have the authority to take additional steps where necessary to improve what we do, learning from very close work with the institutions and the challenges they face, learning what we need to do to strengthen our own systems. There has already been mention made of the failed institutions recently, and I can tell you one of the big changes in higher education, from which we have all learned recently, has been the tremendous growth in the for-profit sector. I don't think that's a secret, that public institutions are very strapped, many non-profit institutions are also financially challenged and are very concerned with selectivity. A great deal of growth has been in the for-profit sector. Just in our Commission, we currently have of our accredited institutions about 13 percent are for-profits. That's 23 now. Six years ago, we had one. If you go to the candidates, it's about 33 percent, if you go to the eligibles, it is about 35 percent, the ones that are just applying, it's about 50 percent that are for-profits. So, we are very keenly aware of the fact that we need to have better and more inclusive information about what's going on. So, accordingly, what we have done learning this is we have commissioned work from PRAGO, a firm that's created the ratio analysis in higher education, this is what the credit analysis has done in higher education, pretty much across the country on the basis of seven financial ratios. We've worked with them to give us a better foundation. We're still in the process of getting this report. Getting a better foundation for how to look not just at institutions but with their parent companies to get the information from them as well, on governance and finances, so that we can see how decisions are being made that are affecting the institution, where the resources are going, and how those are being allocated. I think this is a good example of the fact that we are stepping up as accreditors when we recognize there are issues that we are not covering. Mr. Byrne. That is really not my question. You are doing your job. We know there are instances where it has not been done. I want to find the right balance here, because there is a tension here. Mr. Scott, I think, has done a good job of stating the tension. How do we address the balance? Dr. Pruitt, do you have a thought about that? Mr. Pruitt. Well, there are institutions that fail, and they should be held accountable, but the whole system shouldn't be changed. There are accreditors that have failed, and they should be held accountable, but the whole system shouldn't be changed. Mr. Byrne. How do we hold them accountable? Mr. Pruitt. Well, the institutions that have failed have lost accreditation, they've gone out of business. Mr. Byrne. I am talking about the accreditors. Mr. Pruitt. I think if they failed, they should be held accountable, too, and their recognition should be lost as well. Mr. Byrne. That would come from the U.S. Department of Education? Mr. Pruitt. Yes. Mr. Byrne. So, I guess the question is, Dr. McComis, this is something I was interested in from you, sometimes it falls most heavily on the sector that you deal with, how do we assess an accreditor? What is the basis on which we say an accreditor is doing its job or not doing its job? Mr. McComis. In this regard, there are a whole set of Federal regulations that we go through-- Mr. Byrne. Yes, but are they good? Mr. McComis. Largely, I think, they are. Consistency would be one area that I would point to and the application of those. The National Advisory Committee on Institutional Quality and Integrity, NACIQI, they are working toward their own expectations around that, and I think those expectations are changing, and when we get to a point of greater consistency so that accreditors better understand what those expectations are. There currently exists Federal regulations that say accreditors need to have outcomes around graduation rates or completion rates and licensure rates, things of that nature, and what is the consistent application. The only thing that I would say with regard to that is your first question about can we rely upon the accreditation system, what is really rich about it, to Dr. Pruitt's point, is you can set benchmark outcome standards, and not everybody is going to meet that standard every single time, but what is the process that the institution is going through. That's the richness and the qualitative nature of this process that accreditors should be expecting and that the Federal Government should be expecting accreditors to partake with their institutions to move that quality forward. So, holding accreditors accountable for the way they work with their institutions and establish those outcome standards, I think, is key. Any direction and guidance that the Congress can give to the Department in the establishment of those regulations, to talk about the consistent application across all the creditors, would be useful. Mr. Byrne. My time is up. Thank you, Madam Chairwoman. I yield back. Chairwoman Foxx. Thank you. Ms. Davis, you are recognized for 5 minutes. Mrs. Davis. Thank you. Thank you very much for the panel. I know you all recognize the differences in our educational institutions today. You mentioned more for-profits, other apprenticeship programs, lots of different ways, I think, that we need to really support people when they are going through postsecondary and just everything that is higher ed, everything that is after high school, but how specifically do you think accreditors could be involved in reviewing and accrediting the apprenticeship programs, as one example, that may be different from other accreditations? How do we do that? How do we apply that differently? I think the other question may be, and perhaps we can learn from programs that are more traditional, how do we listen to the people that are involved in this, peer review at schools is something that is a good thing on many levels, but I know from peer reviewers, a lot of this makes them crazy, and yet they feel they cannot track our students well enough to really be able to evaluate their educational experiences as they go into the work world. How do we do that? How do we train them? Do you think there is a good way of doing that today? Mr. McComis. I'll tackle your first question about apprenticeships and other kinds of programs, because I mentioned this a little bit in my written testimony and briefly in the oral, and that is looking for ways for accreditors and for institutions to have competency-based systems supported through the Federal financial aid system as opposed to seat- time measures or requirements. So, while there's some allowances there, I think that in some ways, the requirements that currently exist can serve as those barriers to innovation. My agency is very much interested in working with institutions that work more closely with the employment community, that work more closely in apprenticeship programs, and the question that arises is how does that fit into an overall educational program that can be supported for students with their Title IV student financial aid dollars. And so, where I think there's some tension that exists there in trying to create programs that really can support students' success. So, I would encourage the committee to think about ways that those programs can be thought about in a bit of a broader way. Mrs. Davis. Mr. Miller, do you have any thoughts about that? Mr. Miller. I want to touch on the student part of it and sort of the student feedback. I think there are a couple of challenges here. One is as we talk about students are increasingly older, going part-time, they're not on campuses much. So, if you go and conduct your visit during working hours, you may not be able to find all the students you have. They're busy; if you sort of say come to this room at this time and talk to us, you're not going to catch everyone you need to catch. Part of it is we need student feedback, not just sort of in the moment for people who are enrolled somewhere. We should be talking to people long after they've left, and seeing, you know, did this result in what you thought it would? People in the moment don't necessarily know until they leave. We have seen this with a lot of the troubled schools. They thought they were getting a good education in the moment. They left, tried to find a job, found out it totally didn't work. The other thing I would just say really quick here is this is why we have the experimental sites flexibility within the Higher Education Act to allow Federal aid to test out sort of new types of approaches. There is one right now that says maybe we don't need to have programs be 15 weeks in length to get Federal aid, because there may be quick training programs that are valuable. Unfortunately, the current Administration is terminating them on June 30 without much warning or any information about what they've learned or anything like that. Mrs. Davis. Thank you for that. Please, go ahead. I had another question to ask you as well. Ms. Petrisko. First, I hope everybody realizes that as far as the regional accreditors are concerned, we are limited in the types of institutions that we accredit, so degree granting institutions within a certain geographic scope. So, providers that are not degree granting providers, and we do recognize the world of education is bigger than degrees, it certainly is, but if they're not degree granting providers, they do not fall within the scope of what we can do. Could accreditors do more with different types of programs with expanded scopes? I believe so because the basic principles are what are you promising, what are you delivering, how sustainable is this operation? Mrs. Davis. Could I turn really quickly to trade schools, and I know my time is almost up, because I think there is a concern and certainly maybe it is a misperception, that when you strengthen accreditation standards that you harm good actors in these fields. You put additional burdens on them to show, you know, that they are following through with their promises. Do you think that is a problem? Dr. Pruitt? Mr. Pruitt. Yes, that's a problem. Mrs. Davis. How do we fix it? I think my time is up. Thank you. Chairwoman Foxx. Thank you very much. I think you touched on a subject we need to talk a little bit more about. Mr. Guthrie, you are recognized for 5 minutes. Mr. Guthrie. Thank you, Madam Chair. Dr. Petrisko, I am pleased to hear that regional accreditors have launched a nationwide effort to place increased emphasis on graduation rates as part of their ongoing reviews of colleges and universities. If you may, please provide the committee more information about how the graduation rate information will be used as part of the review process, and why did the regional accreditors decide to undertake this effort, and what successes have you seen so far? Ms. Petrisko. Okay. So, the last part first, why it was decided to do this, because there are seven different regional accreditors and we do things in our own ways, a lot of alignment, a lot of similarities and overlap, but we do things with definitions and things in our own ways, it became clear that without a national statement and a national initiative, that there would still be a lot of misunderstanding or lack of understanding of what