An Overview of Accreditation of Higher Education in the United States

December 12, 2014 – April 12, 2024 R43826

An Overview of Accreditation of Higher
April 12, 2024
Education in the United States
Alexandra Hegji
The federal government provides varying types of support to postsecondary students and schools,
Analyst in Social Policy
including student financial assistance (e.g., Pell Grants and Direct Loans) authorized under Title

IV of the Higher Education Act (HEA). Postsecondary schools seeking to participate in these
federal programs must meet a variety of requirements, including being accredited by an agency

recognized by the U.S. Department of Education (ED) as a reliable authority on the quality of the
education being offered.
The United States does not have a centralized authority exercising singular national control over postsecondary educational
institutions. Consequently, the character and quality of postsecondary schools and their programs can vary widely. The role
of accreditation in higher education is to serve as a marker of a level of acceptable quality across the wide array of
postsecondary schools and educational programs. The federal government has come to rely on accrediting agencies
recognized by ED to help ensure the postsecondary institutions and educational programs to which federal funds are provided
meet a minimum quality level.
Higher education practitioners and stakeholders refer to three general types of accrediting agencies, each of which serves a
specific purpose. Regional accrediting agencies concentrate their reviews on institutions in specific regions of the United
States. National accrediting agencies operate across the United States and primarily review proprietary institutions, career-
based single-purpose institutions, and religiously affiliated institutions. Programmatic accrediting agencies operate
nationwide and review individual educational programs and single-purpose institutions. ED refers to the different accreditors
as institutional accreditors, which evaluate entire postsecondary schools and comprise regional and national accreditors, and
programmatic accreditors.
The accreditation process is voluntary and educational institutions or programs must request it. While ED-recognized
accrediting agencies’ review processes are guided in part by federal requirements, specific procedures for reviews are
adopted by the individual agencies and vary among them. In general, however, the review process begins with an institutional
self-assessment, and is followed by an institutional review by an outside team of peers primarily composed of higher
education faculty and practitioners, submission of a comprehensive report by the team to the accrediting agency, the agency’s
accreditation determination, and regular subsequent reviews of accredited institutions.
Although the federal government relies on accrediting agencies to evaluate the quality of education offered at postsecondary
schools, the HEA and ED regulations specify a variety of requirements that accrediting agencies must meet to be recognized
by ED. Key provisions require that accrediting agencies
• consistently apply and enforce standards that ensure the education programs offered are of sufficient
quality to meet the stated objective for which they are offered;
• use review standards that assess student achievement in relation to the institution’s mission, including, as
applicable, course completion, passage of state licensing examinations, and job placement rates;
• evaluate, among other considerations, an institution’s or program’s curricula, faculty, facilities, and fiscal
and administrative capacity; and
• meet required operating and due process procedures with respect to the institutions and programs they
accredit.
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An Overview of Accreditation of Higher Education in the United States

Introduction
The federal government provides varying types of support to postsecondary students and schools.
Title IV of the Higher Education Act of 1965 (HEA; P.L. 89-329), as amended, authorizes the
primary programs that provide financial assistance (e.g., Pell Grants and Direct Loans) to students
to assist them in obtaining a postsecondary education at eligible institutions of higher education
(IHEs). In academic year (AY) 2022-2023, 5,918 IHEs were eligible to participate in the Title IV
student aid programs.1 Approximately $114.1 billion was made available to students through Title
IV student aid in FY2023.2 Thus, the federal government has an interest in ensuring the quality
and integrity of postsecondary education in general, and of postsecondary education provided by
IHEs in particular. However, federal law makes clear that the U.S. Department of Education (ED)
shall not exercise control over educational curriculum.3 As such, the HEA sets forth three
requirements—known as the program integrity triad—that IHEs must meet to participate in the
Title IV programs.
The three requirements are state authorization, certification by ED, and accreditation by an
accrediting agency or association (hereinafter referred to as an accrediting agency) recognized by
ED.4 The program integrity triad is intended to provide a balance in the Title IV eligibility
requirements. The states’ role is consumer protection, the federal government’s role is oversight
of compliance to ensure administrative and fiscal integrity of Title IV programs at IHEs, and the
accrediting agencies’ role is to provide quality assurance of the education or training offered by
IHEs.
This report provides an overview of accreditation of postsecondary education in the United
States, including its role in the HEA Title IV program integrity triad. It begins with a brief history
of accreditation’s historical role and purpose in higher education. It then describes the
organization of accrediting agencies and the accreditation process. Finally, it discusses the federal
role in accreditation.
Historical Role of Accreditation in Higher Education
Historically, accreditation in higher education developed as a part of the evolution of the
American higher education system, at a time when it was becoming problematic that no single
point of control or central body existed to set educational standards. In the late 19th century, there
was no consensus on the content of the educational programs offered by postsecondary
educational institutions or the distinctions between educational offerings at secondary and
postsecondary institutions. Because the boundaries were unclear, the first voluntary associations
of postsecondary institutions formed in the late 19th century to define the difference between high

1 U.S. Department of Education, National Center for Education Statistics, IPEDS Data Explored, Table 1, Number and
percentage distribution of Title IV institutions, by control of institution, level of institution, and region: United States
and other U.S. jurisdictions, academic year 2022–23, https://nces.ed.gov/ipeds/search?query=
Tables+Library%3Ddate_desc&query2=&resultType=all&page=1&sortBy=date_desc&overlayTableId=35945.
2 This includes federal loans, work-study, and grants. See U.S. Department of Education, Federal Student Aid, FY2023
Annual Report, Washington, DC, November 16, 2023, p. 13, https://www2.ed.gov/about/reports/annual/2023report/fsa-
report.pdf.
3 Section 103(b) of the Department of Education Organization Act (P.L. 96-88), as amended, states that no provision of
a program administered by ED “shall be construed to authorize the Secretary or any officer to exercise any direction,
supervision, or control over the curriculum, program or instruction, administration, or personnel of any educational
institutions.”
4 For additional information on the program integrity triad and other Title IV institutional eligibility criteria, see CRS
Report R43159, Institutional Eligibility for Participation in Title IV Student Financial Aid Programs.
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An Overview of Accreditation of Higher Education in the United States

