In the Room

In the last installment of In the Room, I discussed the work on a Credit Transfer Consortium: why the issue matters, what the draft framework looks like, and where our members opposed it. This time, I want to take you into a room that is doing something more fundamental: rewriting the Principles of Accreditation themselves. The Consortium is just one new initiative sitting on top of our existing standards. This is the foundation those standards rest upon, and right now, we are in the process of rebuilding it from the ground up. Let’s start with why.

The Issue

When I speak with registrars, accreditation liaisons, provosts, or presidents and ask what frustrates them most about the current Principles, I tend to hear three main complaints:
1. The standards leave little room for an institution to find its own path to good outcomes.
2. They fail to meaningfully distinguish between a two-year technical college and a research university awarding doctorates.
3. They create a large amount of documentation that measures whether an institution can prove compliance rather than whether it is doing good work.

None of this is a criticism of the creators of the current Principles; they were designed for a different regulatory era, and like any long-standing document, they have accumulated requirements that were added over time but rarely removed. I would add that I do not necessarily agree with these complaints, but they exist because perception is reality. Higher education has evolved faster than the standards have. This gap highlights the need for a complete, ground-up revision rather than just more marginal edits.

The Discussion

We built the rewrite around three core values: enable innovation, honor institutional mission diversity, and reduce administrative burden. Every draft standard is tested against four guiding questions: does it genuinely promote student achievement, does it advance quality and continuous improvement while maintaining transparency, does it improve transparency and accountability while reducing unnecessary burden, and does it keep the focus on outcomes and results rather than process for its own sake. In practice that means standards are being worded to leave more room for institutions to make their own internal decisions, on the premise that the best outcomes usually come from institutions that have the freedom to find their own path to excellence, and standards are being approached from a more contextual, almost storytelling, posture rather than a checklist posture. In other words, we are committing to outcomes that reflect the missions of our institutions and recognizing that genuine differentiation must be considered during the writing of standards and not after.

The writing process itself was deliberately unconventional. The committee did not start with the current Principles or the current Resource Manual open on the table. It started by asking what actually matters for quality, moved to a review of what federal requirements demand regardless of what we might prefer, and only then circled back to ask what we had overlooked.

We put the draft in front of our members and the public this spring, and the response told us the rewrite is on the right track but not finished. We received 473 total responses, 385 of them fully completed and 88 partial, split between 182 responses to an institutional version of the survey and 291 to a public version. We deliberately did not flag which provisions were federally required and which were our own choices, because we wanted honest reaction to the standards as written, not reaction filtered through what people assumed they had to accept. The overall tone trended positive, but two tensions showed up consistently: a trade-off between the number of standards and how they are structured, and a trade-off between how clearly an expectation reads and how much flexibility institutions have in interpreting and applying it. The most specific feedback clustered around five areas: how the standards differentiate by institutional mission, where the line falls between a standard and its implementation, the role of faculty, the role of libraries, and academic freedom. The committee is now working through revisions that respond to that feedback, informed (and trying to anticipate) as well by the new Accreditation, Innovation, and Modernization (AIM) regulatory language I have been tracking with you.

As we move into the next draft, let me give you a little advice. First, verbs matter, because the difference between an institution ‘shall’ do something and an institution ‘should’ do something is the difference between a mandate and a value. As with assessment language, verbs carry meaning showing depth. Verbs like “list” or “count” are what I would consider compliance verbs. In assessment language, they are low level verbs. Verbs like “demonstrate” are higher level verbs indicating a more active outcome.

Second, beware of crosswalks, because mapping every new standard back to an old one is how you accidentally rebuild the thing you were trying to replace. It is also based primarily in looking for terms or content rather than changes in intent or philosophy. It gives people and institutions permission to do what they have always done rather than looking at new and more effective means to show a commitment to quality and improvement.

Finally, keep asking whether a given requirement is about compliance or about improvement, because those are not the same question and they do not belong in the same sentence.

Progress Update

That work has produced a set of concrete proposals since the draft went out. The committee has recommended discontinuing the CR standards designation, discontinuing differentiated reaffirmations for institutions that previously responded to a smaller subset of standards, introducing attestations for a number of standards in place of extensive documentation, and discontinuing the QEP. It has also proposed shortening the number of years between reaffirmations, eliminating the fifth-year review, and bringing back non-binding on-site committee suggestions alongside formal compliance recommendations. I am particularly excited about the last recommendation. The Commission, and our institutions, should have a focus on holding compliance of course, but we can also identify areas where institutions are excelling. We should acknowledge where quality exists as well as areas of improvement.

