No one understands accreditation better than Daniel O. Aleshire, executive director of the Association of Theological Schools (ATS). Hired 22 years ago to guide ATS accreditation, he continues to oversee, review, and evaluate the ever-demanding criteria by which member campuses are assessed. This is no easy task. The most recent revisions — four years in the works — attempt to keep pace with schools’ aggressive efforts to deliver diverse programs in creative ways.
In an age marked by internal and external change, the challenge is to measure the effectiveness of practices so new that their outcomes are yet unknown. In Trust recently sat down with Aleshire for an update on the 2012 standards and the forces that helped shape them. Our first question set the stage for our conversation:
What’s your best definition of “accreditation?” In short, what does it mean for schools today?
Daniel O. Aleshire: For the most part, accreditation is a mystery — a valued mystery. That is, people think that schools should be accredited. Students want to be graduates of accredited institutions. But if you were to ask most graduates or current students, ‘What does accreditation mean?’ they likely would have a hard time providing a viable answer.
My definition of accreditation is this: A school has been judged by a committee of peers and the Board of Commissioners, on the basis of carefully devised standards, to have the resources to deliver quality educational degree programs and can demonstrate that its programs are achieving their educational purposes.
The accreditation process is a work in progress, right? How has it evolved since 1936, the year ATS voted to become an accrediting organization?
When ATS recognized its first accredited members two years after the ’36 vote, accreditation depended on an affirmative answer to one question: Did the schools have the basic resources necessary to provide theological education? Those resources included libraries with the proper kind of books, faculties with the proper kind of education, students with the proper kind of background, and facilities that were appropriate to support the schools’ efforts. ATS wasn’t alone in these requirements; other accrediting agencies also were resource-focused.
After World War II, everything changed. Community colleges and regional state institutions brought diversification to higher education, which had once been characterized by a single kind of activity.
Accreditation had to change too. It was not enough simply to base a judgment on adequate resources. A second question emerged: Are the schools’ resources appropriate for their missions? One size didn’t fit all. A community college might not require the same kind of library or faculty as a university granting Ph.D. degrees. Accreditation was still resource-focused, but different schools with different missions needed different sets of resources. This change required that the accreditation process take into account how well the resources of a school supported its mission and purpose.
Since the late 1980s, a third and bigger question has emerged: Are the schools accomplishing their educational goals? That’s an “outcomes” way of looking at an institution. Resources are an “inputs” way of looking at the institution.
Of course it’s important to remember that the second and third questions don’t replace the first. The questions are additive. As part of the ATS accreditation process we still ask about resources, but we modify resources by looking at the mission issue. We further modify the resource expectation by looking at educational outcomes. So if a school has a wonderful library but no evidence that any of its students have learned anything, that amounts to a major accrediting problem. If a school has clear evidence that its students are attaining the educational goals of the program, but it doesn’t have a good library, that’s less of an accrediting problem. Somehow that school has been able to accomplish its educational goals without one of the resources presumed to be crucial to the goal.
Do schools view the third question—the one that asks if they are accomplishing their educational goals— as threatening? I’m recalling this year’s teachers’ strike in Chicago over how much standardized test scores would affect teacher promotion or salary increases.
If teachers or institutions are responsible for learning, then their evaluations become dependent on what their students do. That’s a more threatening perspective for an educator, but in the end, it’s the purpose of education. Communities of faith need talented, well-educated leaders to accomplish the complex tasks of ministry. They depend on schools to hold students to high standards. They need to know that a school’s graduates have attained certain standards as they earned their degrees. ATS tries to support that expectation in its accreditation efforts.
The other thing I would say is that accreditation standards are always retrospective. That is, the institutions develop good practices, and these good practices become part of the accrediting standards. It’s very hard to develop accrediting standards for practices that don’t yet exist. In many ways that’s one of the conundrums in theological education right now. So much is moving so quickly. The present standards reflect the good practices of the past, but it is almost impossible to write standards that evaluate the best way of doing something that schools have never done before.
Sure. We don’t really know if an M.Div. program can be completed effectively as an exclusively online and context-based program. And we don’t necessarily know the best form that such a program should take. But the new standards allow schools to petition to experiment. If a school has reasonable plans and effective strategies for evaluation, then the standards allow the Board of Commissioners to give that school a period of time to try a new educational design and assess its educational effectiveness.