school and college and to develop some guidelines and procedures for peer review as a condition
for membership.5
Over time, a number of regional associations of postsecondary schools formed whose
membership was contingent on accreditation. The associations established separate accrediting
bodies or commissions that were responsible for developing standards on the institutional
qualifications for membership. By the early 1970s, all but a small percentage of degree-granting
institutions of higher education were either accredited or applicants for accreditation.6
Purpose of Accreditation in Higher Education
The United States does not have a centralized authority exercising singular national control over
postsecondary educational institutions. The states assume varying degrees of control over
education, but in general, postsecondary schools are permitted to operate with considerable
independence and autonomy. Consequently, the character and quality of postsecondary schools’
programs can vary widely. The role of accreditation in higher education, therefore, is to serve as a
marker of a level of acceptable quality of educational programs and postsecondary schools.
ED describes the current practice of accreditation as “a means of conducting nongovernmental,
peer evaluation of educational institutions and programs” and lists the following as some of the
functions of accreditation:
1. assess the quality of academic programs at institutions of higher education;
2. create a culture of continuous improvement of academic quality at colleges and
universities and stimulate a general raising of standards among educational institutions;
and
3. involve the faculty and staff comprehensively in institutional evaluation and planning.7
Accrediting Agencies
Accrediting agencies are often categorized based on the scope of work they perform. For
purposes of participation in federal programs, including the HEA Title IV federal student aid
programs, ED scrutinizes accrediting agencies and determines whether they are reliable
authorities as to the quality of education offered.8 ED refers to institutional accreditors and
programmatic accreditors. In addition, higher education practitioners and stakeholders refer to
regional, national, and programmatic accrediting agencies. In general, institutional accreditors

5 Fred F. Harcleroad and Judith S. Eaton, “The Hidden Hand: External Constituencies and Their Impact,” in American
Higher Education in the Twenty-First Century: Social, Political and Economic Challenges, edited by Altbach et. al,
Third Edition, 2011, pp. 263 (hereinafter, “Harcleroad and Eaton, The Hidden Hand”).
6 For additional information on the history of accreditation in higher education, see Harcleroad and Eaton, The Hidden
Hand.
7 See U.S. Department of Education, “Accreditation in the United States,” https://www2.ed.gov/admins/finaid/accred/
accreditation_pg2.html, accessed March 29, 2024.
8 HEA §496(a). The Council for Higher Education Accreditation (CHEA) is a national membership organization of
degree-granting colleges and universities that also recognizes the quality of accreditation agencies. Council for Higher
Education Accreditation, “CHEA at a Glance,” October 7, 2022, https://www.chea.org/sites/default/files/pdf/
CHEA%20At%20A%20Glance%20-%20Oct-12-2022.pdf. Accreditation by a CHEA-recognized accrediting agency is
not necessary for IHEs to participate in federal programs but may be necessary pursuant to some state laws. See, for
example, Burns Ind. Code Ann. §25-23.6-10.5-4; 59 Okl. St. §567.12a; and 63 P.S. §1707.
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comprise accrediting agencies that stakeholders and practitioners refer to as regional and national
accreditors.9 Each of these types of accrediting agencies is discussed in detail below.
Institutional Accreditors
Accreditation status from institutional accreditors is granted to an entire institution, including all
of its programs. However, such status does not guarantee the quality of individual programs.
Regional Accrediting Agencies
Regional accrediting agencies generally concentrate on specific regions of the country.10 They
started as leagues of traditional universities and colleges in particular areas of the country.11
Seven regional accrediting agencies operate in six regions of the United States.12
National Accrediting Agencies
National accrediting agencies operate across the United States. They started as associations of
schools with a common theme, many of which served vocational and technical schools. In
general, national accrediting agencies may be categorized as faith-based or career-related. The
faith-based accreditors review religiously affiliated or doctrinally based institutions. The career-
related accreditors mainly accredit proprietary institutions and career-based single-purpose
institutions (e.g., focused on business and technology).13
Programmatic Accrediting Agencies
Programmatic accrediting agencies (sometimes referred to as specialized accrediting agencies)
operate nationwide and review programs and single-purpose institutions (e.g., engineering and
technology). In many instances, particular programs (e.g., law) are accredited by a specialized
accrediting organization, while the institution at which the program is offered is accredited by a

