National Recognition of Accrediting Agencies by the U.S. Secretary of Education
The U.S. Secretary of Education (Secretary) is required by statute to publish a list of nationally recognized accrediting agencies that the Secretary determines to be reliable authorities as to the quality of education or training provided by the institutions of higher education and the higher education programs they accredit. The Secretary only evaluates accrediting agencies that apply for recognition, and certain criteria for recognition that are unrelated to the quality of accrediting activities limit the scope of the Secretary’s recognition activities.
Most institutions attain eligibility for federal funds by holding accredited or preaccredited status with one of the accrediting agencies recognized by the Secretary, in addition to fulfilling other eligibility requirements. For example, accreditation by a nationally recognized institutional accrediting agency enables the institutions the agency accredits to establish eligibility to participate in the federal student financial assistance programs administered by the U.S. Department of Education (Department) under Title IV of the Higher Education Act of 1965, as amended.
The commissions of the institutional (both regional and national) accrediting agencies that are recognized by the Secretary have no legal control over educational institutions or programs. They promulgate standards of quality or criteria of institutional excellence and approve or renew membership of those institutions that apply for meet their accreditation standards or criteria.
Note: The U.S. Department of Education does not have the authority to accredit private or public elementary or secondary schools, and the Department does not recognize accrediting bodies for the accreditation of private or public elementary and secondary schools. However, the U.S. Department of Education does recognize accrediting bodies for the accreditation of institutions of higher (postsecondary) education. If an accrediting body which is recognized by the Department for higher education also accredits elementary and secondary schools, the Department's recognition applies only to the agency's accreditation of postsecondary institutions.
The Department’s recognition of accrediting agencies does not extend to the accreditation an agency may grant to foreign institutions or programs.
The Accrediting Agency Evaluation Unit
The Accrediting Agency Evaluation Unit has been established within the Department of Education to deal with accreditation matters. Located in the Office of Postsecondary Education, the Unit carries out the following major functions with respect to accreditation:
- Conduct a continuous review of standards, policies, procedures, and issues in the area of the Department of Education's interests and responsibilities relative to accreditation;
- Administer the process whereby accrediting agencies and State approval agencies secure initial and renewed recognition by the Secretary of Education;
- Serving as the Department's liaison with accrediting agencies and State approval agencies;
- Providing consultative services to institutions, associations, state agencies, other federal agencies, and Congress regarding accreditation;
- Interpreting and disseminating policy relative to accreditation issues in the case of all appropriate programs administered by the Department of Education;
- Conducting and stimulating appropriate research; and
- Providing support for the Secretary's National Advisory Committee on Institutional Quality and Integrity.
The Recognition Process for Accrediting Agencies
The process for the recognition of accrediting agencies is set forth in 34 CFR Part 602 Subpart C. Other information related to an agency's application for recognition is provided below.
The Application for Recognition
Accrediting agencies desiring recognition by the Secretary of Education must apply and demonstrate their compliance with the Criteria for Secretarial Recognition (34 CFR Part 602 Subpart B). An agency's application for recognition generally consists of a statement of the agency's requested scope of recognition, evidence of the agency's compliance with the criteria for recognition set forth in part 602, and supporting documentation.
Agencies seeking initial recognition should contact the Accrediting Agency Evaluation Unit to discuss the basic eligibility requirements and the application process. If the staff believes the agency meets the basic eligibility requirements, the agency will be provided with the information needed to submit an application through the unit's electronic system.