we're doing, and that we take graduation rates seriously. So, we spent a long time thinking about how to set those rates, and as I said, the rates were set at about half the national average, and again, they are IPEDS rates, so they are not reflective of the full student population, but it was decided that going with those numbers of half the national average was a good starting point as a trigger to say let's go further now and see with the institutions that we accredit, which ones fall in that band, and let's go further and see are those data accurate. If they're not accurate, why aren't they accurate, let's get them accurate. If they are accurate, let's take a look across institutions of similar types and see how well are institutions doing, which institutions are doing better that we could learn from, and when institutions are not doing as well as they should be doing, what actions are the appropriate actions to take, not just to get more information, although more information is always good, but what are the appropriate actions to take to require institutions to do better. There's a lot that has been learned about high impact practices, for example, to assist students in completing and doing better in their work, so not just to encourage but to expect institutions to build on the rates once we have the accurate information, to make sure they are as strong as possible. Mr. Guthrie. Thank you. I want to move to another question. Dr. Pruitt, good to see you again. In your testimony, you highlight the importance of peer review as an affirmation of quality. Please discuss why you believe peer review is a crucial aspect of the quality assurance process even among every different types of institutions, and are there ways the peer review process can be improved? Mr. Pruitt. Because all professions look to be calibrated against the standards set by their profession, and the only way you can get those standards developed are by other people that are in your profession. So, if you're a surgeon, you want the College of Surgeons to set the standards and evaluate you on your proficiencies. That's pretty much true of every profession. So, we look to our colleagues from other institutions to come in and one, set the standards and the process. Standards are set by using the institutions that are members of the association. The application of those standards are done by peer reviewers from other institutions that understand the particular mission and purpose of that particular institution so there's no misapplication of the standards. At the end of the day, accreditation was formed way before it was a gatekeeper function, because colleges want the approval of others in their profession as a process for continuous improvement, so the peer review process is essential as opposed to the review of some external third party coming in to do a compliance measure to see how many wastebaskets you have or how many seats you have or how many library books or test tubes you have. So, at the core, the strength of the system is self-study and introspection, where you are testing yourself against commonly identified standards, so that you're not self- delusional, and then external review to keep you honest against standards that both the reviewers and the reviewee have bought into as appropriate measures of quality. Mr. Guthrie. Thank you. Dr. McComis, because your organization accredits many vocational-focused schools and programs, you understand maybe better than some others do the role of education in preparing students for jobs. Please talk about how the ACCSC maintains a focus on student outcomes and how other accreditors can learn from your expertise, and what work are you doing to ensure that graduates from the institutions your agency accredits are properly prepared to enter the workforce with skills needed. Mr. McComis. Thank you. So, as I said earlier, we almost view it as a luxury that we work with such mission-centric institutions that are really focused on employment outcomes. For two decades, we've had quantitative standards around graduation rates, employment rates, and most recently we've added a quantitative measure for licensure rates as well. We've been able to collect that data. We've been able to use it again as a benchmark, not as a floor but as a benchmark to say anything that falls below this, we're going to begin to really ask questions around the quality of the institution and how you're really meeting that mission, and how you're really fulfilling expectations for graduates. The use of that information is then coupled with competency assessments so that we can and the institution can have some relative assurance that graduates that go out into the employment community are actually able to perform the tasks that they set out to do. So, adding those two elements together, student learning and competency assessment piece, so at that institution it's a process they have to engage in, with the quantitative measures and the opportunity for institutions to then provide qualitative responses to their own performance, we find to really be the indication of what sets an accreditable institution apart from one that's not able to meet that benchmark. Mr. Guthrie. Thank you. My time is up. Chairwoman Foxx. Thank you. Mr. Courtney, you are recognized. Mr. Courtney. Thank you, Madam Chairman, and thank you for holding this hearing. It is another example of why we need to do a Higher Education Reauthorization Act, because what we are hearing, I think, from all the witnesses is just how much change has happened since 2008, which is the last time Congress re-upped the law. Mr. Miller, I wanted to spend a minute just in terms of some of your testimony and writings in terms of alternative accreditation to try to deal with non-traditional sort of programs that are out there. This is kind of near and dear to Eastern Connecticut. We have a National Theater Institute, which is also known as The Eugene O'Neill Theater, it has been around for 50 years, it is non-profit. If you went there, it looks like a campus. There are dormitories, there are rehearsal halls, classrooms, et cetera, but it does not have tenured faculty because it is actors, writers, directors, and the term sometimes is just a semester stint that some of the students attend while they are there. However, its graduates, people who have come through there include Meryl Streep, Michael Douglas, Lin-Manuel Miranda did his first play, In the Heights, while he was at Eugene O'Neill Theater, John Krasinski, Jim, in The Office, that you may recall, Jennifer Garner. Again, its batting average is just outstanding, but it cannot get accredited. It cannot extend opportunity through Title IV to a lot of kids who could really turn into tomorrow's Broadway stars or movie stars. How does your sort of ideas maybe connect with programs like that? Mr. Miller. Yes, I think that's a perfect example of the type of thing that we think would be a good fit for an alternative system, basically saying, you know, this is something that is shorter term, it doesn't necessarily end in something that we recognize as much as being a clear-cut degree or certificate, but there's clearly value in it. What we would basically say is if you can show there's value there, if you can show that the people who enroll are able to complete whatever you're offering and they do okay on the back end in terms of we're not sort of leading them into financial risk and ruin, why should we care as much about all these other things we look at right now. Part of the reason we look at all those things right now is because we're not as confident about those outcomes on the back end, so we use sort of up front input checks to deal with that problem. What we're saying basically let's just look on the back end and see what happens. Obviously, yes, there are a range of outcomes that are useful to higher education beyond just did you pay your loans or things like that. We're only concerned about is this a good financial bet for the government. Should we invest in this, do we think it promotes opportunity, and when you think about it that way, you can sort of set aside some of the more complex things that get used right now in the current system as sort of proxies for other things. Mr. Courtney. Go ahead, Dr. Pruitt. Mr. Pruitt. Congressman, this is a wonderful opportunity to point out a rule that just drives me nuts; it's the credit hour rule. The credit hour rule says that accreditors are required to ask colleges and universities to first of all, award credits in credits, and then to define ``credits'' by the number of hours spent in a seat. Now, please tell me how an accreditor could apply that rule to the institution that you just described. It just would be impossible. So, there needs to be flexibility and communities that come and allow institutions like that to prosper and succeed, but it can't happen unless the regulatory context that accreditors have to function in allow it to make it happen. Mr. Miller. May I mention the credit hour? I think one thing that is important to realize here is part of the reason why we needed this rule was we had colleges out there that were inflating credit hours to get more financial aid, so we had schools claiming they were offering courses worth nine credits that did not have the amount of learning behind that. When you do that, students pull down more financial aid than they should, so they're going to exhaust their lifetime eligibility sooner, and we're going to pay money out to schools faster than we should. So, there is credit hours from the sense of measuring how much learning and things like that, and then there's credit hours in the sense that we want to make sure that schools aren't essentially taking in more money than they should, making it harder for students to get enough money to finish their whole program. Mr. Courtney. Thank you. Again, I think as we hopefully get closer to putting pen to paper in terms of a proposed bill, we would encourage you to continue to share with us your ideas about ways you can actually sort of structure it so that there are safeguards, but on the other hand, we are not denying kids who could be the next author of Hamilton the opportunity to learn and succeed. With that, I yield back. Chairwoman Foxx. Thank you, Mr. Courtney. Mr. Lewis, you are recognized for 5 minutes. Mr. Lewis. I thank the chair and thank the panel for coming today. A couple of questions. Let's start with a follow up to Dr. Pruitt on innovation. Right now, the accreditation process is compromised, and I do not want to use the term ``status quo,'' but employees or members of the traditional system of higher education that we have used for so long and so successfully. How do we get independence or maintain independence of accreditors without Federal Government micromanaging, and at the same time, open up the system to these new delivery methods we are talking about, for instance, competency-based education as opposed to just seat-time? So, on the one hand, we have a system of current traditional education, and on the other hand, we do not want any Federal intervention, but we want independence, too. How do we get there? Mr. Pruitt. You get there by focusing on the student learning outcomes, because these are all processes