Higher Education Accreditors Don’t Want to Hear Your Complaints

Say you are a student at a university, and you have a complaint you want to submit to the institution’s accrediting agency. It could be, for example, that your college offering classes without a professor to teach them, as happened at Southeastern College, or the fact that the nursing school is graduating students without having them complete the minimum number of clinical hours required, as a complaint to the Southern Association of Colleges and Schools Commission on Colleges (SACS) alleges.[1] It should be easy to do that, right? After all, accreditors are meant to hold the colleges they oversee responsible for the quality of education they provide to students.

Think again.

If you want to submit a complaint to SACS, for example, you will need to specify exactly which section of the accreditor’s “Principles of Accreditation” your complaint falls under.[2] Once you know what standard(s) your college has violated—assuming you can figure out the legalese and complicated accreditor jargon—you will need to complete the complaints form and attach whatever evidence you have, in duplicate. These duplicates have to be physical copies, so if you lack a printer, you will need to pay for those pages. Oh, and if you have audio recordings that are part of your evidence, you will need to get those professionally transcribed. Professional transcription services cost around a dollar per minute, and you will need to check the transcriptions for accuracy. Finally, you must create a cover form and visit a notary to swear to the veracity of the transcripts. According to SACS, all these steps are necessary to make sure that “it's an honest complaint.”[3]

You cannot do any of this until you have exhausted the complaints process with your school. But depending on the complaint, starting with your college could feel risky. For example, you might hamper your progress through the program if you complain that its professors are not properly qualified. If you are a staff or faculty member, complaining about the standard of education your institution provides could cost you your job.

If you have assembled a complaint, despite these risks, you will need to mail all the documents to SACS and wait. If your complaint does not meet all the criteria SACS officials have established, they will send it back and tell you to fix and resubmit it. Missing any one of the numerous criteria required to successfully submit a complaint to SACS could lead to your complaint being rejected until you get every detail right—something likely to push you into giving up, and your college being let off the hook.

Belle Whelan, the president of SACS, was asked about this arcane and complicated process at a recent meeting of the U.S. Department of Education’s National Advisory Committee on Institutional Quality and Integrity (NACIQI), which reviews accrediting agencies and advises the Department on whether the agencies are meeting required standards. In response, she said the agency wanted to ensure people complaining were not just trying to make trouble for an institution, as if mistreated students spend their time thinking up ways to make up spurious complaints about their colleges.[4]

We have a form, a complaint form that asks them to tie whatever [accreditation] standard. And we ask them to sign the form. Because otherwise we don't know whether this is a legitimate complaint or somebody's just trying to, you know, create problems for an institution.

Confused yet? Angry, even? Well, that may just be the point. The SACS complaints process seems like it was designed to protect its member colleges rather than the students who attend them. The SACS approach to complaints is the most complicated and convoluted of the seven regional accreditors in the United States.[5] Still, all seven have seemingly arbitrary requirements created outside of the federal statute and Education Department regulations that govern them.

This brief explores three issues: how accreditors have made it difficult to lodge complaints about institutions, how regulations and limited oversight of accreditors have made the burdensome complaints process possible, and how we can go about fixing things.

Accreditors are part of the program integrity triad, along with the Education Department and states, that act as gatekeepers for federal student aid money. Prior work from New America has raised concerns that the triad is not providing effective accountability.[6] Accreditors are charged with ensuring the academic quality of the colleges they endorse. For example, accreditors can require that institutions employ appropriately trained and qualified faculty members, assess whether students receive sufficient academic support, and make sure that students are completing their programs at a reasonable rate. Accreditors are required to ensure that colleges are meeting these standards, and the Department leaves these issues in the hands of accrediting agencies. As a result, if accreditors fall down on the job, there is very little to prevent students from being harmed by poorly performing schools.

These agencies accredit entire institutions, providing the stamp of approval that colleges need to access Title IV financial aid dollars. Because most institutions do not have the resources to operate without access to federal financial aid for their students, accreditation is essential for keeping colleges solvent. Kevin Carey, Vice President for Education Policy and Knowledge Management at New America, has noted that accrediting agencies are largely run and staffed by former senior college administrators, who tend to view the world in terms of what is good for colleges rather than for students.[7] Accreditors are mostly financed through member fees.