9 Prior to regulations that became effective July 1, 2020, ED also referred to these three types of accrediting agencies.
During its 2019 rulemaking on accreditation, ED stated it would no longer categorize accrediting agencies as regional
or national for “Department business.” Rather, it would use an umbrella term, referring to both types of accrediting
agencies as “institutional accreditors.” Some state laws and regulations may distinguish between regional and national
accrediting agencies. U.S. Department of Education, “Student Assistance General Provisions, the Secretary’s
Recognition of Accrediting Agencies, the Secretary’s Recognition Procedures for State Agencies,” 84 Federal Register
58850, 58903, November 1, 2019.
10 Prior to July 1, 2020, ED regulations required that the geographic region on which an ED-recognized agency
concentrated include “at least three States that are reasonably close to one another.” On July 1, 2020, new ED
regulations went into effect, which specify that a geographic region in which an agency concentrates includes a group
of states “chosen by the agency.” 34 C.F.R. §602.11(b) and U.S. Department of Education, “Student Assistance
General Provisions, the Secretary’s Recognition of Accrediting Agencies, The Secretary’s Recognition Procedures for
State Agencies,” 84 Federal Register 58918, November 1, 2019. In light of these changes, at least one accrediting
agency decided to expand its geographic concentration. Doug Lederman, “Go East (or North), Regional Accreditor,”
Inside Higher Ed, February 29, 2020.
11 See, for example, American Council on Education, Assuring Academic Quality in the 21st Century: Self-Regulation
in New Era, 2012, p. 9.
12 The seven regional accrediting agencies are the Accrediting Agency for Community and Junior Colleges Western
Association of Schools and Colleges (WASC), the Higher Learning Commission, the Middle States Commission on
Higher Education, the New England Commission of Higher Education, the Northwest Commission on Colleges and
Universities, the Southern Association of Colleges and Schools Commission on Colleges, and WASC Senior College
and University Commission.
13 Judith S. Eaton, An Overview of U.S. Accreditation, Council for Higher Education Accreditation, Washington, DC,
November 2015, p. 2 (hereinafter, “CHEA, Overview of Accreditation”).
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regional or national accrediting agency. Programmatic accreditation can demonstrate that a
specific department meets established standards for a certain field of study. For example, many
prospective employers require graduation from a program accredited by a certain programmatic
accrediting agency, and licensure requirements for some fields in certain states require recognized
programmatic accreditation. Certain programmatic accrediting agencies also accredit professional
schools and other specialized or vocational IHEs that are freestanding in their operations. Thus, a
specialized or programmatic accrediting agency may also function in the capacity of an
institutional accrediting agency.
The Accreditation Process
The accreditation process is voluntary and must be requested by educational institutions or
programs. Accreditation is an ongoing process and the initial earning of accreditation does not
guarantee indefinite accredited status. A renewal of accreditation of postsecondary schools or
programs takes place on a cycle that may range from every few years to as many as 10 years.14
Funding
Accrediting agencies are funded primarily by annual dues from schools and programs that are
accredited and fees that schools and programs pay for accreditation reviews. In some cases, an
accrediting agency may receive financial assistance from sponsoring organizations. Accrediting
agencies may also derive funds from a variety of other sources such as from government or
private foundations to support special initiatives and from the hosting of conferences and
meetings.15
Evaluations and Review Procedures
To gain or renew accreditation, an institution or program must be evaluated through a number of
steps outlined by the accrediting agency. These procedures are guided, in part by the federal
requirements discussed later in this report. However, the specific procedures for evaluation
reviews adopted by accrediting agencies may vary among them. The following description of the
evaluation process is intended to provide a general overview of how institutions and programs are
evaluated for initial or renewal of accreditation status.16
The process typically begins with institutional or programmatic self-study. This self-study is
designed to be an examination of whether an institution’s or program’s operation and
performance meet the basic requirements or standards of the accrediting agency (which differ
somewhat from organization to organization).17 The self-study typically involves the preparation
of detailed written reports showing how the institution or program determines whether it meets or
exceeds the agency’s standards, as well as how it plans to improve in the future.

14 CHEA, Overview of Accreditation, p. 4. Regulations do not specify a precise timeframe in which an accrediting
agency must reevaluate schools or programs; rather, they require that agencies reevaluate schools or programs at
“regularly established intervals.” 34 C.F.R. §602.19(a).
15 CHEA, Overview of Accreditation, p. 4.
16 Information in this section was drawn from CHEA, Overview of Accreditation and U.S. Department of Education,
“Accreditation in the United States: Primary Accrediting Activities,” https://www2.ed.gov/admins/finaid/accred/
accreditation_pg2.html#U.S., accessed March 29, 2024.
17 In addition, some accrediting agency standards may differ based on institution or educational programs. HEA
§496(a)(5)(A).
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The next phase in the evaluation process typically involves a peer review and site visit at the
institution. An outside visiting team primarily composed of higher education faculty and
administrators, but that also include practitioners in specific fields and members of the public
(e.g., nonacademics who have an interest in higher education),18 conducts the peer review. The
visiting team analyzes the self-study and conducts a site visit to determine whether the standards
of the accrediting agency are being met; the self-study analysis provides the basis for scrutiny by
the team during the visit to the campus. During the visit, team members have an opportunity to
talk to faculty, students, staff, and administrators about issues and questions arising from the self-
study. The team usually conducts an exit interview with the president or dean to discuss issues
that have surfaced during the review. All team members are volunteers and generally are not
compensated.
Following the visit to an institution or program, the team typically prepares a comprehensive
accreditation report that includes judgments about the institution’s or program’s strengths,
weaknesses, and potential for improvement. Staff of the accrediting agency may meet with the
visiting review team to discuss the draft report. The final report is submitted to the accrediting
agency, with recommendations about which actions should be taken.19
Based on the results of the self-assessment, peer review, and site visit, the decision-making body
of an accrediting agency (often referred to as a commission) issues a decision on the institution’s
or program’s accreditation status. Decision-making actions include awarding or denying
accreditation or preaccreditation20 to a new institution or program; renewing or terminating
accreditation for an existing institution or program; or taking an intermediate action for an
existing institution or program, such as placing an institution or program on provisional or
probationary status. Accrediting agencies typically have an appeals process and some
requirements are determined by federal law.21
Accrediting agencies also monitor institutions and programs between full accreditation reviews
and may require annual reporting, interim reviews, or reviews of any substantive changes.22
Annual reporting could include financial statements and updated curricular or planning
information. Interim reviews are required when issues are left unresolved from a comprehensive
evaluation. Review of substantive changes could include reviewing an institution’s change of
control (e.g., conversion from proprietary to private nonprofit), the addition of educational
programs that are a significant departure from existing offerings (e.g., the offering of distance