This will allow the community of schools that make up the ATS Commission on Accrediting to develop understandings of practices that maximize educational effectiveness— and to revise the standards accordingly. If you closely read the standards that were adopted at the June 2012 meeting, you’ll discover that at several significant points these kinds of openings were introduced.
What are the primary drivers that influence the changes we see in accreditation standards and procedures?
Three come to mind:
The increasing complexity of higher education.
The growing expectations of the church.
The U.S. government and its federal student loan program.
We've already talked some about the first, but let me summarize. Thirty years ago most schools had one, two, or three degree programs that they offered on one campus where the majority of their students were enrolled. Today, an accreditation team must visit all the places the school does its educational work and review all its programs, including those available online. So there’s more that has to run through the accrediting filter. The overall effect is a substantial shift in the kind of work that underlies the conclusion that “this school has the appropriate resources for its mission, and it is accomplishing that mission educationally and institutionally at an appropriate level.” (As you’ll recall, that’s how I defined accreditation at the beginning of this interview.)
And the growing expectations of the church?
Accreditation stands at a distance from the church, but in general, the church is reassessing what it wants of its leaders and what kind of background it wants them to have. This leads to some fundamental questions about the education that schools provide.
We’re seeing change on both ends of the spectrum. Denominations that historically took an anti-intellectual stance now have ATS-accredited schools. At the same time, established mainline denominations—who invented much of Protestant theological education as we know it and who have always been stalwart believers in an educated clergy— now have created alternative credentialing structures. With fewer full-time ministry positions, they are asking about the kinds of ministers it takes to provide pastoral leadership in part-time settings—and about what kind of education such leaders need.
All these changes have a dramatic impact on theological schools and a more subtle but perceptible impact on accreditation.
And how is the government bringing about changes in the accreditation process?
For years the U.S. Department of Education has emphasized education’s role in preparing a knowledge-based and service-focused workforce ready to compete in a global economy. But since the federal government doesn’t own or control any higher education institutions, other than the military academies and two Native American colleges, its influence is limited to funds that flow from Washington to the schools. These funds take the forms of research grants and guaranteed student loans. Before authorizing money to schools, Congress has to have a way of determining which institutions qualify for support.
The government decided shortly after World War II, when the GI Bill became law, that the accreditation processes already in place could serve as a good indicators of institutional quality. So it began to “recognize” accrediting agencies that it deemed to be reliable judges of institutional quality. Since the early 1990s we’ve seen an obvious change in the government’s understanding of accreditation, and the Department of Education now expects compliance with a much broader range of regulatory requirements. It evaluates each accrediting agency every five years to determine if the agency is doing accreditation the way the government wants it done.
The Department has a full-time staff that evaluates agencies according to the criteria in the Higher Education Act and has developed very specific guidelines about how agencies can demonstrate that they are meeting departmental requirements. As the need for an educated citizenry has increased and the amount of federal dollars earmarked for higher education has spiked, the government takes a more careful look at what accrediting agencies are doing.
It’s fair to say that the current criteria and guidelines suggest that the government has concluded that it knows more about how to accredit institutions than do the accrediting agencies.
Then why doesn’t the government accredit institutions directly?
It would be a challenge for the government to regulate all institutions directly—the 2012 Higher Education Directory lists almost 5,000 institutions. The schools themselves prefer that the accrediting agency, over which they have some control, does the work. Right now the government is getting a huge amount of free labor because every accrediting agency works with teams of persons who contribute their services. So the government is getting all its regulations enforced, and it’s not paying for any of that enforcement. The accrediting agency acts as an intermediary between the government and the schools.
Here’s an interesting point to remember: Federal law is written in a way that the same statutes apply to all postsecondary education, from a six-month program at a barbering school to a Ph.D. program at a seminary. In trying to address certain excesses in one segment of post-secondary education, the government rewrites criteria that affect all segments. When an ATS-accredited school is receiving its accreditation visit, it may feel as if some of the accrediting questions don’t apply to them. They are right, but the questions have to be asked.
Can you offer an example?
Each school is supposed to publish on its website, or in some publicly available medium, a statement of its educational effectiveness. That can include the percentage of students who complete a degree, the percentage of students who complete degrees that have degree-appropriate employment positions after graduation, or the percentage of students who attain the educational goals of the degree programs.
We’re in the middle of this right now. Schools vary in the amount of tracking they’ve done in the past. Roman Catholic schools know where every priesthood candidate is going to be upon graduation, but evangelical Protestant schools that relate to a range of denominations typically haven’t looked at the placement of their graduates.