getting to a commonly agreed upon destination. The issue needs to be not how you get there or how the learning takes place or what form does the learning take place in, but does the learning take place, and can you certify it through some valid and reliable assessment process at the end so that you know the standard gets met. The regionals have opened up on that. It used to be that was a problem. If I had been here 10/15 years ago, which I think I probably was, I would be complaining about a rigidity from the accrediting community that stifles innovation. That has pretty much changed in the regional area. The problem we have now is not so much with our regional accreditors, but with the regulations that are coming from the Federal Government. Mr. Lewis. Can you give me an example, for instance, on the massive open online courses, the MOOC classes, and accreditation? Is there an issue there? Is there resistance there? Mr. Pruitt. Well, no, not from the accreditors. Students that go through those experiences can come to Thomas Edison, and if they're willing to go through an assessment process to say I went through a MOOC and I was stimulated, I learned all this stuff, and I want credit for that, they can come to Thomas Edison, and there's an assessment process you can go through, and if you can verify that you in fact achieved competencies that you would have achieved had you taken the course, you can get credit for that. We work with StraighterLine and a whole lot of other non- traditional providers where students that acquire competencies through the non-traditional providers can come, and if they're willing to subject themselves to a valid and reliable assessment process, demonstrate that the learning was acquired, they can get credit for that. The key is the assessment of the learning outcome at the back end and not the process of how you get there. Mr. Lewis. Very good. I want to shift gears a little bit, Dr. Petrisko, and ask you a question that may be off the beaten path a little bit. The Higher Education Act requires accreditors to consistently apply and enforce standards that respect the stated mission of the institution. Much of this hearing and much of our work here focuses on the rigors of curriculum and making certain there is academic competence and all that. A crucial part of a classic liberal education is preparing citizenship or preparing good citizens. I have to say I am very concerned with what I see lately and what appears to be a very highly charged political environment on our Nation's campuses that I think is turning into a bit of a threat to free speech and academic freedom. Again, may be off the beaten path, but is that part of the accreditation process, to ensure that we have open and free dialogue? Ms. Petrisko. If you look at our standards for what we expect for an undergraduate education and for graduate education as well, there are certain things that are stated within those standards. In our case, five core competencies, including one which is critical thinking, which I think would certainly relate to what you're talking about. We have asked institutions and expect institutions to give us evidence of the fact that their graduates actually have achieved these core competencies, which are going to look different across institutions. What Cal Tech is going to do with regard to quantitative reasoning is going to be quite different than what a seminary would do, for example, the broad diversity of institutions we have. Participation in society and citizenship is something that we do expect from our institutions, that students get a broad education and part of that is being part of society and a peaceful society, and a society where they can have interaction. So, I do find it disturbing that there have been a number of cases recently where there have been issues of what's been perceived as restriction of free speech on campuses, and I understand from the campuses' perspective that there was safety and security concerns, which they balance. From an accreditation perspective, I think that's what we expect our institutions to do, to recognize what they exist to do and to do that in a way while maintaining a campus or an institution where people are safe and secure, so how to balance those. We do expect that from our institutions. Mr. Lewis. Thank you. My time has expired. I yield back. Chairwoman Foxx. Thank you, Mr. Lewis. Mr. Polis, you are recognized. Mr. Polis. Thank you, Chairwoman Foxx, and thank you to Ranking Member Scott for this great hearing. Accreditation is an issue that frankly receives too little attention for its importance in higher education, and we really need to make sure that we have an accreditation system that allows for the kind of innovations to create an effective 21st century higher education system. Mr. Miller, as you know, competency-based education allows for innovation in higher education, and credits can be awarded based on competency. It allows for more efficient and better forms of pedagogy that are not tied to seat-time requirements, allowing students to move faster or slower through their degree. I was pleased that in 2015, C-RAC recognized the uniqueness of competency-based education and announced a framework for approving competency programs. Can you share why it is important for accreditors to consider the distinct qualities of different types of education, specifically about CBE, what are some areas where accreditors should take a closer look? Mr. Miller. Sure. I think competency-based education is one of the most exciting things that's happening in higher education today because it's moving beyond the sense of did you just stay there long enough to eventually get a degree versus can you actually show that you learned things and that we're confident you got the knowledge you need to succeed? So, I think it's still obviously developing, and it's slow going because, obviously, every time there is new sort of charted areas, we're looking at that. I think probably the next space to look at is to think a little bit more about flexibility on what constitutes a program. So, right now, we're seeing students who maybe are acquiring knowledge from multiple different areas and how can we sort of cobble that together into something that represents a program. I don't think we should get down to the level of like accrediting individual courses. I think in general the return from any given course is probably not great enough to merit that. We should think about when you've got things coming from multiple areas-- Mr. Polis. Does that not also allow for kind of new combinations of courses, even changing the definition of a ``course'' in terms of ways of getting to a particular outcome? Mr. Miller. Correct. The thing you have to do to make sure this all works though, is you have to keep a laser like focus on outcomes on the back end. Mr. Polis. Thank you. I wanted to go to Dr. Petrisko quickly. As a member of C-RAC, and can you share a little bit about your perspective on the guidance you are working on for competency-based education? Ms. Petrisko. I'd love to talk about competency-based education. It is one of the areas where accreditors really are partnered with institutions to support the innovation that they have seen as important in reducing time to degree and allowing for flexibility and affordability. This is one of the areas where I hope there will be attention paid in the Higher Education Reauthorization Act. A number of accreditors, including us, have been sort of caught, as have the institutions, in supporting this innovation and at the same time, when we had an Office of the Inspector General coming to audit how we do this, being caught with the regular and substantive faculty initiated interaction. These programs work differently. We as accreditors make sure that all the things that have to be taken care of to ensure the quality and protect the students are done. They are going to be done in different ways for different programs. But, the Office of the Inspector General looked at this and said well, these programs don't have the same kind of regular and substantive interaction that its faculty initiated, so there was some back and forth on that. That's just not helpful. Mr. Polis. So, what we can get with competency-based is we care about the outcome, regardless of if you find a way to do it with different interactions with faculty, we care about what the actual outcome is rather than the inputs. Ms. Petrisko. Exactly. Mr. Polis. Back to Ben Miller, I wanted to address another innovation in higher education, coding boot camps and boot camps in other fields that relate to job related certifications. In Colorado, there are a number of boot camps like Turing School and Galvanize. They have great track records of placing students into great jobs, after completing their program, which are usually a few months of intensive work. Unfortunately, these programs are not accredited, not eligible for Federal aid. That means the students either have to take out higher cost private loans or the programs are limited to students who can pay for them themselves. I am very supportive of allowing programs to be eligible for Federal aid so they can serve more at-risk students, but only if these programs have a track record of success, and the transparency and accountability that comes along with it. Can you share your ideas on supporting innovative models like Turing and Galvanize, and making sure actors do not take advantage of flexibility, and at the same time, we give our more at-risk population a chance to attend these types of academies? Mr. Miller. Again, this is something that really hits on part of why we felt the need for an alternative system that is really outcomes-focused would be helpful. A couple of things on that. One is obviously is you keep track of outcomes, then you can have greater confidence that it's okay to sort of lend there, to ease them in. We think it's important that these new providers have some degree of financial commitment up front, so that we have some sense that maybe a boot camp that is only a year old actually has the financial capability to sustain itself, so that we don't run into a situation where we open up the aid programs, lend to people, and then being shut down overnight. I think the other thing is this really speaks to we need to think more intelligently about how we ease people into the system, because right now it is basically like we approve you, and then you're eligible for everything right away, and you can get as much money as you can get students. We should probably think about easing people in, letting them try it with a few students, a little bit more sustainable growth, that acknowledges maybe you shouldn't go from 100 to 1,000 people overnight, and things like that. Mr. Polis. Thank you. I yield back the balance of my time. Chairwoman Foxx. Thank you very much. Mr. Smucker, you are recognized for 5 minutes. Mr. Smucker. Thank you, Madam Chair. Dr. Pruitt, I would like to learn a little more about the peer review process. I just recently met with the presidents of several local private colleges, and I am in Pennsylvania, and with the association that represents many of the private colleges. They have both been part of the peer review process, in evaluating other