18 Eligibility criteria for visiting team members vary by accrediting agency. Team members may, but are not
necessarily required to, have an employment relationship with institutions or other entities affiliated with the
accrediting agency. See, for example, See, for example, Higher Learning Commission, “Eligibility Criteria and
Selection,” PEER.A.10.010, June 2021, https://www.hlcommission.org/Policies/eligibility-criteria-and-selection.html;
Council on Occupational Education, “Policies and Rules of the Commission,” 2024 Edition, pp. 28-29,
https://council.org/handbooks/.
19 34 C.F.R. §602.17(e) and (f).
20 Preaccreditation is “the status of accreditation and public recognition that a … recognized accrediting agency grants
to an institution or program for a limited period of time that signifies the agency has determined that the institution or
program is progressing toward full accreditation and is likely to attain full accreditation before the expiration of that
limited period of time.” 34 C.F.R. § 600.2. Preaccreditation status from an ED-recognized accrediting agency enables
public and private nonprofit institutions of higher education and postsecondary vocational institutions to participate in
the HEA Title IV federal student aid programs. HEA §§101(a)(5) and 102(c)(1)(B).
21 Information on federal due process requirements is presented later in this report.
22 See, for example, Higher Learning Commission, “Routing Monitoring and Data Collection,” INST.F.10.010,
February 2024, https://www.hlcommission.org/Policies/routine-monitoring.html?highlight=
WyJhbm51YWwiLCJyZXBvcnQiLCJhbm51YWwgcmVwb3J0Il0=.
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education23 when the institution did not previously offer distance education), or the addition of a
new location or branch campus.
The Federal Role in Accreditation
As previously described, the United States does not have a centralized authority exercising
singular national control over postsecondary educational institutions. For purposes of
participation in a variety of federal programs, including HEA Title IV federal student aid
programs, the federal government has come to rely on accrediting agencies to help ensure a level
of acceptable quality across eligible educational programs and institutions of higher education. To
ensure that an accrediting agency is “a reliable authority as to the quality of education or training
offered,”24 ED administers a recognition process through which an accrediting agency must
demonstrate it meets a variety of statutory and regulatory conditions. Accreditation by an ED-
recognized accrediting agency is often a criterion postsecondary schools and programs must meet
to participate in an array of federal programs. Without such accreditation, postsecondary schools
and programs may lose access to significant amounts of federal funds; thus, achieving and
maintaining an accredited status has become almost essential for the financial survival of some, if
not most, institutions and programs.
Evolution of the Federal Role in Accreditation
The federal role in accreditation has evolved considerably over the years. A brief history of this
role follows for context.
Early Federal Recognition
Federal recognition of accrediting agencies was initiated in 1952, shortly after the passage of the
Veterans’ Readjustment Assistance Act of 1952 (the Korean GI Bill; P.L. 82-550), as one of the
mechanisms to help assess higher education quality and link it to determining which institutions
would qualify to receive federal aid under the GI Bill. A recognition process was established in
the (then) Office of the U.S. Commissioner of Education to produce a list of federally recognized
accrediting agencies and associations.25
The National Defense Education Act of 1958 (NDEA; P.L. 85-864) also addressed the federal role
in accreditation of higher education. In defining the term “institution of higher education” for the
purposes of identifying institutions eligible to receive federal funds to assist in making low-
interest loans to postsecondary students in need,26 the NDEA maintained the criterion that
institutions be accredited by an agency or association recognized by the U.S. Commissioner of
Education.

23 For HEA purposes, distance education is defined as education that uses one or more specified technologies (e.g., the
internet, audio conferencing) “(i) to deliver instruction to students who are separated from the instructor; (ii) and to
support regular and substantive interaction between the students and the instructor, synchronously or asynchronously.”
HEA §103(7).
24 HEA §496(a).
25 For an in-depth look at how the federal role in accreditation evolved, see John R. Proffit, “The Federal Connection
for Accreditation,” JSTOR. The Journal of Higher Education, 1979, http://www.jstor.org/stable/1980935?seq=1.
26 This program was known as the National Defense Student Loan Program (NDSL), the precursor to the Federal
Perkins Loan program.
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Higher Education Act of 1965
In 1965, the importance of accrediting agencies was augmented further with the enactment of the
Higher Education Act (HEA; P.L. 89-329). Title IV of the HEA created new federal student aid
programs for postsecondary students, regardless of their veteran status (many of which were the
predecessors to the currently available Title IV student aid programs). Only institutions accredited
by agencies recognized by the (then) Office of the U.S. Commissioner of Education were eligible
to receive these funds.
Expansion of Federal Recognition Requirements
Between the 1965 enactment of the HEA and its reauthorization in 1992, accrediting agencies
were required to be recognized by ED for Title IV purposes, but the HEA specified few, if any,
criteria for ED recognition.
Leading up to the 1992 reauthorization of the HEA, concerns about fraud and abuse in the
accreditation process by the proprietary school sector were evident.27 Rather than singling out the
proprietary institutions for special oversight, Congress opted to strengthen the criteria for ED
recognition of accrediting agencies of all types of institutions.28 Thus, HEA Section 496 was
added in the Higher Education Amendments of 1992 (P.L. 102-325) in an effort to require
accrediting agencies to exercise genuine oversight of the schools they accredited. Section 496 of
the HEA sets forth the standards and criteria accrediting agencies must meet to be recognized by
ED as reliable authorities as to the quality of education offered at IHEs. The new Section 496
described the types of organizations eligible for ED recognition (e.g., state, regional, or national
agencies with voluntary memberships). It also detailed the types of school assessment
standards—such as recruitment and admissions practices; program length; and “success with
respect to student achievement in relation to [the school’s] mission,” which could include
consideration of course completion, state licensing examinations, and job placement rates—that
agencies were to apply consistently to all IHEs.29
The 1998 reauthorization (the Higher Education Amendments of 1998; P.L. 105-244) saw
changes in the scope of the criteria for ED recognition of accrediting agencies, especially in
regard to changing education delivery methods and distance education programs. Specifically, the
act permitted the Secretary of Education (Secretary) to include within an accrediting agency’s
scope of recognition the ability to assess an IHE’s distance education programs. In doing so,
Congress sought to ensure that the federal government was providing Title IV support only to
quality programs in the rapidly growing area of distance education.30