Accreditors, unfortunately, have a poor history of ensuring that institutions provide students with a high-quality education. Some accreditors have failed to protect students from failing institutions for years on end, including colleges like Ashford University, which a California court found in 2022 systematically deceived veteran students.[8]

The Trump administration made these challenges worse by loosening accreditation regulations in 2019. It rewrote Education Department regulations to allow agencies to accredit institutions outside their traditional regions, giving higher education institutions much longer to fix problems before being sanctioned, and reducing accountability for colleges if they were offering “innovative” programs. New America raised concerns about these shifts when they were enacted.[9] These changes have created an environment where institutions can shop for the accreditor they believe will provide the least oversight. Florida, for example, has already taken advantage of these changes to push its public institutions to switch accreditors every cycle (usually every 10 years) in response to questions from SACS about politicians interfering in institutional governance in order to limit academic freedom of professors. We have written previously about how damaging these changes could be for higher education in Florida.[10]

Given how difficult it is for students at problematic colleges to submit complaints, accreditors are likely missing a lot of issues at the colleges they oversee. Complaints help provide insight into colleges performance, so it seems evident that making it easier for students to submit complaints about their institutions could help accreditors do their job more effectively.

Accreditors have a duty to ensure that the colleges they approve are providing students with the education promised. The accreditation process is a long one, and up to 10 years can pass between accreditor visits to campus. In the years between visits, complaints provide a crucial indication of whether a college is living up to accreditation guidelines; accreditors should welcome complaints as one of many information sources used to determine whether schools are living up to their standards.

A large number of complaints about a college can be an early warning sign that something is amiss. If accreditors make it arbitrarily difficult to submit complaints, they can suppress the number of complaints made, potentially hiding problems that should be investigated.

All seven regional accreditors have problematic complaints processes. Most require complainants to proactively identify the standards that have been violated, all prohibit anonymous complaints, and all require complainants to have exhausted the complaints process with their college before coming to the accreditor.

In addition, there are no uniform standards for complaints. Every regional accreditor has a different process. Allowing accreditors to have significantly different standards for one of their core functions might prove an incentive for institutions that wish to avoid strict oversight to move to an accreditor with the most beneficial complaints process. Allowing lax complaints standards also gives colleges room to behave poorly for extended periods of time, knowing that the chances that issues get raised with their accreditor are slim.

Accreditors serve a vital role as one-third of the program integrity triad. The triad is intended to ensure quality and accountability in higher education. But, as with any three-legged stool, if one leg breaks, the whole structure collapses.

This brief focuses on the seven regional accreditors because they play an outsized role in controlling access to federal financial aid, which totals $110.42 billion annually. These accreditors oversee about 85 percent of the country’s colleges and universities, and combined, the institutions they accredit receive almost 90 percent of federal financial aid dollars.[14]

The following are the regional agencies whose complaints processes we reviewed and the amounts of federal student aid they controlled access to in 2022:

• Higher Learning Commission (HLC)
  • $31.56 billion
• Southern Association of College and Schools Commission on Colleges (SACS)
  • $29.97 billion
• Middle States Commission on Higher Education (MSCHE)
  • $18.65 billion
• WASC Senior College and University Commission (WSCUC)
  • $9.2 billion
• New England Commission of Higher Education (NECHE)
  • $6.51 billion
• Northwest Commission on Colleges and Universities (NWCCU)
  • $5.03 billion
• Accrediting Commission for Community and Junior Colleges (AJCCJC)
  • $1.69 billion

We reviewed the websites of each of these agencies. This review captured each agency's complaints process documents and forms.

Prior work by The Institute for College Access and Success (TICAS) on ways to improve complaints processes in higher education identified five key principles for creating processes that serve students.[15] We have adapted those criteria to help evaluate accreditor complaints processes.

These criteria are:

• Processes should be easy to understand, with simple tools to submit complaints.
• Complainants should receive fast initial responses and be able to track the progress of their complaint.
• Agencies should proactively monitor complaints to identify problematic patterns.
• Data on complaints should be publicly available to create transparency.
• Processes should operate independently of the institutions overseen.

