Statement from the Council of Recognized Accrediting Commissions (C-RAC) Regarding the Accreditation, Innovation, And Modernization (AIM) Negotiated Rulemaking Committee

C-RAC raises questions about not having a voting seat where resulting rules could impact millions of students at 3,000 colleges and universities

WASHINGTON, DC — The Council of Recognized Accrediting Commissions (C-RAC) today issued a formal statement regarding its nominee for primary negotiator representing institutional accreditors not being selected as a voting member of the upcoming Accreditation, Innovation, and Modernization (AIM) negotiated rulemaking committee. Despite unanimous support from all C-RAC members and letters of support from other institutional accreditors, Chair of C-RAC, Heather F. Perfetti, who also serves as President of the Middle States Commission on Higher Education (MSCHE), was selected as a non-voting alternate member of the negotiating committee. 

While C-RAC appreciates Dr. Perfetti’s selection as an alternate negotiator, the role as a non-voting negotiator does not provide a significant enough voice. The Department's decision not to bring a C-RAC member to the primary negotiating role raises questions about the rulemaking process.

C-RAC has remained steadfast in its commitment to accreditation reform through negotiated rulemaking, with repeated calls for inclusion and representation. C-RAC calls upon the selected primary negotiators to demand that the Department and the AIM Committee ensure voting representation based on proportionality of oversight by institutional accreditors. C-RAC's seven member commissions — the Accrediting Commission for Community and Junior Colleges (ACCJC), the Higher Learning Commission (HLC), the Middle States Commission on Higher Education (MSCHE), the New England Commission of Higher Education (NECHE), the Northwest Commission on Colleges and Universities (NWCCU), the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC), and the WASC Senior College and University Commission (WSCUC) — accredit 3,000 Title-IV colleges and universities serving roughly 17 million students with an estimated $120 billion in federal student aid annually. Dr. Perfetti’s nomination as primary negotiator was to represent that broad perspective in the constituency group of institutional accreditors.  The Department’s stated commitment to select negotiators significantly affected by the issues proposed for this negotiation requires Dr. Perfetti’s selection as a primary negotiator. 

C-RAC has consistently demonstrated a willingness to engage constructively with the Department, to participate in reform discussions, and to hold ourselves accountable to rigorous quality standards. We have not shied away from difficult conversations, and we have endorsed many Department initiatives. 

The AIM committee will develop proposed regulations addressing consequential and wide-reaching policy changes, including simplifying the Secretary's recognition of accrediting agencies and related institutional eligibility regulations; examining accreditation's relationship to rising higher education costs; amending requirements for accrediting agencies’ standards; and refocusing quality assurance on data-driven student outcomes. C-RAC members have deep, decades-long experience navigating exactly these issues across the full range of American higher education from community colleges to research universities, from rural institutions to urban campuses, from public flagship universities to small private liberal arts colleges, tribal colleges, and faith-based institutions. This breadth of experience and institutional knowledge is precisely what should be represented at the table through a voting negotiator.

The offer of C-RAC to serve as an alternate voice does not simply affect C-RAC as an organization. It means that the institutions, faculty, students, and communities served by the nation's largest accreditors have no direct vote in shaping regulations that will govern their accreditors and, by extension, their students. The alternate role for a C-RAC member is far too limited and does not serve this process, or federal policy, well. We urge the Department to reconsider this decision.

About C-RAC

C-RAC represents seven federally recognized institutional accrediting commissions that are responsible for accrediting nearly 3,000 postsecondary, degree-granting colleges and universities across the United States. These include over 1,500 public, 1,100 private non-profits, and nearly 100 private for-profit institutions with a broad set of missions and constituencies.