colleges, and have participated in their own organizations. By the way, they spoke very highly of the Middle States process. With your expertise, your experience working as an accreditor, and your experience in higher ed as well, how have your views on the peer review process changed or been shaped by working on both sides? Mr. Pruitt. Well, first, peer review is more than just peer review. It's peer review. Peer review has to be honed so that the peers that are evaluating you are peers from comparable institutions that really understand your institution. It is true that sometimes--I'm fairly aggressive about talking about mission differentiation, being evaluated by peers that share your same mission, sometimes institutions can hide behind that, so how do you have people that are evaluating you that can call on your own stuff if you're not being really candid and are hiding behind a broader definition of your mission. So, you have to have peers that come in, that are not only from other institutions, but other institutions that understand your kind of institution, so they know when to probe, when to test. They know what kind of data to look for, that if one set of metrics isn't the right set of metrics, what is the right set of metrics. The peer process starts with the developing of the standards, the development of the processes, and the implementation, and then to the teams that evaluate it, and then after the team does a report, that report goes back to the accrediting body and gets reviewed again by a different set of peers to keep some distance and objectivity. The other thing you'll find, and I know it from Middle States, and I believe it's true of the other regionals, the institutions that are in it overwhelmingly support it. There is anecdotal evidence about people that are ticked off about this or that process, and it's always going to be the case, but when you look at an objective evaluation of the data, and we evaluate everything, including how our institutions are satisfied with the process, it's overwhelmingly supported by our members. So, it works very well. It really does. Mr. Smucker. Thank you. You also made the comment and I appreciate it, that compliance is not the substitute for quality. You mentioned there may be compliance things that accreditors can look at now required by either the law or regulation that Congress could potentially remove in the reauthorization of the Higher Education Act. I would like you to expand on that. Mr. Pruitt. In my testimony, there are three that I suggested need to go away. The first was credit hour, for reasons I've already spoken to. The second is State authorization. There was earlier discussion about the triad. The triad does need to be strengthened, and it is reasonable that States should exercise licensure authority over the colleges and universities that operate in their States, and there are a number of States, unfortunately, that have no licensure and no oversight, and that should be changed. The current definition of ``State authorization'' extends that to online courses and even literature. That's just absurd. It destroys the use of technology that shortens time to completion, and kills innovation. The third one is the score card, and I'd love to talk about that, where the Federal Government has come up with a template to try to evaluate colleges and universities, and the results are bizarre. So, those are three things that I'd like to see go away right away. Mr. Smucker. Thank you. Chairwoman Foxx. Thank you, Mr. Smucker. Ms. Bonamici, you are next. Ms. Bonamici. Thank you very much, Chairwoman Foxx and Ranking Member Scott. This is an excellent discussion we are having this morning. I know like many of my colleagues I am concerned about institutional quality, and we have heard so much about places like Corinthian and ITT Tech that provide these recent examples of financially unsound institutions that were allowed to operate as accredited schools for way too long. I know the policy group, Third Way, just noted in a report issued this year that more than 130 accredited colleges and universities graduate fewer than 10 percent of new full-time students. I appreciate the good work that accreditors are doing, but there is no doubt that we should look for opportunities to work together so the accreditation process is really helping to make sure that students and families who invest in higher education are not taking unnecessary risks with their future. I think Mr. Polis left, but I wanted to follow up briefly on his comment about the coding boot camps. I know that many of them have now joined a coalition and developed a framework called the Council on Integrity and Results Reporting, to just try to get some consistency out there with what they are doing. That is a conversation we need to have with alternatives like that. Mr. Miller, I wanted to ask you, the Department's guidance from November 2016 encouraged accreditors to provide more information about the actions they take, and some of the information is made available on the Department's database of accredited institutions. So, what could the Department do to further this effort, and is the database useful for consumers? Mr. Miller. So, this is a really important first step, but it still has a ways to go. We actually try to look at accreditor actions, and before this comprehensive reporting was required, it was a total mishmash. You could look in some places and you could see things for a year, you look at others, they would have it for five years. The reasons why actions were taken were sometimes very clear, sometimes they weren't clear at all. So, getting the information is a crucial starting point. Unfortunately, the database now is not exactly the most user friendly, and I think expecting a student to actually find it is unlikely. You have to download a spreadsheet, and then click through to a link that's contained in the spreadsheet, so nobody is going to get it there. I think the starting point is the Department needs to make sure it's starting to use that information, too. A big part of that is the Obama Administration created an enforcement unit that was supposed to be able to conduct more investigations and feed in information from third parties about problems, and there are real concerns now about whether or not that enforcement unit will be continued in the current Administration, and whether or not it will truly be effective. Ms. Bonamici. I want to follow up. I know that in April 2016, there was a letter to federally recognized accrediting agencies sent by then Under Secretary Ted Mitchell, outlining the power that accreditors have to differentiate in their reviews of institutions under current law. Do you know what steps if any you are aware of that accreditors have taken in response to that letter? Mr. Miller. I know there are many accreditors that are considering different differentiated processes. WASC is in the middle of working on one. I believe the Higher Learning Commission has one as well. I think that's a really important first step. It would be nice to see it go further because I think we should be discussing whether or not there should be differentiated levels of approval for Federal financial aid. Right now, it's so all or nothing that it makes it hard to ease people in, and also ease them out, and we should recognize that a loan is riskier for a student than a grant. I think it's still a little early to tell because we haven't seen exactly how these play out yet, and the process for accreditation is such a long cycle that it's hard to know, you know, if you do something over 10 years, we won't know right away. Ms. Bonamici. And did you want to respond to that, Dr. Petrisko? Ms. Petrisko. Well, just to note that indeed I anticipate that at the next Commission meeting we will approve a process that will allow for institutions that have very strong histories of clear financial sustainability, good learning outcomes, graduate rates, et cetera, that they would have a reduced burden as far as visit and as far as reporting is concerned. Ms. Bonamici. Thank you. Mr. Miller, in 2014, the GAO report found that the Department of Education does not consistently use accreditor sanction information for oversight. After that, the Department agreed to develop better internal information sharing systems to enable its analysts to use the information about sanctions from accreditors to inform the Department's oversight. Do you know if this change has been effective, and what more can the Department be doing to align oversight and enforcement responsibilities? Mr. Miller. So, there hasn't been a ton of public information to judge the effectiveness of this. We do know that last fall one of the reasons why the Department decided to take action against ITT Technical Institute was because of some concerns that came from the accreditor. It is possible that some of the actions against Corinthian may have started with accreditors raising concerns about the accuracy of job placement rates, but the Department has not been completely transparent on it, and again, if the Department does not have the people in place who are really taking a critical eye to looking at the information coming in from accreditors, it will be for naught. Ms. Bonamici. Thank you. As I yield back, I want to recognize Madison, who is here today shadowing me with Girls, Inc. She is a junior in high school, and I hope she found this conversation helpful. Thank you, Madam Chair. Chairwoman Foxx. Thank you, Ms. Bonamici, and Madison, we are very glad to have you with us today. Mr. Walberg, you are recognized for 5 minutes. Mr. Walberg. Thank you, Madam Chair. Thank you to the panel. I think it has been a very helpful panel today. Before I ask my questions, Dr. Pruitt, thank you for helping us to understand very clearly that unless we ask the right question, we will not get the right answer. Thank you for the part you play in really stimulating us to think in new directions, think what works in the present world, not what worked well in the past, that is fine, and because of what you and others are doing, I think both Princeton, University of Michigan, in my case, Michigan State, will be better and will not rest on laurels because of the competition of new ideas that entities like your own bring about, so thank you. Dr. Petrisko, past actions by regional accreditors have raised concerned that some agencies may be acting inconsistently with the HEA's requirement that accreditors, and I quote, ``Consistently apply and enforce standards that respect the stated mission of the institution of higher education, including religious missions.'' I am of the opinion that there may not be a war on, but certainly a battle taking place in society today against some traditional missions, religious values, First Amendment liberties, that are not good in continuing freedom in this country. Certainly, in academia, there ought to be a high priority in saying while we may not agree with you, your mission statement is extremely important for what you are providing for your students. Can you discuss how your agency makes accreditation decisions in light of institutional missions, and particularly religious missions? Ms. Petrisko. I think it is probably going to be surprising to some that about 