We reviewed all the criteria that institutional accreditors used in their complaints processes and judged them against the design principles listed above. These criteria included key standards, such as whether an agency had an online submission process, the maximum time frame after an incident the agency would consider complaints, and whether the agency required complainants to identify the accreditation standard they thought had been violated.

Differing standards, combined with the removal of regional boundaries for accreditors, sets up the perfect conditions for a race to the bottom in higher education oversight. A review of the complaints processes used by the seven regional accreditors reveals no common standard in how they handle complaints. The Education Department recently issued public guidance, outlined in a blog by Antoinette Flores, Senior Policy Advisor at the Department, making it clear that it will not allow accreditation to become a downward spiral of quality standards.[16]

It is challenging to provide a complete review of how accreditors currently handle complaints because there is limited public information available. Accreditors are not required to release data on how many complaints they receive or how those complaints are resolved. New America has called for increased transparency from accreditors around complaints, suggesting, among other things, that they should be required to publish data on how many complaints they receive per institution and how those complaints are settled.[17]

Table 1 shows some of the barriers that regional accreditors have put in place that make it challenging for individuals to successfully lodge complaints.

Requiring Complaintants to Specify Accreditation Standards

Five of the seven regional accreditors require complainants to identify the accreditation standard that the institution has violated, rather than just stating the nature of their complaint. Given the complexity of accreditation standards, this is a high bar to clear. Only two agencies, HLC and WSCUC, will consider complaints without indication of a specific violated standard. Still, HLC recommends that complainants read its accreditation standards before submitting their concerns.

Few people outside of the staff at accrediting agencies, the Education Department, and college personnel who deal with accreditation are familiar enough with agency requirements to know whether something violates an accreditor’s standards. Requiring non-experts, including college students, to determine what accreditation standard they believe has been breached and, in some cases, provide the exact citation for the standard in question, is likely depressing the number of complaints accreditors receive.

By requiring people submitting complaints to identify what standard their college has breached, accreditors are asking others to do their jobs for them. Students, staff, and faculty who raise concerns about their college’s actions do their part by bringing a problem to the accreditors’ attention. Once a concern has been raised, accreditors should determine whether their standards have been violated. Nothing prevents accreditors from determining that a complaint lacks merit or is outside their purview after a thorough review.

Requiring Complainants to Go to Colleges First

None of the accreditors allow anonymous complaints, making it risky for students and staff to lodge complaints if they fear their college might retaliate against them for raising problems with institutional behavior. Further, all of the regional accreditors require that complainants exhaust the complaints process with their institution before they bring their issue to the accrediting agency. This combination of restrictions makes it challenging for students, faculty, and staff to bring up problems if they believe it would pose a risk to their academic success or their job. These requirements also mean the complaints process is never truly independent of the institutions.

Imposing Time Cutoffs for Complaints

Accreditors have widely differing standards for how long ago an incident has occurred for them to consider a complaint about it. Three of the agencies require that complaints be submitted within one year of an incident. This is a very short window, especially as poor performance can take years to surface in higher education.

NECHE is the most generous with its complaint time frame, allowing complaints to be lodged up to three years after an incident has occurred.[18] However, even three years is a relatively short time, since students often do not realize the quality of education they received was poor until they try to get a job, attempt to transfer to another college, or find out that their institution misrepresented job placement rates and earnings potential.

The arbitrary time cutoff for complaints is made worse when combined with the need to exhaust any grievance process with the college before going to the accreditor. There is no justification for this combination of barriers.

Making It Difficult to Track Complaints

Agencies have differing time frames for acknowledging receipt and review of complaints. These range from 10–30 working days for acknowledgment, and from completely unspecified to 60 working days for review. Accreditors also provide limited opportunities for complaints to be tracked through their complaint process. The combination of long, and even undefined, response windows and the lack of tracking ability is particularly problematic. With no way to know what is happening with a complaint or how long a response will take, complainants may feel like they are shouting into the void. NECHE, for example, takes more than a month even to acknowledge that a complaint has been received.

