Sylvia Manning, former president of the regional accrediting agency, the Higher Learning Commission, who was also infamously embroiled in the closure of Altius Education, has published a paper with the American Enterprise Institute on—ironically—how to make way for innovation through accreditation.

Briefly, accreditation acts as the gatekeeping mechanism for federal financial aid in higher education. In this report, Manning describes a chicken-and-egg conundrum of accreditation: new institutions cannot get accredited unless they have students, but in order to have students, you need to attract them with access to financial aid. In other words, she explains, it “is not possible to both preserve the time test of accreditation and hurry up accreditation for new institutions.”

Manning draws a useful analogy between this chicken-and-egg problem and construction/occupancy permits: “In higher education, accreditation is the occupancy permit that allows a school to operate, yet there is no building permit equivalent to facilitate new entrants coming into the market.” Her solution therefore is to create the equivalent of a building permit for higher education institutions so that they can at least be “provisionally approved for federal student financial aid.”

It sounds logical to think of alternatives to this serious barrier to entry, especially given that it seems unlikely that accreditation will suddenly disappear anytime soon. Manning’s building permit, however, is a conservative argument for further reliance on a broken system that sustains and protects the trajectory of established institutions while inevitably erecting barriers to keep entrants out. Indeed, in her defense of accreditation, Manning actually underscores how agencies are ill equipped to foster radically different forms of education. Consider these key phrases from her report:

  • Accreditation per se is not a barrier to innovation, but it is inherently conservative. Yet there are good reasons for its being conservative and good reasons not to make it any less so.
  • Accreditation agencies have no particular interest in the status quo, but they approach with caution any radical elimination of the basic conditions that have underpinned sustainable institutions.

Such statements unfortunately do not, as she asserts, “la[y] to rest the canard about accreditation and innovation.” Rather, they make obvious that “new” in Manning’s parlance is not necessarily synonymous with “innovative.” Provisional access to Title IV dollars may work as a potential stopgap but serves primarily as a sustaining innovation. Manning views this as a way to “pu[t] an end to the demands that accreditation change its standards or procedures….”

This paper reinforces that all roads still lead to accreditation. Manning does not question accreditation as the gatekeeper to federal funds even though it was never, in the words of AEI authors Rick Hess and Andrew Kelly, “intended to serve an external accountability role.”

Accreditation defines excellence according to an existing set of value propositions. “Because there are so few measures of actual quality of outcomes in higher education,” USC Provost Emeritus Lloyd Armstrong explains, “this naturally leads to considerable regulation of the resources and processes traditionally required to create such excellence.”

Accreditation does not do an adequate job of measuring quality, even with its member institutions—not to mention the more modularized and unbundled kinds of learning that are gaining traction at the margins of the higher education ecosystem. Manning even acknowledges that accreditation is like “a bet that, based on current evidence, the institution will continue to offer an acceptable level of quality in the education it provides.” It’s not exactly heartening though if the only lever and link to federal financial aid is, at best, an approximation.

The de facto measures therefore have been perceived quality. With a dearth of data around the outcomes of graduates, prospective students are left with imprecise proxies such as brand, prestige, rankings, and price. We need to figure out better measures of quality particularly as the gamut of postsecondary learning pathways widens and resembles less and less the kinds of offerings traditionally found at colleges and universities today.

It seems likely that there will be a need for some new seal of approval—outside of accreditation—for alternative learning providers. I’ve explained in another blog how non-accredited institutions with more to prove would be the ideal sandbox in which to test what my colleague Michael Horn calls the Quality-Value Index. For the short-term and especially so long as federal financial aid dollars are desirable, access to different and transparent performance metrics and student outcomes might enable non-accredited providers access to Title IV money.

But another provocative, albeit long-term, solution exists that accreditors and many institutions tend to underestimate: the obviation of accreditors as well as the need for financial aid dollars. Who better than employers to assess the quality of alternative—not to mention, affordable—learning pathways? As the ultimate consumers of students, employers have the ability—and, it would seem, the incentive—to validate learning experiences that may deliver prospective job candidates that are just as qualified—if not better suited—for the opportunities at hand.

Industry validation has the potential to serve as a powerful mechanism to validate upstart providers and ultimately override the existing stranglehold of college rankings and accreditation. That would be truly disruptive and upend the current chicken-and-egg games around access to federal dollars.


  • Michelle R. Weise, PhD
    Michelle R. Weise, PhD