27 See, for example, U.S. Congress, Senate Committee on Governmental Affairs, Permanent Subcommittee on
Investigations, Abuses in Federal Student Aid Programs, 102nd Cong., 1st sess., May 17, 1991, 102-58 (Washington,
DC: GPO, 1991), pp. 16-21.
28 For additional information on the Higher Education Amendments of 1992 as they relate to institutional eligibility, see
out-of-print CRS Report 93-861, Institutional Eligibility: The Higher Education Amendments of 1992, by Margot A.
Schenet, available to congressional clients upon request.
29 Federal regulations related to ED recognition of accrediting agencies were in effect prior to 1992. The regulations
published before the 1992 amendments contained many of the same concepts that were eventually codified in the 1992
amendments (e.g., evaluation of school assessment standards, including student achievement, and applying review
criteria consistently to all IHEs). See U.S. Department of Education, “Secretary’s Procedures and Criteria for
Recognition of Accrediting Agencies,” 53 Federal Register 25088, July 1, 1988.
30 See, for example, U.S. Congress, House Committee on Education and the Workforce, Higher Education
Amendments of 1998, report to accompany H.R. 6, 105th Cong., April 17, 1998, H.Rept. 105-481 (Washington, DC:
GPO, 1998), p. 148.
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Congress provided a host of additional criteria for ED recognition of accrediting agencies in the
Higher Education Opportunity Act of 2008 (HEOA; P.L. 110-315), which reauthorized the HEA
in 2008. The 2008 additions included provisions relating to how accrediting agencies were to
review distance education programs; transparency of agency policies and decision-making
processes; due process requirements for IHEs subject to an adverse agency action;31 and various
other standards related to IHE operations, including ensuring that IHEs make transfer-of-credit
policies publicly available and submit teach-out plans32 to accrediting agencies in specified
circumstances. 33
Recent Regulations
Since the HEOA, ED has updated its regulations relating to accrediting agencies multiple times.
Most recently, in October 2022, ED issued a Final Rule specifying how accrediting agencies are
to evaluate prison education programs (PEPs) offered by IHEs to enable PEPs to participate in the
Pell Grant program.34 Additionally, in October 2023, ED updated regulations relating to its
certification procedures for IHEs to participate in the Title IV programs. Specifically, effective
July 1, 2024, IHEs must determine, if applicable, that programs that prepare students for
occupations requiring programmatic accreditation or state licensure meet those requirements for
each state
1. in which an IHE is located,
2. in which a student is located35 for students enrolled by an IHE in distance
education or correspondence courses, and
3. for which a student who enrolls in a program on or after July 1, 2024, attests that
they intend to seek employment.36
While these changes do not directly amend regulations specific to accreditation, they effectively
require IHEs participating in HEA Title IV federal student aid programs to hold applicable
programmatic accreditation, if an individual is required by state law or a federal agency to have
completed a program with such accreditation to enter the intended occupation.

31 An adverse action is “the denial, withdrawal, suspension, revocation, or termination of accreditation or
preaccreditation, or any comparable accrediting action an agency may take against an institution or program.” 34
C.F.R. §602.3(b).
32 A teach-out plan is a written plan developed by an institution that provides for the equitable treatment of its own
students if it, or one of its locations that provides 100% of at least one program, ceases to operate before all students
have completed their program of study. A teach-out plan may include, if required by the institution’s accrediting
agency, a teach-out agreement between institutions. HEA §487(f)(2).
33 For additional information on teach-out plans and teach-out agreements, see CRS Report R44737, The Closure of
Institutions of Higher Education: Student Options, Borrower Relief, and Other Implications.
34 U.S. Department of Education, “Pell Grants for Prison Education Programs; Determining the Amount of Federal
Education Assistance Funds Received by Institutions of Higher Education (90/10); Change in Ownership and Change
in Control,” 87 Federal Register 65426, October 28, 2022.
35 A student’s location is determined at the time of their initial enrollment in a program and, if applicable, upon the
IHE’s formal receipt of information from the student that the student’s location has changed. 34 C.F.R. §600.9(c)(2).
36 IHEs must also determine that they satisfy applicable education requirements for professional licensure or
certification requirements in each state for the same groups of students. U.S. Department of Education, “Financial
Responsibility, Administrative Capability, Certification Procedures, Ability to Benefit (ATB),” 88 Federal Register
74568, 74697, October 31, 2023.
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Role of the U.S. Department of Education in Accreditation
ED does not accredit IHEs or programs of higher education. Its primary role is to recognize,
through the process and conditions set forth in the HEA and accompanying regulations, an
accrediting agency as “a reliable authority as to the quality of education or training offered” at
IHEs for the purposes of Title IV funding and other federal programs.37 As part of the recognition
process, the accrediting agency must show that it is “effective in its performance” with respect to
the criteria established in the law and regulations. If, at any time, ED determines the agency has
become ineffective in its performance, it may revoke recognition.
The Accreditation Group38 was established within ED’s Office of Postsecondary Education to
help facilitate accreditation matters. In effect, the Accreditation Group carries out many of the
statutory and regulatory requirements of ED as they relate to the approval of accrediting agencies.
Two of its primary functions include “continuously review[] standards, policies, procedures, and
issues in the area of [ED’s] accreditation responsibilities” and “administer[] the process by which
accrediting agencies and state approval agencies secure initial and renewed recognition by the
Secretary of Education.”39
Recognized Accrediting Agencies
ED recognizes agencies that accredit all types of institutions (public, private nonprofit, and
proprietary) and a variety of educational programs. They include agencies that accredit multi-
disciplinary universities, as well as those that accredit smaller, specialized institutions or a
specific program within an institution.40 ED publishes lists of recognized accrediting agencies in
certain categories that may be used by institutions to seek accreditation or by students to ensure a
reasonable assurance of program quality and acceptance of diplomas and degrees by employers.
A primary type of accrediting agency that ED recognizes are those that enable institutions of
higher education to participate in the Title IV programs. As of March 2024, ED recognizes 37
accrediting agencies for Title IV purposes. These agencies include institutional and programmatic
accrediting agencies.41 ED also recognizes accrediting agencies that enable postsecondary schools
and programs to participate in other federal programs. As of March 2024, ED recognizes 18