Ranking the Accreditors’ Complaint Processes

None of the agencies meet the five criteria for having an effective complaint process. SACS has by far the most burdensome complaints process of all the regional agencies. While some agencies are better than others, the bright spots are limited. WSCUC’s is the easiest to navigate and does not require complainants to digest and understand complex accreditor standards and jargon. However, WSCUC falls short in other areas: it refuses to accept anonymous complaints, has a one-year complaint window, and insists that redress is first sought from the institution. Being the “best” in this instance is not much to write home about.

There is no need for the complaints process to be this complicated. Many oversight agencies take much simpler approaches. Take, for example, the Consumer Financial Protection Bureau (CFPB), which handles tens of thousands of complaints about financial products every week. The entire complaints process is easily accessible and can be completed online in 5–10 minutes. The CFPB process does not require an intimate knowledge of complex federal regulations, and complaints can be submitted anonymously. Complaints are trackable, and the turnaround on complaints is typically two weeks or less.[19] CFPB complaints are also publicly accessible.

Accreditors are much smaller and have fewer resources than the CFPB. Still, they oversee fewer institutions and are not, to our knowledge, dealing with tens of thousands of complaints every week. Making their complaints processes simpler and more streamlined would make reviewing complaints easier for the agencies themselves. It is hard to imagine how a completely paper process, like that of SACS, is easy to administer. It seems almost designed to be overly complicated for all involved. SACS could presumably easily create an online form, like its peers.

There are examples of accreditors who have designed much easier complaints processes. During the same NACIQI meeting where SACS’s process was heavily critiqued, committee members praised the Accreditation Council for Pharmacy Education (ACPE), a programmatic accreditor, for its relatively straightforward approach to complaints.[20] The ACPE process includes drop-down menus that allow students to identify that element of the agency’s standards they think has been violated without requiring them to parse complicated standards, and it includes a simple online form for submitting complaints. ACPE’s approach shows that some accreditors are working to provide consumer-friendly procedures, unlike the regional agencies that cover the largest number of students and institutions.

Accreditors are inherently compliance-focused organizations, but that does not give them license to maintain inaccessible processes. Having created a complaints process and using that to indicate compliance with regulations is insufficient. As New America, The Center for American Progress, and the Wall Street Journal have extensively documented, accreditors have consistently shown themselves resistant to changing their processes when doing so would harm even the worst colleges they oversee.[21]

If accreditors are unwilling to fix their complaints processes, as history suggests they will be, then the Education Department and NACIQI may have to step in and force change.

Simply having a complaints process should not be sufficient to pass muster. The Education Department and NACIQI can help protect students and taxpayer dollars by creating clear and concrete rules governing complaints. The Department can and should provide accreditors clear guidance on the minimum expectations in this area. And the Department and NACIQI should make obvious that adherence to those standards will be an integral part of the accreditor recognition process. The Department should also include revisions to regulations governing complaints in the negotiated rulemaking it intends to hold this year.

All accreditors should abide by a shared set of minimum standards for their complaint procedures. Here we provide recommendations on what those standards should be, arranged according to the guiding principles outlined above. Many of these changes could be made immediately, and the Education Department should issue guidance directing accrediting agencies to revise their procedures to meet these standards.

1. Processes should be easy to understand, with simple tools to submit complaints.

Accreditors should accept complaints online and allow for digital and typed signatures. Agencies should review all complaints to determine whether the grievance relates to an accreditation standard and falls within their remit. Students and staff are not experts on accreditation, nor should they need to be to raise concerns about institutional behavior.

2. Complainants should receive fast initial responses and be able to track the progress of their complaint.

Accreditors should shorten response times and provide regular updates on the status of all complaints submitted to them.

3. Agencies should proactively monitor complaints to identify problematic patterns.

Accreditors need to follow up with colleges when they receive multiple anonymous or identified complaints about the same or similar issues. The accrediting agencies should also consider complaints from other regulatory entities, including, but not limited to, states, the Education Department, or other federal agencies.

