Below are comments I presented at today’s meeting of NACIQI, the Department of Education’s advisory committee on educational quality.

Thanks for the work you’re doing here.

At last summer’s meeting you debated how much you should be looking at the conduct of particular schools in your evaluation of accreditors.

When the Department approves an accreditor, that makes a school under that accreditor not just eligible for student aid but also able to tell prospective students that their school has the Department’s seal of approval. Schools that aggressively recruit students often tout just that.

That might be OK if the Department provided sufficient scrutiny of quality and abuses. But some people suggest that’s not really your business, that you can’t possibly address school misconduct in considering accreditors.

The Department did seem to think it was its business that ACICS was approving Corinthian, ITT, and other predatory schools when it made the case to drop that accreditor.

But the Department staff’s report last year on ACCSC did not address that accreditor’s many years tolerating egregious abuses, law enforcement problems, and bad outcomes, especially at the CEHE schools.

You were right to demand greater accountability for ACCSC, even if some of you seemed to have second thoughts after.

Of course the Department and NACIQI should not judge an accreditor solely on the basis of a few schools. But such information is surely relevant.

This isn’t about requiring the accreditation unit or NACIQI to become college detectives, or review every school. It’s about asking you to take into account glaring violations of Department and accreditor standards that are right in front of you, in government investigations, law enforcement actions, and media reports.

If the accreditation unit and NACIQI don’t ask accreditors about blatant school abuses, that greatly reduces the chance that accreditors will genuinely hold schools accountable. And that reduces the chance that students and taxpayers will be protected against waste, fraud, and abuse, abysmal outcomes, and a growing student debt crisis.

You would be on solid ground next year to ask Higher Learning Commission why it has tolerated years of abuses and law enforcement problems at the Perdoceo schools, and asking the same of WASC regarding Ashford University. Fifteen organizations (and me) sent the Department a letter last month asking it to do that.

You also would be right to ask SACS this summer about its toleration of issues at Keiser University, including abuse of non-profit status, as Senators Durbin, Warren, and Brown asked in 2017, and I asked the Department last August. Those senators and also Chairman Scott of House Education and Labor wrote the Department this month seeking investigations of Keiser.

Please always consider how much good you can do by asking hard questions. Thank you.