37 ED also recognizes state agencies for the approval of public postsecondary vocational education and nurse education.
The criteria and procedures used by the Secretary in designating a state agency as a reliable authority concerning the
quality of public postsecondary vocational education in a state are contained in Part 603 of Title 34 of the Code of
Federal Regulations (C.F.R.). The criteria and procedures used by the Secretary in designating a state agency as a
reliable authority concerning the quality of training offered by schools of nursing in a state are contained in regulations
published in the January 16, 1969 Federal Register. For more information, see U.S. Department of Education,
“Accreditation in the United States, Criteria and Procedures for Recognition of State Agencies in Nurse Education,”
https://www2.ed.gov/admins/finaid/accred/accreditation_pg9.html#CriteriaforNurseEducation.
38 Formerly known as the Accrediting Agency Evaluation Unit.
39 U.S. Department of Education, “Accreditation in the United States, History and Context of Accreditation in the
United States,” https://www2.ed.gov/admins/finaid/accred/accreditation_pg2.html, accessed April 1, 2024.
40 Generally, institutions are accredited by only one accrediting agency or association. Dually accredited institutions
must choose one accrediting agency for the purposes of Title IV eligibility.
41 ED places some conditions and limitations on the types of institutions that may be accredited for Title IV purposes
by programmatic accrediting agencies. For a list of the 37 accrediting agencies and any conditions that may apply, see
U.S. Department of Education, “Accreditation in the United States, Institutional Accrediting Agencies,”
https://www2.ed.gov/admins/finaid/accred/accreditation_pg3.html#RegionalInstitutional.
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accrediting agencies whose conferral of accreditation enables postsecondary schools to participate
in federal programs other than HEA Title IV programs.42
Current Recognition Requirements
Currently, many of the HEA ED-recognition requirements put into place since 1992 remain. An
ED-recognized accrediting agency must meet general organizational requirements, demonstrate
that it has accreditation standards that are “sufficiently rigorous” to ensure that it is a “reliable
authority regarding the quality of education” provided by the IHEs and programs it accredits,43
and maintain required operating and due process procedures.
General Organizational Requirements
According to Section 496 of the HEA, an accrediting agency must be a state, regional, or national
agency or association that demonstrates the ability and expertise to serve as an accrediting
agency. These agencies must then meet one of the following specific criteria, the application of
which largely depends on whether obtaining accreditation from the agency enables an IHE or
program to participate in HEA programs generally, the HEA Title IV federal student aid programs
specifically, or other federal programs:
1. For the purpose of determining eligibility for HEA programs, including the Title
IV student aid programs, the agency must have a voluntary membership of
institutions and have as a principal purpose the accrediting of institutions.
2. For the purpose of determining single-purpose freestanding institutions’44
eligibility for Title IV HEA programs, the agency must either have a voluntary
membership of individuals participating in a profession, or have as its principal
purpose the accrediting of programs within institutions that are accredited by
another ED-recognized agency.
3. For purposes of determining eligibility for HEA and non-HEA federal programs,
the agency must be a state agency approved by the Secretary as an accrediting
agency on or before October 1, 1991, and have as a principal purpose the
accrediting of institutions, education program, or both.45
4. For the purposes of determining eligibility for non-HEA federal programs, the
agency must have a voluntary membership and have as its principal purpose the
accrediting of institutions or programs.

42 U.S. Department of Education, “Accreditation in the United States, Programmatic Accrediting Agencies,”
https://www2.ed.gov/admins/finaid/accred/accreditation_pg4.html#National_Institutional, accessed April 2, 2024.
43 34 C.F.R. §602.16(a).
44 Single-purpose freestanding institution refers to a postsecondary school that offers a single educational program or
course of study. For example, a postsecondary school that only offers programs in legal education that lead to a
professional degree in law may be considered a single-purpose freestanding institution.
45 HEA §496(a)(2)(B); 34 C.F.R. §602.14(a)(1). The New York State Board of Regents and Commissioner of
Education is the only such state agency in existence.
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Accrediting agencies or associations meeting the first or second criterion must also be
administratively and financially separate and independent46 from any associated or affiliated trade
organization or membership organization.47
Accreditation Standards
Regardless of the type of accrediting agency, the organization must consistently apply and
enforce standards that ensure that the education programs, training, or courses of study offered by
an IHE are of sufficient quality to meet the stated objectives for which they are offered.48 In
general, the standards used by the accrediting agency must assess student achievement49 in
relation to the institution’s mission, including, as applicable, course completion, passage of state
licensing examinations, and job placement rates.50 In practice, institutions and programs often set
their own standards for student learning outcomes, depending on a variety of factors such as the
level of education offered and the skills and competencies required of its graduates in different
fields, and that may be guided by accrediting agency policies. Accrediting agencies then evaluate
the appropriateness of those standards and whether institutions and programs use information
gained from student learning outcomes to improve student learning.51 In some instances,
accrediting agencies may establish specific student achievement measures (e.g., graduation rates)
and benchmarks that schools and programs must meet.52
In addition, an accrediting agency must consider the institution’s or program’s curricula, faculty,
facilities, fiscal and administrative capacity, 53 student support services, recruitment and
admissions practices, measures of program length,54 objectives of the credentials offered, and
student complaints received directly by the agency or those that are available to the agency. The
institution’s or program’s record of compliance with the institutional requirements of Title IV