40 percent of our institutions are actually faith-based institutions in the WASC region. Mr. Walberg. A lot of them are feeling put upon. I mean across the Nation. Ms. Petrisko. Yes, I understand. We absolutely do respect mission, and we understand when institutions make decisions and set goals and set their curricular objectives, et cetera, in line with their mission, that is to be respected. There have been cases where there have been internal struggles at institutions amongst faculty about evolution, for example, and how to deal with that, what should be taught, what may be taught, what may not be taught. We have watched those things closely, but ultimately it is our position that the institutions must allow for that sort of discussion with integrity and honesty while supporting its mission, so not to forbid the conversation but to put forward the tenets of the faith as they see that, but allow that to be discussed. Mr. Walberg. Or to change the mission. Ms. Petrisko. Pardon? Mr. Walberg. Or to change the mission also, is that your position, you are not there to change the mission of that particular institution. Ms. Petrisko. We are not there to change a mission, absolutely not. Sometimes institutions themselves on who they want to serve and how they want to serve them will amend their own missions, but that's not our job. Mr. Walberg. Thank you. Dr. McComis, how does your agency determine and set standards for your institutions and what they are required to meet, and secondly, how do you and other accreditors update your standards to ensure progress? Mr. McComis. Well, again, that is all done within the peer review foundation and establishment for the agency. So, it's really looking at what are the best practices in a particular area, and then utilizing those in such a way that they promote quality, that they promote an opportunity to assess how well an institution meets those standards, and then going back and evaluating ourselves for whether or not those standards actually do what they intended. So, again, it's a process whereby experts/peers come together, say these are the practices we want to hold ourselves and our fellow institutions to, and then creating a process by which assessment can be done for an institution's adherence to and promotion of those best practices. Mr. Walberg. Thank you. I yield back. Chairwoman Foxx. Thank you, Mr. Walberg. Mr. Takano, you are recognized for 5 minutes. Mr. Takano. Thank you, Madam Chair. As has already been mentioned, last year, the National Advisory Council for Institutional Quality and Integrity recommended that the Department of Education withdraw its recognition of the Accrediting Council for Independent Colleges and Schools, otherwise known as ACICS, which the Department did last year. ACICS accredited over 200 for-profit institutions with over 800 locations, including several very large online for-profit networks, notably ITT Technical Institute, which shut down in September 2016. They also accredited Corinthian Colleges before the school shut down two years ago today. The abrupt closures of ITT Technical Institute and Corinthian Colleges left thousands of students burdened by loans for degrees they did not complete. This especially impacted student veterans who lost their post-9/11 G.I. Bill benefits, because they were unable to complete their courses or gain transfer credits. I do not believe accreditors should be--I do believe accreditors should be in the business of protecting students, and ACICS in this case clearly was not protecting the students. My question first is for Mr. Miller, and anyone else who would like to chime in. Mr. Miller, the Obama Administration took steps to strengthen accreditation standards, but what more could be done to ensure that bad actors in the for-profit industry are held accountable? Mr. Miller. So, within accreditation, part of it really needs to be looking more at the outcomes of accreditors and the quality of their standards when they come before review. Unfortunately, the current process of reviewing standards tends to mostly be around do you have something that credibly fills a requirement in law, not is that requirement any good. For example, one of the things we saw with ACICS was it was able to persist with weaker outcomes measures than other national accreditors because it had something that filled the box that just said there's an outcomes measure there. The second thing is we need to make sure the rules that are in place right now are enforced, so we need to ensure that if a school has--I'm sorry, a vocational program has too high debt relative to the earnings of its graduates, that it is held accountable for that, because we need to make sure they are sort of moved out of there. The other big thing is we don't pay enough attention to the possibility of failure and what might happen there, so one is the Department of Education is not nearly aggressive enough in demanding financial commitments from large schools that might go under. As a result, when schools close, taxpayers have to foot the bill and students are out of luck. And, the second thing is the teach-out plan provisions are not strongly enough verified, essentially. When you have these large operators, you need to make sure that the plan for what happens if it closes is actually a real plan and not a piece of paper, so when you've got a place like Corinthian that shuts down overnight, if you just have a plan and no one has actually tested to see if the school that supposedly will take students actually will, then you are putting yourself at a real risk that you might be caught unaware and have serious trouble. Mr. Takano. Well, the Obama Administration also finally issued the gainful employment rule. In your estimation, does this rule help accreditors ensure that institutions are best serving students? Mr. Miller. I think it absolutely does. First of all, it puts out there numbers that we never saw before about the actual earnings of graduates, which is a very important outcomes measure that we didn't have before. I think it could go further. The biggest risk is it doesn't look enough at how many students are actually finishing, so it's only focused on graduates, so essentially if a program enrolls 1,000 people, 10 make it through, it may look okay on gainful employment even though there are a host of other problems that aren't captured there. It should be providing a wealth of additional information for accreditors and giving them cover because something else is going to step in and remove a problematic actor so they might not have to. Mr. Takano. Dr. Petrisko, you look like you want to say something. Ms. Petrisko. I did want to say something about Corinthian and ITT, just to remind everyone that accreditors do not accredit the parent company of these institutions. We accredit the institutions. We have learned from the past failures that we must have the information from the parent that is going to affect those institutions. What was also the case with regard to Corinthian was the Department of Education had information that we did not have as accreditors, so there's an issue about who has what information at the State level, the Federal level, and the accreditors, how is that information shared appropriately, may it be shared, what can be shared, so that any of the players in that triad have a good foundation for the actions that they take. Mr. Takano. I do not have enough time to get an answer, but I do want to put the question out there and maybe take it for the record. I am interested in the programmatic accreditors and what I see as possible inflation or credential inflation. I am thinking of community colleges who used to be able to offer physician assistance programs, those programs are now requiring Master's level work, and also the movement towards the bachelor's of nursing degree. I realize there is interplay with industry here, but I want to be able to get reactions from some of you about whether or not you believe there is inflation of credentials. I yield back. I am sorry for going over my time, Madam Chair. Chairwoman Foxx. Thank you, Mr. Takano. Dr. Roe, you are recognized. Mr. Roe. Thank you. Thank you all for being here, and thank you, Madam Chairwoman and Ranking Member Scott. Obviously, the idea in Tennessee, we are very committed to education and training our people, community college is free in our State to residents there, and we have a Drive to 55, where you can go to either a Tennessee college or applied technology and get a certificate or a degree, and we found that in those particular schools, 90 percent secure a job upon graduation in their field, whether it is nursing assistant or phlebotomist, whatever it may be. I was 18 years old when I started college. I did not have a clue what I was going to do. Vietnam war focused that pretty quickly for me. I decided I was going to do something in college. Dr. Pruitt, your students are different, and there are people I see every day in my community who have lost their jobs or whatever and are going back while they are working to try to get some skills so they can take care of their families. I applaud you for what you are doing at your university. I think it is incredibly valuable. I guess for the accreditation part, once I figured out what I was going to do, could my college get me into medical school. That is what I was interested in. If I could pass the courses, could I then pass exams. I had a plan. It could. I did not know whether it had an accreditation or not, but it provided those assets and benefits for me as a student because I had an idea about what I wanted to do. I think in doing the accreditation, I watch it in medicine today, how you measure success, how is that done, and then how do you define it. I think defining it could be graduation rates, it can be certificates, it can be a lot of things. I think that definition needs to be broadened, and certainly, how do you simplify the reporting. I will give you an example, a 2015 Vanderbilt report on the cost of regulations in higher education estimated that the accreditation costs of compliance was $3.4 billion a year for regional accreditation. Does that actually bring value to me because I know who is paying for it, the students. I have written a lot of checks to colleges for my kids to go to school. It is not nearly as affordable as it used to be, so does it really bring value. I want to stop and just ask these three questions quickly, and I will let you take the rest of the time. What are the regulations that are preventing accreditors from focusing on student outcomes? Number one. Number two, are there duplicative data collection requirements the Education Department makes on accreditors and schools? Number three, how can innovation in accrediting be encouraged? Those three, any of you can take off on any of them. I will pick on you, Dr. Pruitt. Mr. Pruitt. Well, there's a long answer to that. There are a lot of things that need to be changed. I think how you define ``success'' is relative, and that's also very important. I certainly think if you go to a school, either a professional school or a graduate school or proprietary school that is preparing you for a profession, you ought to expect that if you meet the requirements of the institution, that you