Examining Accreditation Commissioners’ Conflicts of Interest

This report is authored by Preston Cooper with the research assistance of Allie Howell. To read the full report, click  here.

Accreditors are organizations that exist to ensure that institutions of postsecondary education in the United States meet basic standards of quality and financial soundness. To participate in Title IV programs, which include federal student loans and Pell Grants, an institution must obtain accreditation from an agency recognized by the Department of Education. In other words, accreditors are the “gatekeepers” of federal student aid programs.

Each accreditor has a commission or board of directors that issues final decisions on whether schools can receive accreditation. These commissions, which comprise between nine and 73 commissioners per agency, generally have the power to either recognize or terminate the recognition of accredited institutions, as well as set the standards by which these decisions are made. The affiliations of these commissioners are the focus of this report.

We analyze fifteen accreditation agencies listed by the Department of Education as regional or national accreditors. These between them have 332 commissioners. Two hundred thirty five are currently employed at an institution of postsecondary education. The vast majority of these commissioners (221) are employed at institutions that their agency accredits, a potential conflict of interest. These “interested” commissioners represent 67 percent of all commissioners.

We define an “interested commissioner” as a commissioner who is also employed at an institution of postsecondary education accredited by the agency at which he or she is a commissioner—a potential conflict of interest.

College presidents also frequently serve on accreditation commissions. One hundred thirteen college presidents serve as commissioners at their institution’s accreditors. These college presidents account for 51 percent of interested commissioners and 34 percent of all commissioners.

However, these figures are only raw totals: e.g., the total number of interested commissioners divided by the total number of commissioners. A more informative approach, arguably, is to weight the figures by other variables.

For instance, when we weight by the number of institutions each agency accredits, the share of interested commissioners increases to 74 percent, up from 67 percent. Weighting by the Title IV aid each accreditor’s institutions receive raises the share of interested commissioners to 80 percent. In other words, the average dollar of Title IV aid flows to a school whose accreditor has 80 percent interested commissioners.

To be fair, all accreditors have a conflict of interest policy that generally prohibits interested commissioners from voting directly on their school’s accreditation. However, these safeguards may not go far enough. There exists the possibility of logrolling: an interested commissioner casts a favorable vote toward a particular school with which he is not affiliated in exchange for the explicit or implicit promise that other commissioners will make a favorable decision toward his own school when the time comes. As long as an accreditation commission has a substantial number of interested commissioners, it is difficult to prevent such favor-trading.

In addition to trading direct votes on their own institutions, interested commissioners also have a say in developing accreditation standards, which can be designed to be favorable to particular schools without mentioning any by name. Perhaps more importantly, commissioners can design standards that are unfavorable towards schools seeking to gain accreditation. Since a school generally needs accreditation to gain access to Title IV funding, interested commissioners may throw up barriers to accreditation in order to hamper potential competition for their institutions.

Accreditors, which act as gatekeepers of federal Title IV aid, employ commissioners who decide which schools receive accreditation and which do not. This analysis has shown that roughly two-thirds of commissioners at regional and national accreditors recognized by the Department of Education are employed at institutions that their agency accredits. This figure rises when weighted by various characteristics of the accreditors’ recognized institutions. While all accreditors have policies in place to guard against conflicts of interest, these may not be sufficient to stem the undesirable consequences of the high number of interested commissioners at these agencies.

Preston Cooper is a fellow at the Manhattan Institute. Allie Howell is a contributor to E21.

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