46 Section 496(b) defines “separate and independent” to mean that (1) members of the postsecondary education
governing body of the accrediting agency are not selected or elected by the board or chief executive officer of any
related, associated, or affiliated trade associations or membership organizations; (2) the board has at least one public
member for every six board members; (3) dues paid to the accrediting agency are separate payments from any dues
paid to any related, associated, or affiliated trade associations or membership organizations; and (4) the accrediting
agency develops and determines its own budget without consulting any other entity or organization.
47 For accrediting agencies meeting the second criterion and that were recognized by the Secretary on or before October
1, 1991, the Secretary may waive the requirement that the agency be administratively and financially separate and
independent, if it can demonstrate that existing relationships with associated or affiliated trade organizations or
membership organizations have not compromised the independence of the accreditation process. HEA §496(a)(3)(C).
48 The standards must respect the stated mission, including religious missions, of the institution. HEA §496(a)(4)(A).
49 Section 496(a)(5)(A) of the HEA explicitly states that success with respect to student achievement may include
different standards for different institutions or programs, as established by the institution.
50 This student achievement criterion is not required for ED recognition of accrediting agencies for the purposes of
participation in non-HEA programs administered by ED and programs administered by other federal agencies. HEA
§496(a)(5).
51 See, Council for Higher Education Accreditation, The Value of Accreditation, June 2010, p. 5. See also, for example,
Higher Learning Commission, “Criteria for Accreditation” CCRT.B.10.010, Criterion 4, Revised September 1, 2020,
https://www.hlcommission.org/Policies/criteria-and-core-components.html.
52 See, for example, The Accrediting Commission of Career Schools and Colleges, “Standards of Accreditation,” July
1, 2023, p. 132.
53 As part of an accrediting agency’s administrative and fiscal responsibilities under federal laws and regulations, its
accreditation teams must include competent and knowledgeable individuals, qualified by education and experience in
their own right and trained by the agency on their responsibilities, as appropriate for their roles, regarding the agency’s
standards, policies, and procedures to conduct on-site evaluations.
54 The measures of program length criterion is not required for ED recognition of accrediting agencies for the purposes
of participation in non-HEA programs administered by ED and programs administered by other federal agencies. HEA
§496(a)(5).
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must also be examined, as applicable, with respect to the most recent student loan default rate
data, the results of financial or compliance audits, program reviews, and other information
provided to the agency by ED.55
Required Operating and Due Process Procedures
ED-recognized accrediting agencies must maintain and apply a variety of required operating and
due process procedures. With respect to operations procedures, all ED-recognized accrediting
agencies must, among other requirements,56
• make publicly available information on the standards and procedures used to
determine whether to grant accreditation;
• disclose publicly whether an institution is being considered for accreditation or
renewal of accreditation;
• make publicly available a list of institutions and programs that the agency
currently accredits;
• notify ED, state licensing or authorizing agencies, other appropriate accrediting
agencies, and the public of a decision to award initial or to renew an IHE’s or
programs’ accreditation or preaccreditation;
• notify the aforementioned parties of an initiated adverse action,57 or final
decision of a probation or adverse action, against an IHE or program;
• provide the aforementioned parties with a statement summarizing the reasons for
the adverse action, along with evidence that the affected institution has been
offered an opportunity to provide official comment;
• require the IHE or program to disclose an accrediting agency’s final decision to
take an adverse action to current and prospective students; and
• review in a timely manner complaints an agency receives against an accredited
institution or program that are related to the agency’s standards or procedures.
For purposes of determining eligibility for HEA Title IV programs, accrediting agencies must
meet additional operating procedures requirements,58 including
• reviewing newly established branch campuses of any of its accredited
institutions;
• performing regular onsite inspections that focus on educational quality and
program effectiveness;59

55 This record of HEA Title IV compliance criterion is not required for ED recognition of accrediting agencies for the
purposes of participate in non-HEA programs administered by ED and programs administered by other federal
agencies. HEA §496(a)(5).
56 HEA §496(a); 34 C.F.R. §§602.23 and 602.26.
57 An adverse action is “the denial, withdrawal, suspension, revocation, or termination of accreditation or
preaccreditation, or any comparable accrediting action an agency may take against an institution or program.” 34
C.F.R. §602.3(b).
58 HEA §496(c) and 34 C.F.R. §602.24.
59 Prior to the 1998 HEA amendments, accrediting agencies were required to make unannounced visits to institutions.
Unannounced visits are no longer required but are permitted in Section 496(c)(1) of the HEA.
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• requiring institutions to submit a teach-out plan in certain circumstances60; and
• confirming that the institutions or programs they accredit have publicly disclosed
transfer of credit policies and that such institutions or programs make public the
criteria by which they make a determination with regard to accepting credits from
another institution.
Under Section 496(a)(6) of the HEA, accrediting agencies recognized by ED must meet certain
requirements with respect to due process. That is, an accrediting agency must implement specific
procedures to resolve disputes between the accrediting agency and any institution or program that
is subject to the accreditation process. Under current law, accrediting agencies must provide an
IHE or program with, among other procedures, adequate written specification of accreditation
requirements and of any deficiencies identified at an IHE or program being examined, and
sufficient opportunity to provide a written response to any deficiencies identified before an
adverse action is taken, as well as the right to appeal any adverse action against it.
Distance Education
Distance education programs61 must be evaluated by an accrediting agency recognized by ED as
having the evaluation of distance education programs within its scope of recognition.62
Accrediting agencies that accredit distance education programs are not required to have separate
standards, procedures, or policies for the evaluation of distance education. They are, however,
required to mandate that IHEs have processes in place to verify that a student who registers in a
course offered via distance education is the same student who participates in the course. Such
agencies must also use processes that protect student privacy and notify students of any additional
costs associated with such verifications.63
Process for Recognition of Accrediting Agencies
Like the standards and criteria an accrediting agency must meet to be recognized by ED, the
process for ED recognition was not established in the HEA until the 1992 reauthorization. At that
time, Congress prescribed the major components of the recognition process, which largely have
gone unchanged since that time. The HEA contains broad requirements for ED-recognition
processes and then specifies that ED shall provide in regulations procedures for ED’s recognition
of accrediting agencies.64 The HEA expressly states that nothing in the HEA “shall be construed

