A Conversation with the Middle States Commission on Higher Education
Many in higher education believe it is difficult–if not impossible–to undertake large-scale innovations due to accreditation requirements. Our postsecondary system is degree-centric, organized around associate, baccalaureate, master’s, and doctoral degrees. The entry of nondegree credentials into these waters is not sitting so well; many are pointing to the challenges around quality assurance, and some are viewing nondegree credentials as an intrusive new species that threatens to push out traditional degrees. Within this complex, rapidly changing system of educational waterways, there are many checks and balances–key among them, institutional accreditation requirements for approved colleges and universities.
The Credential As You Go (CAYG) initiative is proposing a major transformation of postsecondary education to an incremental credentialing system. What would this transformation mean for quality assurance, especially for accreditation? Is an incremental credential system compatible with accreditation? We recently interviewed Dr. Christy Faison, Senior Vice President for Accreditation Relations at the Middle States Commission on Higher Education (MSCHE), to explore these issues in a three-part conversation. Part 2 focuses on readiness for incremental credentialing and greying the lines between degree and nondegree credentials; and policy implications from Pell considerations and other issues.
Holly Zanville (HZ): When an institution says, ‘We’re starting to integrate hybrid non-credit, badges or other short-term credentials into our regular program,’ how does MSCHE guide them? Are your institutions asking these questions?
Christy Faison (CF): We are just starting to have those conversations with institutions and systems. In all honesty, the majority of the focus has been around credit-bearing programs.
HZ: Those are the degree programs, right?
CF: Yes, and other programs that end in a recognized credential. Our attention has been on credit-bearing programs and of course oversight of anything Title IV-eligible because we have to respond to the U.S. Department of Education. Technically anything offered in the name of the institution─credit-bearing or not ─is part of an accreditation review and evaluation conducted by one of our peer evaluation teams. So, they would still be asking questions about outcomes for non-credit bearing programs.
HZ: How could changes in federal policy focused on Pell grants, with more assistance potentially for short-term credentials, impact regional accreditors and greying of the lines between traditional degrees and other credentials?
CF: Post pandemic, everybody’s going to need to think about the new normal. What is business as usual? What areas of our accreditation processes can we make clearer, so institutions understand that they have permission to proceed? And again, for accreditors, what areas are we vague about? We will need to go back and clarify our language, policies and procedures as regulations change. We are seeing several areas of change around innovative partnerships, contractual arrangements, mergers, consortia, consolidation and of course incremental credentialing. These changes are making us step back and think about what they mean for the institution and what we need to be aware of within our policy and procedures framework to help institutions move along this pathway without doing themselves—or students—harm.
So, it may be the same as institutions explore different credentials─we need to see whether our communication lacks clarity or where we haven’t done sufficient policy and procedure work to understand the process and procedure. SUNY began having these conversations with us a few years ago when they started coming to us about microcredentials, and that was not terminology that was defined within our policies. We had a credit-hour policy. We also have to rely on federal regulatory language around substantive change, which was recently changed around the approval of credential levels that could be helpful for incremental credentialing.
It is important to have these conversations with our state, system and institutional partners to try to meet institutions’ needs and eliminate areas of vagueness, lacking clarity or where our policy presents a challenge. There is a willingness on our part and that of our Commission to revisit them. Remember, our commissioners are institutional representatives—it’s likely they are having these same conversations at their institutions or with an institution close by. They will be receptive to making sure we are helping our institutions while keeping an eye on quality, student outcomes and regulatory requirements.
Nan Travers (NT): Some questions I’m getting from SUNY faculty are, Can they break up their curriculum? Does it have to stay as a unit of a degree because that’s what they already have the authority for? And if you start to break it apart, what does it do to quality and integrity? Are you getting those kinds of questions at the MSCHE?
CF: Yes, someone from Pennsylvania recently reached out with those sorts of questions. I referred them to our New York colleagues to learn more about these issues because CAYG has been explored there. Quality will always be a concern for an accreditor, whether for a degree or a different credential. Institutions will need to work through their internal governing structures and those at the system and state levels as they approach incremental credentialing. Institutions and accreditors want all programs to be delivered with quality and integrity.
HZ: Have the accreditors taken a position on using Pell funds for shorter-term credentialing?
CF: Have the accreditors talked about it? Yes, many of the accreditors support expanding Pell, including ours. Many of us signed a letter that the American Council on Education sent on behalf of higher education to double Pell. This is probably a good place to note that with the change in the regulations in July 2020, where regional accreditors are no longer bound by geographic region (which we used to rely on), we’re technically now competitors and known more broadly as institutional accreditors. So, we have to be aware of the antitrust laws that govern the ways we act and the conversations we have. The level of detail and collaboration that regional accreditors have been used to in the past is changing; we need to make sure we’re operating within the realm of current regulation and law.
HZ: What are other issues your Commission has taken on recently?
CF: One of our strategic priorities is advocacy─we want to advocate on behalf of our institutions and our students. So, we have signed on to many of the amicus briefs or to ACE letters around issues for DACA, dreamers, the Pell grant and increasing broadband access for all students. My organization has set up regular meetings with small groups of presidents, so they can keep us aware of issues in higher ed from their perspective, allowing us to act as advocates on behalf of our institutions. And the Commission has also launched the Pillars of Change podcast to spotlight highly effective institutional diversity, equity, and inclusion initiatives.
HZ: Are they asking for you to advocate on behalf of credentialing?
CF: The presidents have not yet asked about credentialing, but the conversations we held with them were intended to be focused differently. So, I don’t think we should interpret anything from their not asking about this. I think they’re just trying to get past the impact of the COVID-19 pandemic, get their campuses up and running and safely returning to face-to-face instruction. That said, we know it is an area of interest among our membership. When we did ask our institutions through surveys about what issues the Commission could bring to them for further exploration, this incremental nondegree credentialing ranked very high. And because of that, the Commission offered a webinar so institutional representatives could learn more about this topic. Right now, this is something that most institutions know about, that they’ve heard about, but that they may not have sufficient information about yet—though not all. Some are really moving the needle forward on their individual campuses to approach the changing credentialing world.
HZ: Let’s pick up the conversation in Part 3, to focus on who benefits in an incremental credentialing system and how ready accreditors and institutions may be for this level of transformative change.
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