U.S. Department of Education
1990 K Street, NW, #8065
Washington, DC 20006-8509
Telephone: (202) 219-7011
An agency's application for initial recognition or renewal of recognition consists of a narrative statement, organized on a criterion-by-criterion basis, showing how the agency complies with the Criteria for Recognition. For many recognition requirements, the narrative statement need only consist of a brief narrative demonstrating how that agency complies with a particular requirement. This statement must, however, be accompanied by clearly referenced supporting documentation demonstrating that the agency meets the requirement. For example, §602.15(a)(6) of the regulations requires an agency to have clear and effective controls against conflicts of interest or the appearance of conflicts of interest by the agency's board mem¬bers, commissioners, evaluation team members, consultants, administrative staff, and other agency representatives. The agency's narrative statement addressing this issue might simply be a statement that the agency's policies against conflicts of interest may be found in a particular policy document. The agency would have to submit a copy of that document and identify the pages on which the relevant policies were located. The agency might also choose to include a copy of the minutes of a meeting at which an agency representative abstained from voting because of a conflict of interest to demonstrate that it adheres to its written policies.
For other recognition requirements, because of their nature, the brief narrative statement, with supporting documentation, is insufficient to demonstrate compliance. In these cases, the agency's narrative statement should provide sufficient information to demonstrate that the agency's policies, standards, procedures, and practices comply with all aspects of the requirement. For example, §602.21 of the regulations requires that an agency maintain a systematic program of review that demonstrates its standards are adequate to evaluate the quality of the education or training provided and relevant to the education or training needs of students. As this requirement is fundamental to sound accreditation practices, the agency's narrative statement would have to describe in depth the processes the agency uses to review and update its criteria and standards, the tests it uses to determine their adequacy and relevance in evaluating educational quality, as well as the results of those tests, and how it determines they are relevant to the needs of affected students. The agency would also have to provide relevant supporting documentation, such as policy statements pertaining to its review program for validating and updating its standards, surveys and the results of those surveys, the constituencies involved in the review process, etc. The agency’s statement and documentation would need to establish that the program of review is comprehensive; occurs at regular, yet reasonable, intervals or on an ongoing basis; examines each of the agency’s standards and the standards as a whole; and involves all of the agency’s relevant constituencies in the review, affording them a meaningful opportunity to provide input. The agency would also need to establish that it has the requisite procedures in place for timely changing its standards in response to the results of the review.
If an agency's application for recognition does not make specific reference to the following documents and does not include them as supporting documentation for one or more of the recognition requirements, the agency must include them as additional supporting documentation:
Accreditation standards and procedures
Policies and procedures
Most recent externally audited financial statement
Published lists of accredited schools or programs
Guidance and training materials for visiting team members
Sample completed self-study reports
Sample site visit reports
Sample institution responses to site visit reports
Sample minutes of decision meetings
A list of all complaints received by the agency against an accredited program during the six-month period immediately preceding the agency's submission of its application for recognition, together with a summary of the issues involved in each complaint, the agency's disposition of that complaint, and the current status of the complaint, if it is not resolved by the time the agency submits its application
The agency's constitution and by-laws.
Note: it would be helpful if the samples provided by an agency referred to the same institution(s) or program(s), where applicable.
Time Frame for Submission of an Application
Application for Initial Recognition
The Accrediting Agency Evaluation Unit accepts applications for initial recognition at any time. To request consideration at a particular meeting of the NACIQI, an agency seeking initial recognition must submit its application at least six months in advance of that meeting. Consideration of the agency's application at the first NACIQI meeting that occurs after the six-month time frame is not guaranteed, however, as Department staff may need more time to complete its independent evaluation of the agency and to observe at least some of the agency's site visits and decision meetings, as required by §602.32(b)(1) of the regulations.
An agency considering applying for initial recognition is encouraged to contact the Accrediting Agency Evaluation Unit as early as possible to discuss its possible application and to afford staff the opportunity to observe its site visits and decision meetings. Because observation of an agency's site visits and decision meetings by staff is a critical component of the review of the agency's application, it is imperative that an agency seeking initial recognition submit a list of scheduled site visits and decision meetings with its application for recognition. If an agency does not provide staff with an opportunity to observe an adequate number of site visits and decision meetings (typically 2-3 of each) before NACIQI meeting at which the agency requests consideration of its application, staff may recommend that the agency's application be denied.