ought to be able to pass the licensure exams to participate in the profession. If you go to medical school, they have like a 98 percent pass rate. If you go to medical school and graduate from medical school, you're not worried about whether you're going to pass the exam to participate in your profession. Mr. Roe. Actually, yes, I was worried, but I did pass it. Mr. Pruitt. I'm going to take a risk because my data is about nine years old, but when I was on NICIQI, I had a real problem with the bar association because law schools are very selective and very expensive, but the national pass rate from accredited institutions, law school, was around 70 percent. In some cases, it was lower than that. John Kennedy graduated from Harvard and couldn't pass the bar exam. There is something wrong with that. If you're going to a school to be a nurse or a teacher, you ought to be able to pass your licensure exam. Your ability to participate in the profession that you're going into ought to be a factor in accreditation in terms of being able to value the accreditation that you get. The regulatory environment takes good ideas. The rules that I'm complaining about, in their concept, they make sense. I think gainful employment in its concept makes sense, but the way it got operationalized doesn't make sense. If you look at the list of bad actors under gainful employment, Harvard is on that list. So, the challenges, how you take something conceptually sound, the rules that we have to execute make no sense. There needs to be a reengagement between the regulators and the community, and we used to have that. We lost that. That reengagement needs to happen again so we can take the good ideas, work through the consequences and operationalize in a way that satisfies the public interest and also meets the needs of the professions. Mr. Roe. Thank you. I yield back. Thank you very much. Chairwoman Foxx. Perhaps the witnesses would be willing to give Dr. Roe answers to his questions in writing. That would certainly be very helpful. Ms. Adams, you are recognized. Ms. Adams. Thank you, Madam Chair. Thank you, Ranking Member Scott. Thank you to all the witnesses for being here. Dr. Pruitt, good to see you again. Mr. Miller, how was the Department's decision to publish accreditor's standards for evaluating student outcomes improve the accreditation system, and could this be constituted as an overreach? Mr. Miller. I don't think it is. I mean basically what the Department of Education did was went on the websites of all accreditors that already make their standards public and essentially put them all in one place. I think it's more of a useful starting point in the conversation because you can start to see how things vary and understand maybe there's a good reason why something varies, but also start to raise questions about why is it that a branch of one publicly traded for-profit college has to hit a 70 percent placement rate at say ACCSC, and maybe only needs to hit 60 percent at a different accreditor. So, I think it's a good starting point to start to ask why do things vary and where is the right line between consistency versus variation? Ms. Adams. Thank you. In your testimony, Mr. Miller, you mentioned that one way to improve student outcomes through the accreditation process is to increase Federal minimum requirements for student financial aid. Would you explain what the current student loan performance metrics are, and how you would recommend that Congress strengthen these metrics? Mr. Miller. I mean, the big problem we have right now is the only real measure of student loan performance we use is what's called the cohort default rate, which essentially asks what percentage of borrowers default within three years of leaving school. The problem is right now it's just a cliff. So, essentially if you're nowhere near that 30 percent rate, you don't have to worry, and functionally basically nobody fails this. So, in the most recent data, I believe it was 10 schools that had about 600 and some odd borrowers total--sorry, borrowers in default total, that failed that test. So, 99 and some odd percent of schools and borrowers aren't affected by this rule. So, I think the big thing we need to think about is measuring other problematic loan outcomes that aren't captured now, particularly people who can't repay their loans, because one of the problems we're seeing is students maybe aren't defaulting, but they're not making any progress actually getting rid of their debt, and the only other fix we have available to those people is we say to them in 20 years, basically half your working lifetime, if you do the right things and keep up with all this paperwork and stuff, we'll forgive your loan, and that's a long time to make people wait if they have borrowed a loan that's not helping them. Ms. Adams. So, what steps could the Department of Education take right now to encourage accreditors to begin working with an institution before it has to close and students have to look for a new school? Mr. Miller. So, I think one is really trying to take a more risk-based approach to say, you know, we have some schools here that maybe they only have 100 students, so if they close, the risk and the complexity is not that high, but once we get schools that have thousands and tens of thousands of students, we should say what are the plans in place in case these things go under? It is almost actually some of the same conversations we had around the big banks, like are we stress testing schools to make sure they are sound, do we have a plan in place in case they fail, and are we actually testing that plan? So, are we calling those schools listed on that teach-out plan to see how many would you actually take, and will you actually take them? Are we making sure that the places that are on that teach out plan actually have good results, and we're not going to basically kick students from one school that had a bunch of bad outcomes to another that also got a ton of challenges as well, and actually make sure we are thinking about what happened and we are taking risk into account. You know, a place that gets $1 billion in Federal financial aid is a much bigger risk to taxpayers and to students than one that might get $500,000 in Federal aid. Ms. Adams. Thank you very much. I spent 40 years teaching on the college campus in Greensboro, North Carolina, been through many, many accreditations. I have learned a lot here today, and I thank you very much, Madam Chairman, and I yield my time back. Chairwoman Foxx. Thank you very much. Mr. Allen, you are recognized for 5 minutes. Mr. Allen. Thank you, Chairwoman, and thank you so much for your insight today as far as the college level. Dr. Pruitt, I am particularly interested in what you are doing at Thomas Edison State University based on your testimony. I called all of our school superintendents or met with them while we were in the District, just to find out about the school year, how it is going, graduation rates, that sort of thing. The highest graduation rate we have is in a rural county. I said how are you doing this. He said well, we are actually teaching the children to get an education, to get a job first. We are also giving them the skills that if they want to go to college, they can do that, too, rather than the other way around. In other words, rather than teaching students to go to college, we are teaching them the reason they are getting an education is to get a job. It sounds like based on your student population that most of your students have careers or what not, and are now saying you know, I want to learn more to move up the career track. I know even with my own children, they entered college on one track and said well, I do not know if that is what I want to do, so they are kind of back and forth. They had worked in our business, but that was kind of all they had done. Well, I think I want to do this. We are spending a lot of money on education. Of course, I hear, too, that the career tracks are very successful as far as graduation rates. In other words, if you can get young people to understand kind of where they want to be in life early, they just get on that track and they are energized and motivated, and that sort of thing. Tell me how that is working, and I want to ask the accreditors, do you look at that as far as accreditation. Go ahead, Dr. Pruitt. Mr. Pruitt. Most people ask- see our student body, they want to know why are your students there, because they are older, most of them are all working. They are very diverse in their characteristics. We have students that are 25. We have had a graduate that was 92. When you ask them why are you here, it's one thing that comes back; it's unfinished business. They started college-- pretty much 90 percent of our graduates come to us with previous college. They started college and life got in the way, or they weren't ready, or there were financial issues. There weren't institutions like ours around that could accommodate them. So, it was an unfilled life objective, and that's who most of our students are. They are self-directed, they are well motivated, they are there because they want to be there, and they have powerful outcomes. I've given you the data. A lot of that is because of them, because they are self-directed goal oriented. They are there because they want to be there. Most of them are paying their own way, so they take the experience very seriously. But you raised a really good question. We have to not over simplify things. To ask an 18-year-old to know what they are going to do for the rest of their life is not wise. Most 18 year old's don't have a clue. Only 22 percent of the people in this country are in professions related to their undergraduate major. Seventy-eight percent of us are in areas that had nothing to do with our undergraduate major. I think higher education ought to be accessible and an opportunity for everyone, but that doesn't mean everyone needs to go to colleges and universities. You could make a good case in terms of economic benefit-- Mr. McComis' graduates outperformed teachers, nurses, doctors, lawyers. I know I am paying a lot of money to a diesel mechanic right now. The issue is--I don't want to get too preachy, but if you go back to Thomas Jefferson, Jefferson said, and I'm paraphrasing, but basically the future of the country is dependent upon the quality of the human capital, of our people, and education is the vehicle developing that human capital. So, the issue is if you create and build the capacity of an educated person, let them have choices and options about how they want to pursue and develop their life, be it higher education, be it vocational, technical training, and have them prepared to be able to make those choices, the country will be okay. Mr. Allen. That gets back to accreditation. I think in some colleges, they are misleading these young people. Did you have a comment on that? Ms. Petrisko. I just wanted to say there are many paths through life, many paths to and through education. Some students will know when they are six years old what they want to do and what they want to be and they follow that through forever. Others don't know, change their minds, change careers, find the wrong institution, et cetera. I think accreditors absolutely recognize