A lot of people come to seminary because they’re trying to discern how they’re supposed to live out their faith. Some don’t complete programs because they discover that professional ministry is not their call; others may finish their degrees but go into different lines of work. In both cases, the summative statistics that the Department of Education likes to use make these situations appear as educational failures, when that may not be the case at all.
The authentic discernment process that’s involved for many seminary students may lead them away from vocational ministry and it may lead others to vocational ministry. That’s very different from students enrolling at a barber school. They’re not exploring. They’re thinking of one thing—they want to become hair stylists, and the ultimate indicator of whether they’ve succeeded in getting the necessary skills is whether somebody hired them to do that job.
That seems murky. There will always be jobs that are halfway in and halfway out of any particular field.
Right. But regulations don’t allow for “murky.” They determine whether you are in or out of the fold. The government is not a mean ogre on this; it’s trying to look out for the good of the citizen student (who is borrowing money that must be paid back) and the citizen taxpayer (who provides funds for the loan). The problem is that it’s one blunt instrument across the diverse, complex, and nuanced world of postsecondary education.
The higher you go in education, the harder it is to find the clear, bright-line indicator of success. For example, we know whether Johnny can read at the third-grade level of reading, but it is much harder to know if John can interpret Scripture at the master of divinity level of scripture interpretation. It can be discerned, but it’s a more subtle and complex assessment. The government would like for higher education to come up with the same kinds of bright-line indicators for higher education that have already been established for achievement at the K–12 level.
And that would require the government to set standards for curriculum?
That’s the problem. Government could never set the standards for curriculum in theological education. As it is, some people even question whether the government should be giving loans to students preparing for ministry. They see that as violating the separation between church and state—and many ATS schools do not participate in the federal loan program for precisely that reason.
The law makes the student loan program an entitlement for U.S. citizens. It doesn’t differentiate between the student who wants to be a scientist and the student who wants to be a pastor. If the government went into the direct regulation business, I think theological schools would probably be eliminated from the list at the outset. As it is, the current structure allows the money to flow to individual citizens through schools accredited by a government-recognized accreditor regardless of the student’s vocational aspirations.
What about efforts to reduce students’ dependency on the federal loan program? Are they succeeding?
There was a time when theological schools were very light users of the federal loan system. That has definitely changed. If all of government loans were withdrawn from theological education, a lot of ATS schools would be pressed on enrollment and pressed on student aid. Many (if not most) ATS schools want to be in the program, but they chafe at the bureaucratic intervention the program imposes on them. I understand both sides. Unfortunately, many students are graduating from seminary with so much debt that they’ve got to find jobs that pay more than most entry-level ministry jobs pay.
From your vantage point, what do you see as the next wave of changes to the accreditation process?
In recent political campaigns, we have heard a lot of discussion about the government helping to control rising tuition costs. But how can that happen, given that the government doesn’t run any schools? I expect the next round of changes to include some way in which accrediting teams will assess whether schools are charging too much tuition for their degree programs. The government could create some kind of regulatory ceiling, and if a school goes above that ceiling it might risk losing access to the federal money that comes into higher education.
Up to this point we’ve limited our conversation to U.S. schools. Are Canadian institutions affected by any of this?
Yes. Some Canadian schools participate in the U.S. federal loan program. They tend to be close to the border and have student constituencies that include U.S. citizens. The student loan program is a citizen benefit program, so if a Canadian school wants to jump through all the hoops necessary to become a participating school, it can administer student loans to U.S. citizens.
The Canadian schools that aren’t in the program sometimes ask, “Why do we have to abide by accrediting standards that are influenced by the U.S. Department of Education?” It is an altogether fair question, and ATS does everything that it can do to segregate these schools from purely U.S. federal requirements. Not all federal requirements are problematic, though—even for Canadian schools. For example, Department of Education regulations require schools to publish their policy on refunding tuition when a student withdraws and the basis by which schools determine if transfer credits will be accepted. These are just good institutional practices, whether for U.S. or Canadian schools.
Accreditation is a great resource in higher education, in my judgment. It provides a means for those who know a particular kind of education best to assess its quality and counsel peer institutions toward improvement. Accreditation has sometimes been blamed for problems it did not create; at other times it has been given credit that it does not deserve. It’s not the only way to judge institutions, but it is a very good and prudential way.
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