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Competency-Based Education and Accreditation: A Personal Perspective (Part 2)

The EvoLLLution | Competency-Based Education and Accreditation: A Personal Perspective (Part 2)
Accreditors are not the only actors that need to change in the face of competency-based education’s growth. Other stakeholders have central roles to play in facilitating the wider adoption of CBE as well.

This is the final installment of a two part series by Barbara Wright discussing how accreditation is transforming to adapt to the rise of competency-based education. In the first installment, Wright set the scene for some of the changes being made to accreditation in the CBE era. In this article, Wright shares some specific changes that higher education’s five central stakeholders need to make to help facilitate CBE’s further growth.

So What’s the Problem?

Given the complexity of CBE and the substantial contributions of regional accreditors, I’ve been frankly baffled by the vitriol directed at accreditation as an obstacle to innovation in general and to CBE in particular. Outgoing Secretary of Education Arne Duncan recently claimed that accreditors were “the watchdogs that don’t bite,” (Kelderman). The Wall Street Journal has accused accreditation of being a “cartel” that must be “busted” and sees no contradiction in calling for accreditation to be both more rigorous and more flexible (see also Eaton). Presidential candidate Marco Rubio and Utah Senator Michael Bennett have introduced a bill to create an alternative certification process for non-traditional education (Wall Street Journal). Even the president of AAC&U has been critical, faulting accreditors for being “timid” in pressing for common learning outcomes and educational quality (Schneider).

But to see accreditation only as an obstacle to innovation that must be reinvented or even replaced is too simplistic and lets too many other actors of the hook. Accreditation may need to change, but so do a lot of other stakeholders.


Those 600 institutions looking to develop CBE programs face a series of challenges. Because CBE starts with the question of what graduates can actually do with their learning, institutions will need to rethink their curricula, learning resources, the coherence of degrees and assessment approaches. Additionally, since CBE is both more granular and more holistic than traditional educational models, they will need to shift the focus of assessment from courses, where most faculty attention has been directed, and set specific standards of performance. This means that in addition to aiming for improvement, they will need to focus more strongly on accountability: to students, the students’ future employers, fellow educators and the public.

Greater transparency will be required, too. Most institutions with regional accreditation now publish their learning outcomes for general education and majors. What’s missing are performance standards:  i.e., not just what students are expected to know and be able to do, but how well. Institutions will need to become more transparent about how they arrive at their learning outcomes, how they set standards, and the kinds of assessments they use. Pulling back the veil will hopefully be educative, not only for students, who will have a clearer idea of what’s expected of them, but also for families, employers, the public, and perhaps even policy makers and the media.


Accreditors need to clarify and streamline the substantive change process without sacrificing its rigor. To do so, they will need clarity and consistency from USED. They need to press institutions to develop their assessment practice, to shift their focus from process and improvement to specific standards of performance, and to report on students’ achievement in relation to those standards. Accreditors can also require that performance standards be transparent and readily available to any student, parent, employer, or policy maker seeking the information.

Regional accreditation’s own standards have been criticized for being vague and ambiguous. But would more prescriptive standards be more rigorous and trustworthy? The strength of these standards is their very flexibility: they can accommodate wide differences in educational philosophy, mission, educational offerings (including CBE), and student or regional needs. That means students will have a choice among institutions, and in economic circles choice is normally regarded as a good thing. Choice does not mean, however, that anything goes. Institutions must be able to explain and document convincingly the ways in which they meet their accreditors’ standards.

It’s important to remember that accreditation is not one thing. There are regional accreditors, generally viewed as the most prestigious, as well as professional or program-based accreditors, and national accreditors of particular types of schools. The variability in rigor and reliability is significant, within and among accreditation sectors—hardly the “cartel” that the Wall Street Journal rails against.

The United States Department of Education

The USED needs to become clearer and more consistent about its expectations for CBE programs. The Office of the Inspector General (OIG) has been auditing regional accreditors’ substantive change processes.Accreditors have been perplexed especially by the OIG’s scrutiny of expectations for faculty-initiated interaction with students (as opposed to student-initiated interaction, which is not considered sufficient) and by questions about how CBE differs from correspondence courses—a counter-intuitive notion for most people.

At the same time, and to its credit, USED has tried to support institutions and their CBE programs with a series of “Dear Colleague” letters and, most recently, with its Competency-Based Education Experiment Guide (2015). It insists that it wants to “take an expansive view” of CBE programs and “minimize existing limitations.” Accreditors can only hope that they won’t be caught in the middle. One unwelcome effect of the required substantive change review is to move accreditors another step away from their traditional role as a force for educational quality and improvement and closer to the role of compliance officer for the USED.


A common language would support clear communication among the many stakeholders involved, from USED, policy makers, and accreditors to institutions, students, employers, and the public.  Terms need to be defined in ways that acknowledge the priorities of different audiences and the very different connotations they attach to what may appear to be the same terms.