4. Data on complaints should be publicly available to create transparency.

There is no publicly available information on complaints submitted to accreditors. The Education Department and NACIQI should require accrediting agencies to release data on all complaints they receive. This could be made part of the Database of Accredited Postsecondary Institutions and Programs (DAPIP)[22] as a way to provide information in a timelier manner. Data on complaints should include the following:

• The number of complaints received by an accreditor, broken down by the college or university that is the subject of the complaints.
• The number of complaints that each accreditor rejected for administrative or procedural reasons.
• The number of complaints accreditors followed up on.
• The number of complaints that led a college or university to take action after the accreditor inquired about issues raised.
• The number of complaints resulting in any accrediting agency action against a college or university.

5. Processes should operate independently of the institutions overseen.
Students and college faculty members or staff should not be required to exhaust college and university grievance processes before submitting a complaint to accreditors. Accrediting agencies should investigate concerns even when the complainant is not comfortable submitting a complaint directly to the institution.

Accreditors should also accept and follow up on anonymous complaints. In addition, accreditors should require colleges to share an overview of complaints they have received from students, since most complaints are likely to go straight to the institutions. Agencies should also use publicly available sources of complaints, to ensure they are proactive in their monitoring of colleges’ behavior.

Once the Education Department has instructed institutions on how to revise their complaints processes, NACIQI should review these revised processes during the agency recognition review to ensure that accreditors are complying with Department guidance.

In addition to providing guidance to accreditors on best practices, changes need to be codified to ensure future compliance. The Education Department has listed accreditation as a topic up for regulation during negotiated rulemaking in 2023.[23] Improving accreditors' complaints processes should be part of that regulatory agenda. Codifying higher standards in the regulations will ensure that accreditors improve their processes.

Currently, accreditor complaints processes at the seven regional accreditors are not consumer-friendly and fail to meet the standard of effective policies. Some accreditors' processes are more consumer-friendly than others, but none provide an easy, streamlined approach available for a reasonable period after the incident which led to a complaint.

By creating overly complex complaints processes, accrediting agencies are likely suppressing the number of complaints they receive and missing problems at institutions that warrant investigation. New, robust Education Department guidelines and regulations are needed to push accreditors to change.

New America would like to thank Arnold Ventures for its generous support of this project, and the Bill & Melinda Gates Foundation for its generous support of our work. The views expressed in this report are those of its author and do not necessarily represent the views of the funders their officers, or employees.

Thanks to Tiara Moultrie and Carolyn Fast from the Century Foundation, Clare McCann from Arnold Ventures, and Jared Bass from the Center for American Progress for reviewing early drafts and providing helpful suggestions. I would also like to thank Steve Burd and Rachel Fishman for their thoughtful feedback. The work is better for their comments.

[1] Kevin Carey, “Asleep at the Seal: Just How Bad Does a College Have to be to Lose Accreditation?” Washington Monthly, March 1, 2010, https://washingtonmonthly.com/2010/03/01/asleep-at-the-seal/; and This complaint was highlighted at a meeting of the National Advisory Committee on Institutional Quality and Integrity (NACIQI), meeting transcript, July 19–21, 2022, Day 3, 214, https://sites.ed.gov/naciqi/files/2022/08/Transcription_NACIQI-Day-3-revised_2022-07-21.pdf

[2] The Southern Association of College and Schools Commission on Colleges, Complaints Against SACSCOC or its Accredited Institutions Policy Statement, 2019, https://sacscoc.org/app/uploads/2020/01/ComplaintPolicy-1.pdf

[3] NACIQI, transcript, 206.

[4] NACIQI, transcript, 209.

[5] Until 2019, the agencies this brief focuses on were known as “regional accreditors” because they were allowed to only accredit institutions within their particular regions. The Department of Education, under the Trump administration, made changes to regulations that removed regional boundaries and allowed these agencies to operate nationally. For the sake of simplicity, the brief refers to the agencies in question as regional accreditors even though they are no longer restricted to those historical boundaries.

[6] Clare McCann and Amy Laitinen, The Bermuda Triad: Where Accountability Goes to Die (Washington DC: New America, 2019), https://www.newamerica.org/education-policy/reports/bermuda-triad/

[7] Carey, “Asleep at the Seal.”