Agencies seeking initial recognition are reminded that recognition by the Secretary is not a prerequisite for an agency to function as an accrediting body, i.e., an agency does not have to obtain recognition before it begins to accredit institutions or programs. Rather, recognition is granted by the Secretary to an agency that meets certain federal eligibility requirements and can demonstrate compliance with all of the criteria for recognition, establishing through its accrediting actions and decisions that it is a reliable authority regarding the quality of education offered by the institutions or programs it accredits. A new agency must demonstrate that its accreditation is a required element in enabling at least one of the institutions or programs it accredits to establish eligibility to participate in one or more federal programs. Beyond that basic eligibility requirement, a new accrediting agency will need to have had at least two years' experience functioning as accrediting agency - establishing standards, evaluating institutions or programs for compliance with those standards, and making accrediting decisions based on those standards - before it submits its application for recognition. In addition, a new agency will need to be mindful of the recognition criterion requiring it to establish that it has gained wide acceptance of its standards, methods of evaluation, and accreditation decisions, as required by §602.13 of the regulations. Staff will also consider whether the new agency has been organized under conditions that reasonably ensure its stability and permanence.
Application for Continued Recognition
Agencies that have been granted recognition by the Secretary are officially notified of the expiration date of their recognition period in a letter each time recognition is granted or renewed. They should plan to submit their application for renewal of recognition approximately six months in advance of the spring or fall meeting of the NACIQI that precedes that expiration date. The Accrediting Agency Evaluation Unit usually notifies agencies a year in advance of the NACIQI meeting at which their renewal application is to be considered and informs them of the date by which their application is due. The notice also requests a schedule of each agency's site visits and decision meetings for the upcoming year in order to plan staff observation of at least some of those activities, as required by §602.32(b)(1) of the regulations.
Staff Analysis of an Accrediting Agency's Application
The application review process conducted by the Department includes analysis of the application and observation of some of the agency's site visit and decision-making activities by Accrediting Agency Evaluation Unit staff. Staff members may also visit agency administrative offices to conduct interviews of agency staff and to review the agency's facilities, records and administrative operations. They may also conduct interviews or surveys of other persons, organizations, or institutions concerning the applicant agency's approval process in order to obtain further information relating to the agency's compliance with the Criteria and Procedures for Recognition. Department staff then prepares a written analysis of the agency's application for recognition, which includes a recommendation on recognition.
Hearing Before the Advisory Committee
When staff completes its evaluation of an agency's application for recognition, the agency's application is placed on the meeting agenda of the National Advisory Committee on Institutional Quality and Integrity; (NACIQI).In preparation for the meeting, the committee is provided with the accrediting agency's application and supporting documentation; the final staff analysis of the application; the staff's recommendation on recognition; all information relied upon by staff in developing the analysis; at the agency's request, any response by the agency to the draft staff analysis; and any written third-party comments the Department received about the agency and agency response.
The NACIQI meets at least twice a year to review applications for recognition submitted by accrediting agencies. The usual times for the Committee meetings are spring (May-June) and fall (November-December). Although each member of the Committee receives every staff analysis of an application for recognition and all the other materials mentioned in the preceding paragraph, the Executive Director of the NACIQI usually assigns two or more individuals to serve as principal readers for each application.
An agency that applies for recognition is invited to make an oral presentation before the Committee. The Committee also hears oral presentations from third parties who request to be heard. Department staff are available throughout NACIQI meetings to respond to questions.
The NACIQI conducts its business in public, and a transcript of the proceedings is made. After each meeting, the Committee's and Department staff's recommendations concerning recognition are forwarded to the Senior Department Official, who makes the final determination regarding recognition. Any agency that disagrees with the decision of the Senior Department Official may appeal to the Secretary. Agencies may be granted initial recognition or renewal of recognition for a period of up to five years.
Expansion of Scope
An application for expansion of an agency's scope of recognition may be included as an integral part of an application for renewal of recognition or it may be submitted separately. If an expansion of scope is sought prior to the agency's next regularly scheduled review, agency personnel should consult with the Accrediting Agency Evaluation Unit staff concerning the application format.