the diversity, we recognize the diversity of institutions, we recognize the diversity of students. I don't think institutions mislead students. I think institutions provide opportunities for students to figure out what they want to do and how they want to get there, and provide the support to do that. They don't force them. They support them. Mr. Allen. I think we could do a better job. As usual, I am over time. I yield back. Chairwoman Foxx. Ms. Blunt Rochester, you are recognized. Ms. Blunt Rochester. Thank you, Madam Chairwoman and Ranking Member Scott. I want to thank the panel. This has been a really great conversation, the questions, across the aisle. It's been incredible. When I think of accreditation, I think of not just the institution but I think of parents, as a parent of college students, I think of the students. I think of employers. There are so many pieces to this. I stepped out of the room for a moment because Delaware's Teacher of the Year, Wendy Turner, is here, and she actually started her career as a teacher later in life, so it was a career change. My question touches on Congresswoman Bonamici and Congressman Polis' comments about the boot camps. In Delaware, we actually have a great program. It is called Zip Code Wilmington. It is a non-profit. It is a 90-day intensive software development boot camp. It was developed both with the employer community, both local and nationally. It actually is in partnership with Wilmington University and participated in the U.S. Department of Education's Educational Quality Through Innovative Partnerships, or EQUIP Program. The great thing about it is there are Pell eligible students that get to participate in it. I guess my question is for Mr. Miller but others can answer as well, about these kinds of programs that are unique. It is a partnership between a non- accredited program, teaching entity, and an accredited university. They even can get college credits and go on to get a Master's degree or Bachelor's degree. The success rate is incredible. How should we evaluate the success of programs like these that partner career training programs with accredited institutions? Mr. Miller. I think fortunately because these are short term programs and they have very clear discernable goals, you really start with the question of are people finishing them and what is happening to them after they finish. We just want to make sure, you know, are most people walking in the door graduating, and then are they able to get jobs and sort of sustain themselves. I think the trick here is we should ask that question not just three weeks after they leave, but try to look at it over time, too, so we can see is this really worthwhile, is it working, et cetera, and that we need a process in place to sort of verify if those outcomes are true. I think this is also a good example of where we should be experimenting more. I mean there is flexibility in the Higher Education Act around trying out sort of new methods, new models, et cetera, and EQUIP is a perfect example of it. And I think this safe space for Innovation with flexibility that says, you know, you're a good actor, you have good outcomes, we're going to trust you a little bit more to try something new, is how we should approach it. Unfortunately, what we have done in the past, we sort of tried something, we think it kind of works, and we blow the doors open to everybody, so your first 15 actors are great, your next 15 are so-so, and then your final 15 after that are bad, and you sort of ruin the model for the good actors because the bad ones have come in and sort of exploited it. Ms. Blunt Rochester. Quickly, are there any concerns that you have about programs like this? Mr. Miller. I mean I think the only major concerns is just that they are pretty new, so we just don't have a great sense as to what the long term outcomes look like, and we don't have a great sense of their financial stability. The other thing I would just say is some of the other boot camps got started really sort of educating people who often already had a Bachelor's degree and maybe had a couple of years of work experience, so you probably are looking at changing the population in some of these places, and I think we just want to make sure that they are figuring out how to serve people who might be slightly different learners than the ones they had at first, and their model is also working for them, or if it's not, they are adapting it accordingly, and they're not sort of saying this worked over here, let's try to do something with completely different people and just assume it will work. Ms. Blunt Rochester. Anyone else? If not, I just want to say you guys, this was a great panel. Thanks, Dr. Pruitt, for the history and the preaching, too. That was good. Mr. McComis. We have had some experience. We have had some interest and inquiry from some coding boot camps. We have also received some cautionary tales from some other States, not as successful as Delaware, in this particular regard. So, on one hand, accreditors do serve a risk aversion role and a protection role. So, finding the right balance between those new entrants, those new providers, how to bring them into the system, I think as Mr. Miller said, slowly and with some eye towards potential success without having a whole lot of past success to rely upon, which is really what accreditors use now in making their assessments about who gets into the process and who gets to go to the next step. Ms. Blunt Rochester. Thank you. I yield back my time. Chairwoman Foxx. Thank you very much. Mr. Grothman? Mr. Grothman. Great. A general question. This can be for any of you. I do not believe we have touched on this, because there are criticisms of the accreditation programs in a variety of areas. I have heard some evidence in which people feel there are arbitrary standards and universities sometimes have to spend money on things that may be unrelated to the actual development of the student. Can any of you comment on that or think of any anecdotes that would apply to? Mr. Pruitt. You know, one of the things that Middle States did through its last process was to listen to its critics. We invited critics from all over the country to talk to us. We took our standards and threw them in the wastebasket, and we started all over again and completely redid them. Most of the criticisms we got came from the things that we were forced to do because of the compliance issues of the Department. So, on the new standards, we bifurcated them. We basically said here are the things that we don't think are particularly useful, and you know, you don't think are particularly useful, but we have to do them because we're required to do them. Here is the quality assurance piece that your peers have put together that says these are the things we think you have to do to meet our qualitative standards. Probably 90 percent of the problems that we had were from people that were concerned about the compliance side of the house, which we had no control over, and once we separated them, it had a remarkable outcome on the buy-in we got from our 500 and so institutions on the assessment side, because they saw their community was really looking at the right things. Mr. Grothman. Can you think of examples of things that universities had to do in the past that you felt cost them money but had nothing to do with quality of education? Mr. Pruitt. If you go back a little bit, accreditation was an input-based system, how many books did you have in the library, what was the square footage ratio, what were the student/faculty ratios. A lot of things that weren't necessarily tied directly to learning outcomes. That has pretty much changed, and certainly with the regionals, that's gone. That is really not the case anymore. There are still compliance costs we have in terms of the reporting, the data requirements. I have four people at my institution that do nothing but collect data to fill out forms to report information that doesn't get used very well. My colleague here talked about the IPEDS stuff, they exclude my whole student body, the reporting requirements and financial aid, we have to notify the Department every time a student drops a course. We start a semester every month. We don't operate on the traditional calendar. The complexity of just trying to keep up with the reporting requirements is very costly and expensive. I understand why the Department wants to know about student engagement behavior, because they want to know if you change your eligibility, they want the financial aid cut off, so I get why it is coming, but the burden of complying with it is enormous. The overhead costs of managing Federal programs in some cases is not worth having the programs. I could give you a lot of details on that, but that's-- Mr. Grothman. Maybe one more quick thing. I think there is to a certain extent a trend towards MOOCs, these big huge courses. I think a lot of time those courses, at least common sense would tell you, are superior to the courses being offered in the traditional fashion, better professors, way better professors. Could you comment on if you feel there are any unfair barriers to students using MOOCs more, and just in general, do you feel they are to become a bigger, bigger share of our education? Ms. Petrisko. I'd like to answer that. I'm going to try to tie two things together here, and that is what is restricting in regard to innovation and these other kinds of things. One of the things that is currently a requirement for accreditors is that if anything is considered to be a substantive change at an institution, something really different than what they've done before, it must go through accreditor's review and approval to be able to be eligible for Federal financial aid. There is not a lot of flexibility. There are some very clear and defined things that we must review, although education has gone beyond these things as being actually substantive changes in the institutions. That costs institutions time and money. For some things like the MOOCs, for example, some other things that might be new that are very innovative and effective, we still have to approve them. We would like to have the flexibility as accreditors to determine what really does count as something that is substantive that we need to review, and where knowing the institution inside and out as we often do, where the flexibility can be granted to the institutions to go ahead and do that without that cost and burden. Mr. Grothman. Thank you very much. Chairwoman Foxx. Thank you, Mr. Grothman. Mr. Mitchell, you are recognized for 5 minutes. Mr. Mitchell. Thank you, Madam Chair, and thank you to all of you, and for your dedication to addressing this issue. I spent 35 years in postsecondary education with a private career school group, in fact, sat on an accrediting commission, not one of those discussed today, let's put it that way. Dr. Pruitt, I absolutely agree- your comment about accrediting agencies existed long before it got tied into Title IV. I think it reflects the need to address the world of accreditation. As we talk about the Higher Education Act, we need to start with what should the role of the accrediting agencies be. They have evolved into being a regulatory agency, a gatekeeper, which makes it a