NASFAA, Higher Ed Organizations Provide Comments to ED on Accreditation Process
By Maria Carrasco, NASFAA Staff Reporter
NASFAA joined dozens of other higher education organizations in providing comments to the Department of Education (ED) on the accreditation handbook and process, just as ED announced an upcoming negotiated rulemaking committee focused on accreditation reform.
The letter, led by the American Council on Education (ACE), is in response to a December Federal Register notice where ED requested comments on its accreditation handbook and the accreditation process as a whole. The department also called for comments on an executive order issued by President Donald Trump last year, which called on ED to reform the accreditation process.
Just earlier this week, ED announced that it is seeking nominations for a new negotiated rulemaking committee, dubbed the Accreditation, Innovation, and Modernization (AIM) Committee, focusing on four topics related to accreditation: deregulation, student outcomes, merit, and integrity. The committee will convene for two in-person sessions in April and May.
In the letter, the organizations highlighted different ways ED can improve the accreditation process and raised concerns over some proposals.
For example, the organizations wrote they oppose any measure to establish student achievement standards in regulatory text, or any measures that go beyond the flexibility provided in the Higher Education Act (HEA). Currently, the HEA provides flexibility for institutions in how they measure student achievement. The organizations warned against isolating outcome measures to determine the quality of an institution. Instead, accreditors should use outcome measures in conjunction with on-site visits, institutional reports, and other tools to gain a comprehensive view of the institution and its programs, they argued.
The organizations also proposed that accreditors could create teams of reviewers with deep knowledge of different institution types when conducting on-site inspections. For example, when a historically Black college or university (HBCU) is being inspected by a team, that team of individuals should be familiar with HBCUs, their missions, their culture, how they operate, and their challenges.
The organizations also wrote in support of ED’s move to streamline the process of changing accreditors through a Reasonable Cause Request Certification, and hope this process is codified into regulations.
However, the organizations raised concerns over proposed changes to states’ roles in the accreditation process. Recently proposed legislation would allow states to designate an entity within the state as an accreditor, which could ultimately lead to barriers to Title IV funding for institutions and programs, the letter warned.
The organizations strongly oppose giving states the authority to determine institutional eligibility for federal student aid, also voicing concerns that this measure could undermine program integrity and “improperly insert government officials into matters involving academic quality.”
“We also oppose letting states determine eligibility for federal student aid because states may use that authority to disadvantage some institutions,” the letter reads. “Given the current political environment, we fear a possible negative impact on institutions should a state have any bias against an institution of higher education. In a world of academic freedom and institutional autonomy, institutions should be able to operate and fulfill their mission without fear of losing Title IV funding due to political differences.”
The letter also outlined concerns regarding Trump’s executive order on accreditation. In the executive order, Trump outlined new principles of “student-oriented accreditation,” which called on ED to ensure accreditation “requires that institutions support and appropriately prioritize intellectual diversity amongst faculty in order to advance academic freedom, intellectual inquiry, and student learning.”
The letter warned that this provision in the executive order could be counterproductive, and questioned whether this would be an expansion outside of the HEA’s scope – which ED cannot legally do.
Lastly, the organizations reminded ED that the accreditation handbook is a handbook – meaning that it is not the law. ED should make it clear that only statutes and regulations hold the force of law. When the accreditation handbook is revised, ED should ensure that definitions and processes used in the handbook are aligned with statute and regulatory text.
Publication Date: 1/28/2026
Anthony S | 1/28/2026 10:52:35 AM
Incoming RANT:
Trump has made it clear that Laws only apply to certain people (groups). Removing DEI, Pardoning January 6th Rioters, refusing to release Epstein files, supporting (and encouraging) ICE agents unlawful activity to include lying, blaming and harassing others. Trump accepting a multi-million dollar Jet for himself was not in America's best interest.
Trump is abusing his position of power and we are in an Authoritarian Government. Will he leave peacefully? His unprofessional behavior suggests otherwise.
We all can agree that the Department of Education needed reform, but Linda McMahon? Really? She's had to endure Vince McMahon's abuse for so many years; I don't think that she should be the one handling any countries educational processes.
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