[8] Natalie Schwartz, “Court Fines Ashford University and Zovio $22.4M for Misleading Students,” Higher Ed Dive, March 8, 2022, https://www.highereddive.com/news/court-fines-ashford-university-and-zovio-224m-for-misleading-students/620058/; Veterans Education Success, Summary of Veteran and Servicemember Student Complaints about Ashford University (Washington DC, 2020), https://vetsedsuccess.org/summary-of-veteran-and-servicemember-student-complaints-about-ashford-university/; Antoinette Flores, The Unwatched Watchdogs: How the Department of Education Fails to Properly Monitor College Accreditation Agencies (Washington DC: Center for American Progress, September 19, 2019), https://www.americanprogress.org/article/the-unwatched-watchdogs/; and McCann and Laitinen, The Bermuda Triad.

[9] Clare McCan and Amy Laitinen, Comments on Proposed Accreditation and State Authorization Rules (Washington, DC: New America, July 12, 2019), 33, https://s3.amazonaws.com/newamericadotorg/documents/New_America_Comments_on_Accreditation_State_Authorization_NPRM.pdf

[10] Edward Conroy, “Not So Fast! Department of Education Puts Colleges on Notice About Accreditor Shopping,” EdCentral (blog), New America, August 9, 2022, https://www.newamerica.org/education-policy/edcentral/department-of-ed-puts-colleges-on-notice-about-accreditor-shopping/

[11] Operating procedures all agencies must have, 34 CFR § 602.23(c).

[12] Recognition of accrediting agency or association, The Higher Education Act of 1965, 20 U.S. Code § 1099b 5(i), 747, https://www.govinfo.gov/content/pkg/COMPS-765/pdf/COMPS-765.pdf

[13] Procedures for submitting an application for recognition, renewal of recognition, expansion of scope, compliance reports, and increases in enrollment, 34 CFR 602.32(f).

[14] National Advisory Committee on Institutional Quality and Integrity, Recognized Institutional Accreditors: Federal Postsecondary Education and Student Aid Data (Washington, DC: U.S. Department of Education, July 2022), 9, https://sites.ed.gov/naciqi/files/2022/06/Accreditor-Dashboards-Updated-Summer-2022-1.pdf

[15] Angela Perry, Debbie Cochrane, Libby Masiuk, and Ana Fung, Unheard Voices: The Case for Improving the Higher Education Complaints Systems (Washington, DC: The Institute for College Access and Success, 2020), 11, https://ticas.org/accountability/unheard-voices-the-case-for-improving-higher-education-complaints-system/

[16] Antoinette Flores, “Postsecondary Accreditation Cannot Become a Race to the Bottom,” Homeroom (blog), U.S. Department of Education, July 19, 2022, https://blog.ed.gov/2022/07/postsecondary-accreditation-cannot-become-a-race-to-the-bottom/

[17] Edward Conroy and Rachel Fishman, “Comments to the Department of Education Regarding Information Collected for the Database of Accredited Postsecondary Institutions and Programs,” New America (website), December 15, 2022), https://www.newamerica.org/education-policy/public-comments/comments-to-the-department-of-education-regarding-information-collected-for-the-database-of-accredited-postsecondary-institutions-and-programs/

[18] NWCCU specifies one year from exhausting the institution’s complaint process. MSCHE allows two years from exhausting the institutional process rather than time elapsed since the incident.

[19] Consumer Financial Protection Bureau (website), “Submit a Complaint,” https://www.consumerfinance.gov/complaint/

[20] Programmatic accreditors focus on individual programs, often those requiring licensure to practice, such as nursing, rather than reviewing entire colleges.

[21] Andrea Fuller, and Douglas Belkin, “The Watchdogs of College Education Rarely Bite” Wall Street Journal, June 17, 2015, https://www.wsj.com/articles/the-watchdogs-of-college-education-rarely-bite-1434594602; Flores, The Unwatched Watchdogs; and McCann and Laitinen, The Bermuda Triad.

[22] DAPIP is a database of information about accreditor actions taken when institutions fail to meet their standards.

[23] Office of Information and Regulatory Affairs (website), “Fall 2022 Unified Agenda of Regulatory and Deregulatory Actions,” https://www.reginfo.gov/public/do/eAgendaMain