“Assessment” is one example. In the higher ed community, it’s shorthand for assessment of student learning, but it has become trendy among many stakeholders to use it as a synonym for evaluation. Similarly, in academic circles “outcomes” are usually shorthand for learning outcomes; for external audiences, in contrast, the reference is usually to retention, degree completion, job placement, salary, and the like. Those outcomes may serve as surrogates for learning, but they become problematic when they crowd out consideration of actual learning in the language of policy makers, politicians, employers, and the public. There’s contention, too, about the differences between “proficiency,” “mastery,” and especially “competency,” which some educators assume—erroneously—can only mean a low-level skill.

USED’s introduction of the term “direct assessment” without a real definition is another example of confusing language. The assessment community has for decades distinguished between “direct assessment” and “indirect assessment.” Direct assessment means looking directly at evidence of what students know and can do, e.g., in the form of projects or papers. Indirect assessment means using evidence of learning that is mediated through perceptions or opinions, for example, in the form of surveys or interviews.

When USED began talking about CBE programs based on “direct assessment,” however, the term was defined as “not based on credit or clock hours.” But credit and clock hours are indicators of seat time. They are only surrogates for learning and do not constitute even indirect evidence. More recently, the USED’s Competency-Based Education Experiment Guide (2015) has elaborated on what the department means and lists “projects, papers, examinations, presentations, performances, and portfolios” as examples. So there’s an oblique nod to the traditional definition, but still without any direct reference to it, a gap that has been disorienting for long-time assessment practitioners.

The President, Congress, Policy Makers, and the Public

External actors need to recognize the complexity of high-quality education and avoid unintended consequences like a narrow reductionism. Knowledge and skills for the workplace matter, but education can’t just be about near-term employability. It should prepare students for meaningful personal lives and for their responsibilities as citizens, now more than ever.

External audiences also need to be realistic. In part, enthusiasm about CBE stems from the hope that it will be faster, better and cheaper. Theoretically, in a CBE program students can progress rapidly through parts of the curriculum where they have prior knowledge, less time will mean lower cost, and assessments will guarantee mastery—in contrast to traditional course grades, which can mask serious learning deficits. However, students, policy makers and others need to recognize that while CBE may save time, it may also take longer, e.g., when a student has difficulty mastering a demanding competency like writing or critical thinking.


Ultimately, accreditation is human judgment, as are legislating, policy making, data analysis and reportage. They’re all dependent on the perspectives, knowledge and values of the actors making those judgment calls. Progress can only be as swift as the evolution of perspectives and the acceptance of new knowledge.

That is true for accreditation, which is dependent on the interpretations and judgments of many people beyond the agency—i.e., peer reviewers and commission members—as well as faculty, staff and institutional leadership. It’s true for educators who may struggle, for example, with the shift from teaching- to learning-centeredness.  And it’s true for politicians, policy makers, members of the business community and the public, many of whom rely on a personal experience of what higher education “is” that may be decades out of date.

In the fact-free zone that so much of our public discourse has entered, the reality of what accreditation is and what it has contributed to CBE has gotten lost. Accreditation may need to change, but so do other actors. There’s no simple answer, but one thing we can be sure of is that all stakeholders need to learn, grow and be willing to listen.

Acknowledgement: I would like to thank colleagues from several regional accrediting agencies for helpful conversations about the intersection of CBE and regional accreditation. Any errors and opinions expressed here are entirely my own.

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Berrett, D. (2015). How a 40-Year-Old Idea Became Higher Education’s Next Big Thing. The Chronicle of Higher Education. Retrieved from

Council of Regional Accrediting Commissions (2015). “Regional Accreditors Announce Common Framework for Defining and Approving Competency-Based Education Programs. Retrieved from

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Kelchen, R. (2015). The Landscape of Competency-Based Education. Retrieved at

Kelderman, E. (2015). “U.S. to Put New Requirements on Accreditors.” The Chronicle of Higher Education. Retrieved from http:// /article/US-to-Put-New-Requirements/234082

LeClair, J., and Berenson, R. (2015) “Designing a Competency Based Education (CBE) Program: Context, Challenges, and Pivots.” Retrieved at

Schneider, C. (2015) “Policy Priorities for Accreditation Put Quality College Learning at Risk.” Retrieved from

USED. (2015) Competency-Based Education Experiment Guide. Retrieved from

USED. (2014) Experiments Announced in the July 31, 2014 Federal Register: Competency-Based Education. Retrieved from

USED. (2013) Applying for Title IV Eligibility for Direct Assessment (Competency-Based) Programs. Retrieved from

Wall Street Journal. (2015) “Trust Busting Higher Ed.” Retrieved from /trust-busting-higher-education-1443997741

WASC  Handbook of Accreditation (2013). Retrieved from

Wright, B. (2002) “Accreditation and the Scholarship of Assessment.” In: The Scholarship of Assessment and Accreditation. Trudy Banta, ed. Jossey-Bass, P.240-258.

Wright, B. (2012). “The Challenge for Institutions – A Thought Experiment.” Talk delivered at AAC&U General Education and Assessment Conference, New Orleans, February 24, 2012.