I wholeheartedly agree with Scott Yenor’s timely observation that “accreditors are political actors” (The Politics of Higher-Education Accreditation: Accreditors are Political Actors), but I want to clarify some of his comments about accreditation, and, hopefully, add to our understanding of accreditation as a system of volunteers carrying out their assigned tasks in the context of federal statutes and regulations, and overseen by a small group of agency staffers.
The most important point to be made is that accrediting bodies are not disinterested third-party actors. They are, in fact, statutory membership associations that are made up of post-secondary schools, colleges and universities for the purpose of accessing federal funds, like financial aid for students and federal student loan guarantees. Member schools that lose their place on the accreditor’s membership roster, lose access to these resources, and eventually close their doors.
Member colleges and universities also pay membership fees, fund the cost of visiting review teams, and the cost of attending membership conferences and trainings. Members are also responsible for the process that produces the center-piece “self-study” of the accreditation review, put together over a period of years by many volunteers from the school. Institutional reviews of compliance with federal and accrediting standards are conducted by thousands of member volunteers (so-called “peer reviewers”), and a small professional staff from the agency itself. By far, the largest “cost” is born by the volunteer reviewers that contribute their time and expertise to “impartially” review the self-study and sample faculty rosters from each institution applying for reaffirmation.
The fact that membership associations are teeming with hundreds and hundreds of volunteers, but overseen by a thin-layer of supervisors, and the few managers of the agency itself, adds nuance to the picture of accrediting bodies as “political actors”. Membership input to changes described by Yenor need to be understood as largely driven by administrative personnel from membership colleges and universities, which ever so slowly filter “change” upward to agency leadership. It is therefore inaccurate to say that “WSCUC foists DEI policies on colleges.”
Any analysis of organizational change, one that accounts for the diffusion of new standards of conduct and localized myths — whatever they may be — recognizes that professional strata are more apt to channel so-called ideologically driven views and behaviors across organizations; colleges and universities are no different in this regard, for example, than organizations working to close the wage gap between men and women.
But in the case of DEI support by middle- and upper-level administrators in higher education, there is another mythology in operation; namely, that the schools themselves are absolutely indispensable for providing social mobility to students and distributing economic opportunity through the production of degrees. Among higher education elites, however, these beliefs are sacred and undisputed; in fact, it is taboo to question them. But it is from within this group, armed with this sacred mission, that DEI initiatives — however ineffective they may be — originated and blossomed into enormous bureaucracies buffered from ordinary demands and pressures.
This overview of organizational life, then, provides more reasons to question the claim that “WSCUC foists DEI policies on colleges” — because this analysis seeks to locate DEI’s origins in higher education’s professional strata, and the nature of the widely accepted myths used to legitimate their work about the economic value of a college degree, and their role in making that happen. (And, it goes without saying, lower status workers are prone to internalize the values and views of those over them.)
Yenor seems confused about the respective roles of NACIQI, the Secretary of Education and the senior department official, the “Accreditation Group” within the department, and the relevant HEA statutes that are implemented in 34 CFR 600, 34 CFR 668 and especially 34 CFR 602.
But as a newly appointed board member at UWF, which is in the midst of its decennial review process, he will have ample opportunity to acquaint himself with the existing structure before proposing changes. In these endeavors, I sincerely wish him the best.
Glen McGhee, Dir.
Florida Higher Education Accountability Project (FHEAP)