C-RAC Highlights Opportunities to Improve Higher Education Quality, Innovation, and Affordability

WASHINGTON, D.C. – Dr. Heather Perfetti, chair of the Council of Regional Accrediting Commissions (C-RAC) and president of Middle States Commission on Higher Education, today offered comments on behalf of C-RAC during the Department of Education’s public hearing to gather input on the Department’s plans to establish a series of negotiated rulemaking committees that will assess a range of policy matters, including accreditation.

The full transcript of the remarks is appended below:

My name is Dr. Heather Perfetti, and I currently serve as the President of the Middle States Commission on Higher Education and as Chair of the Council of Regional Accrediting Commissions, also known as C-RAC. I am here today, on behalf of C-RAC, to discuss the Department’s intent to establish negotiated rulemaking. 

We look forward to being part of discussions which examine how current regulations may be inhibiting innovation and contributing to rising college costs. C-RAC has always offered ways to address these and other issues by streamlining or eliminating unnecessary regulatory processes that are not otherwise required by law.

Institutions and accreditors would benefit from reduced regulatory burden in some areas to both allow for more innovation while also addressing issues of cost. We want to draw attention to several specific areas as examples:

First, the recognition and renewal process of accreditors. Aspects of current regulations could be streamlined to facilitate the recognition of new accreditors while holding all accreditors to the same standards and expectations. Reviewing the current process of renewal could also result in a more streamlined and efficient system. 

Second, the process for institutions changing accreditors. The Higher Education Act has for decades allowed institutions to move from one accreditor to another. However, recent regulations as well as sub-regulatory guidance have led to confusion and at times lengthy delays in this process. Reviewing existing policies and actions can help better streamline this process.

Third, re-examining definitions. Definitions of “distance education”, “competency-based education,” and “credit-hour” should be reexamined to determine the extent to which current regulations inhibit innovation in any of these areas. 

Fourth, providing increased flexibility regarding substantive change. Current regulations require accreditors to approve a wide variety of actions considered as “substantive changes.” Accreditors should be provided more flexibility to determine when such approvals are actually needed to prevent unnecessary and costly reviews.

As in past negotiated rulemaking efforts, C-RAC welcomes the opportunity to participate in a full review of current regulations to ensure consistency with the Higher Education Act. We appreciate the opportunity to share our input and help the Department drive quality, ensure accountability, and protect students through sound federal policy. We look forward to working with the Department to address these and other issues, and I thank you for the opportunity to be here today to share the position of C-RAC.

For more information, please visit www.c-rac.org.

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About the Council of Regional Accrediting Commissions (C-RAC):

C-RAC is a collaborative of the nation’s seven federally recognized institutional accrediting commissions, including the Accrediting Commission for Community and Junior Colleges, Higher Learning Commission, Middle States Commission on Higher Education, New England Commission of Higher Education, Northwest Commission on Colleges and Universities, Southern Association of Colleges and Schools Commission on Colleges, and WASC Senior College and University Commission. Collectively, C-RAC is responsible for accrediting approximately 3,000 postsecondary, degree-granting colleges and universities in the United States, as well as internationally. Accrediting commissions are private, nonprofit organizations. To learn more, visit www.c-rac.org.