tremendously distorted approach. I saw it in my career, I saw it on the accrediting commission. We have to recognize that the failures that we see in accreditation simply reflect the failures in postsecondary education and in all sectors, not just the for-profit sector, but in fact in the non-profit and public sector. There is a direct link between--at least an indicated link between graduation rates and default rates, yet some groups argue that we cannot measure graduation rates or we should not measure graduation rates, but only 55 percent of freshmen in 2010 now possess a degree or certificate as of 2016. We know what the likelihood is, they are more likely to default. Rather than set up another oversight--I have forgotten what Mr. Miller called it, the quality assurance group, another regulatory burden, why is it we do not create a mechanism to provide consumers information, valid information, so they can assess the value of education to their future career. What is so hard about doing that and putting out that information so that families, citizens, and taxpayers can see what they are getting for their money. Yet, we seem to struggle with that. Dr. Petrisko, enlighten me what we do to get there, because I think consumers desperately need that to understand the burdens they are taking on. Maybe Dr. Pruitt, you may want to weigh in, too. Please. Ms. Petrisko. So, one of the things that we do requires that all of our institutions make public on their website what their student learning outcomes are. Then you go to our website, and there is a page for every institution that we accredit and outcomes, and there is a link where you can go directly from our site-- Mr. Mitchell. Let me stop you, you know and I know from my experience with Michigan State University, there is a significant difference between the outcome of the nursing program and the architecture program. It has a fundamental impact on if people knew that, whether or not they would choose to invest in it. Let's be honest, investment in any institution here is based on what is the likely outcome, whether they are going to be successful. What is so hard about drilling down on that data, provide that to consumers and families? Ms. Petrisko. Well, what we do as an accreditor, and perhaps you can comment on whether you think this would be a good thing to put out to the public, what we require as an accreditor is that every institution provide us at the time of reaffirmation, at a mid-cycle review, getting us updated, what their learning goals are, evidence those goals have been achieved, who is measuring them, what they're doing about it, and when their program reviews are. We do that at the institutional level, we do that for general education, we do that for every single program. One of our large campuses at the University of California has 580 programs, so we do ask that for 580 programs. That can be drilled down even further. I think it's a question about how to present that kind of information at that level in that much detail to the public. Mr. Mitchell. You may not want to go with 580 programs, do it by college. You did not indicate employment rates in terms of the metrics you're talking about. Maybe they are in there and I do not know. Ultimately, most of the students that go through your institutions went through ours. They came there to theoretically get the skills to go to work. Ultimately, to pay their loan back hopefully. Why are we not reporting that in most institutions other than private and for-profit? Why do we not gather that information and report it by program? Dr. Pruitt, do you have a comment? Mr. Pruitt. I think the key is with a lot of the data is what is the reasonable expectation of the program. If you're coming to a program, if you want to be an architect, if you want to be a nurse, if you want to be a teacher, it's reasonable to say what is the performance of our graduates in these areas? If you're coming in a program where there is no expected definable employment outcome, you are just coming there to be educated to increase your own capacity, it's harder to do. I do think we should and many of us do, if you look at our websites, you will see that kind of information, and most of us like to put it up there because we like to brag about it. The stuff I told you this morning about us, because we wanted to brag about it. If it wasn't good, I probably wouldn't have told you about it. We want to do that. The issue is the system is very complex, so the challenge is how do you come up with useful data that reinforces and gives you incredible information on which to make an informed judgment in the programs where you need that information to decide, and that varies by program by program, by institution by institution. Mr. Mitchell. One of the things I would like to talk to you further about is the comment you made about the intended outcome. I guess one of the questions is ultimately it is taxpayer money being invested in the education of adults, helping them vocationally. Is it wise to use taxpayer money for general education from Federal financial aid. I think it is a question we need to address and goes to some of your concerns. What are we investing in both as taxpayers, through Pell grants, Title IV, and through State agencies. It is a huge amount of money. Mr. Pruitt. I'd love to finish that conversation with you. That's a long one. Mr. Mitchell. We are out of time and the chair has been patient with me, so thank you for your feedback. Thank you. Chairwoman Foxx. You have been very patient, too, today. I want to thank our witnesses again for taking the time to testify before the committee today. I think from the comments you have heard from all the members, they have benefitted a great deal from your testimony and from this event. I do not think people's comments were just perfunctory. I think they really mean that, and I certainly mean it from my perspective. I would like to now recognize Ranking Member Scott for his closing comments. Mr. Scott. Thank you, Madam Chair. This has been a great hearing. We got a lot of good information, and it appears accreditors can identify those institutions of higher learning that should be eligible or ineligible to participate in the Federal student financial aid programs, as well as providing important information that students should have when deciding how to assess the right postsecondary education program. The fact that some institutions maintain accreditation right up to the day they collapse is evidence that more needs to be done. The Federal Government has $150 billion a year interest in getting this right. So either the accrediting agencies, who should be in the best position to judge the quality of education, must credibly make the assessments, or the Federal Government will have to figure something out that is both fair and workable. Hopefully, the progress we have recently made will continue so we can rely on the accrediting agencies to assess the quality of our institutions of higher learning, and I thank the witnesses for providing us with good information, and I yield back the balance of my time. Chairwoman Foxx. Thank you, Mr. Scott. I have found this to be a very interesting discussion today, too. It raises a lot more questions for me. I am a little sorry I asked my questions first. I would like to come back and ask more, but we do not have time for that. I think one of the major questions raised, particularly by Mr. Mitchell, right at the end, is a big discussion going on in our culture, and that is what is the purpose of ``higher education.'' I often say that education in our country is basically the only institution that has not changed for 150 years. We're still operating on an Agrarian Model. Nine months out of the year, it started out a long time ago three months out of the year. It really has not changed, although we have a lot of alternatives, and I think that is wonderful. I asked Ranking Member Scott when the question came up about only 22 percent in jobs related to their degrees. I was an undergraduate English major. I often point that out. That should have prepared me for a lot of different jobs, I believe. I am a firm believer in liberal arts education, but I saw an article this week that said we have to go more into skills development and away from liberal arts education, but I think what we are blessed with in this country, and I want it to stay that way, is we have a diversity of institutions who are there to meet the needs of many different people, and the needs of our culture. I think we should celebrate that as much as we possibly can. I thought, Dr. Petrisko, of your comment about one of the objectives of some schools is to teach critical thinking skills. Yet, I read reports all the time that say 34 percent of employers say their employees have no critical thinking skills. How are we getting at measuring those kinds of things? It is true, I completely agree with Ranking Member Scott, we are investing--this is a case where we are spending a lot of hard-earned taxpayer dollars in these institutions, and we need to know and the public wants to know if it is getting something for its money. I am happy for the issues to have been brought up about some for-profit institutions being closed precipitously, but what troubles me is the total lack of concern that the previous Administration had with the students in those institutions. It seems to me it was so unkind for the Department to simply pull the plug, and I cannot blame the accreditors for the students having the problem because it was the Department who said we are cutting you off from your money and then they closed, without the ability to teach out, without the ability to help those students make a transition. That was not the fault of the accreditors, I do not think. The accreditors may have had a responsibility. That was the fault of very uncaring people in the Department of Education in my opinion, who did not give one thought to what was going to happen to the students. I want for every student in this country, and I believe Ranking Member Scott does, to have the best possible educational experience wherever that occurs. We have to decide as a people are we going to subsidize that educational experience. Again, with taxpayer dollars. There is a huge range of issues here to deal with. We cannot take care of all of them in a hearing on accreditation. I think this has helped us. I think one of the things we did not touch on at all that I have to bring up and that is are the accreditors looking at the caliber of the students being admitted, and what is the responsibility of the institutions for admitting students who cannot graduate, who do not have the skills, and that is a topic I think for another day. Lots and lots of issues. I asked the staff while we were talking because I remembered looking at Kiplinger's Best College Values, there are institutions in here who after four years have a 19 percent graduation rate. Lots of issues, not many answers, but lots of issues to deal with. I thank you for helping us look at some of those issues. There being no further business, the committee stands adjourned. [Additional submissions by Ms. Petrisko follow:] [GRAPHICS NOT AVAILABLE IN TIFF FORMAT] [Whereupon, at 12:21 p.m., the committee was adjourned.] [all]