60 Instances in which an institution is required to submit a teach-out plan include, but are not limited to, (1) ED
notifying the accrediting agency of any emergency or initiating a limitation, suspension, or termination action against
the institution; (2) the accrediting agency acting to withdraw, terminate, or suspend the accreditation of the institution;
and (3) the institution notifying the accrediting agency that the institution intends to cease operations. For a full list of
when an IHE may be required to submit a teach-out plan to its accrediting agency, see 34 C.F.R. §602.24(c).
61 On July 1, 2010, regulations issued by ED came into effect, distinguishing distance education from correspondence
education. In general, correspondence education is provided through one or more home study courses by an institution
to students who are separated from the instructor whereby interaction between the instructor and student is limited, not
regular and substantive, and is primarily initiated by the student. Accrediting agencies are required to consider
correspondence education as separate and distinct from distance education as it relates to accreditation, pre-
accreditation, and expansion of scope.
62 HEA §481(b)(3).
63 HEA §496(a)(4)(B); 34 C.F.R. §602.17(g) and (h).
64 HEA §496(l), (n), and (o).
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to permit the Secretary to establish” recognition criteria that are not required by the HEA.65 Once
granted, recognition is established for up to five years.66
The recognition process generally begins with an accrediting agency submitting an application for
initial or renewal of recognition.67 ED then solicits comments from the public regarding the
accrediting agency’s compliance with recognition criteria.68 Staff in ED’s Accreditation Group
review the application and public comments to determine whether an accrediting agency meets
the recognition criteria. The review also includes announced or unannounced site visits to the
accrediting agency or institutions or programs that the agency accredits or preaccredits and a
review of complaints or legal actions against IHEs or programs accredited by the accrediting
agency.69 ED staff then prepare a draft analysis of their findings and permit the accrediting agency
to respond to the findings.70 A final analysis, including a recommended recognition action,71 is
then drafted by ED staff and submitted to the National Advisory Committee for Institutional
Quality and Integrity (NACIQI).72
Next, NACIQI reviews the materials provided to it by ED staff during a public meeting and
recommends a recognition action to ED.73 A senior department official (SDO) then makes a
recognition decision based on ED staff and NACIQI recommendations, written comments and
responses submitted to it by the accrediting agency, and relevant new documentation.74 An
accrediting agency may appeal the SDO’s decision to the Secretary of Education,75 and the
Secretary’s final decision may be contested in federal court.76
National Advisory Committee on Institutional Quality and
Integrity (NACIQI)
NACIQI advises the Secretary on matters related to accreditation, including decisions to
recognize accrediting agencies. Section 114 of the HEA provides for the establishment of

65 HEA §496(g).
66 HEA §496(d).
67 34 C.F.R. §602.31. Processes for additional action, such as an accrediting agency’s request for an expansion of scope
generally follow the same procedures described herein. Slightly different procedures apply when ED reviews agencies
during a period of recognition. See 34 C.F.R. §602.33.
68 34 C.F.R. §602.32(c).
69 ED has stated that complaints and legal actions against IHEs or programs accredited by an accreditation agency “may
be considered but are not necessarily determinative of compliance.” Department of Education, “Student Assistance
General Provisions, The Secretary’s Recognition of Accrediting Agencies, The Secretary’s Recognition Procedures for
State Agencies,” 84 Federal Register 58834, November 1, 2019.
70 34 C.F.R. §602.32(h).
71 Recommended actions may include, for example, a recommendation to fully approve/renew the agency’s
recognition, to approve/renew its recognition with compliance reporting or other monitoring requirements, or limit or
suspend recognition.
72 34 C.F.R. §602.32(h)(5). Additional information about NACIQI is presented later in this report.
73 34 C.F.R. §602.34(e).
74 34 C.F.R. §602.36.
75 34 C.F.R. §602.37.
76 34 C.F.R. §602.38.
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NACIQI, 77 and delineates the qualifications for membership, meeting procedures, and other
reporting requirements.78
Functions
NACIQI advises the Secretary on matters related to accreditation and to the eligibility and
certification process for IHEs. Certification is the process through which ED determines whether
an IHE meets HEA Title IV eligibility requirements. Specifically, NACIQI provides
recommendations to the Secretary regarding79
• the establishment and enforcement of criteria for recognition of accrediting
agencies or associations;
• the recognition of specific accrediting agencies;
• the preparation and publication of the list of recognized accrediting agencies;
• the eligibility and certification process for IHEs under Title IV of the HEA; and
• the relationship between (1) accreditation of IHEs and the certification and
eligibility of such institutions, and (2) state licensing responsibilities with respect
to such institutions.
NACIQI may also advise the Secretary on other matters relating to accreditation and institutional
eligibility that the Secretary may prescribe in regulation.
The HEA requires NACIQI to meet not less than twice a year to review applications for
recognition submitted by accrediting agencies.80
Membership
The HEA specifies the composition and terms of NACIQI membership. NACIQI is an 18-
member committee, with six appointments made by the Speaker of the U.S. House of
Representatives,81 six appointments made by the President pro tempore of the U.S. Senate,82 and
six appointments made by the Secretary. Members are to be appointed (among other criteria)
from among individuals who are representatives of, or knowledgeable concerning, postsecondary
education and training, and represent all sectors and types of IHEs (e.g., public, private nonprofit,
proprietary).83 Appointees serve staggered six-year terms.84

77 The HEA, as amended by the Higher Education Opportunity Act (P.L. 110-315)—the last comprehensive
reauthorization of the HEA—authorized NACIQI through September 30, 2014. Since then, NACIQI’s authorization
has been extended numerous times, including most recently through September 30, 2024, under the Further
Consolidated Appropriations Act, 2024 (P.L. 118-47).
78 NACIQI was originally established in the HEA under the 1992 Amendments to the Higher Education Act (P.L. 102-
325). Prior to NACIQI, the HEA authorized the National Advisory Committee on Accreditation and Institutional
Eligibility, which assisted the Secretary with recognition of accrediting agencies. NACIQI replaced this committee.
79 HEA §114(c).
80 HEA §114(d)(1).
81 Section 114(b)(1)(B) of the HEA specifies that of the six appointments made by the Speaker of the House of
Representatives, three will be made at the recommendation of the majority leader of the House of Representatives and
three will be made at the recommendation of the minority leader of the House of Representatives.
82 Section 114(b)(1)(C) of the HEA specifies that of the six appointments made by the President pro tempore of the
Senate, three will be made at the recommendation of the majority leader of the Senate and three will be made at the
recommendation of the minority leader of the Senate.
83 HEA §114(b)(2).
84 HEA §114(b)(3).
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Author Information

Alexandra Hegji

Analyst in Social Policy

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