On timing, the current discussion phases institutions in by reaffirmation class (date approved by The Commission’s Board of Trustees): the Class of 2027 stays on the current Principles, the Class of 2028 gets a choice with a Fall 2027 reaffirmation visit, and the Class of 2029 moves fully to the new standards. I realize this creates tons of questions, but we do not have all the answers as yet. We are working through the dynamics of these changes, so more to come on that. We anticipate a full package of both the standards and process changes by the Board meeting with the Resource Manual followed closely.

We walked through all of this with attendees at the Summer Institute in July, and the reminder I gave the room there is worth repeating here: this is still a draft, and there is more work to do. Writing the standards turns out to be the easier half of this project. Implementation is the real work ahead of us: a full revision of the Resource Manual, a reconfiguration of the review cycle and its processes, and retraining every evaluator so that on-site teams apply the new standards, and the new philosophy behind them, consistently across the membership. So, we are not simply looking at a change of standards but a change of approach.

The Pruitt Perspective

Before I get into my perspective on this work so far, I want to give a heartfelt thank you to the incredible individuals who have worked so hard on this first draft. The group made up of peers from across our membership comprising of presidents, provosts, and liaisons have worked very hard to meet some pretty tough deadlines. Thank you for your work so far and the work yet to come.

Underneath the guiding questions and the feedback tallies, this rewrite comes down to one trade: we are asking institutions to accept less prescriptive language in exchange for more responsibility for demonstrating quality in their own words based on their own missions. That is a harder ask than it sounds. A detailed standard tells an institution exactly what to produce. A contextual standard asks an institution to make an argument, and arguments can be second-guessed in ways checklists cannot. I think that trade is worth making anyway, because a system built entirely around proving compliance eventually optimizes for compliance rather than for the outcomes compliance was supposed to protect. That is the same argument I have made about negotiated rulemaking and about the Credit Transfer Consortium: accreditation works best as a peer-driven process grounded in professional judgment and institutional mission, not as a federal or bureaucratic checklist exercise. The AIM rulemaking is going to put a floor under some of what we do regardless of how this rewrite turns out. What we control is whether the rest of the Principles reads like a document written by peers who trust institutions to tell their own story, or a document written to survive an audit. It is the difference in being Quality Seekers versus auditors. I know which one we are trying to build.

Standards should measure whether students are being well served, not whether an institution can produce the right binder. That is the whole point of this rewrite, and it is why I would rather take the time to get it right than rush it to get it done.

A few weeks ago, at the close of Law or Lore, I told you I was moving to something new. That series taught me how strong the appetite is among our institutions for straight talk about what accreditation actually requires versus what people assume it requires. In the Room is going to do something a little different. Instead of correcting misconceptions after the fact, I want to bring you into the room while the work is still being shaped, the issues we are wrestling with and the initiatives we are building at The Commission, before they are finished products. If you know me, you know where the name comes from. This first installment is about one of the most consequential ideas on our table right now: a Credit Transfer Consortium. Let’s start with why it matters.

The Issue

Every year, roughly 38 million Americans carry some college credit and no credential, what researchers call the ‘some college, no credential’ population. A significant share of that group stopped out or transferred between institutions, only to discover that credit they had already earned did not travel with them. The Government Accountability Office found that students who transfer lose an average of 43 percent of their earned credits. That number is higher among military and student athletes. Over a third of all undergraduates transfer at least once in their academic career, so this is not an edge case. It is a structural feature of how students actually move through higher education, and it costs them time, money, and often the momentum that keeps them enrolled at all.

Accreditation standards have historically said almost nothing about whether an institution accepts transfer credit. That silence was not neutral. It left the decision entirely to institutional discretion, and institutions, understandably, have used transfer policy to protect enrollment, tuition revenue from required courses, and, in some cases, a sense of academic prestige. None of that makes institutions wrong to have acted that way. It makes clear that credit loss is a systems problem, not a bad-actor problem, and systems problems need a structural remedy.

That is why The Commission is exploring a voluntary Credit Transfer Consortium: member institutions would commit to recognizing general education credit earned at other member institutions, subject to agreed equivalency standards. It is voluntary. It asks institutions to accept real constraints on their autonomy in exchange for something valuable in return. And it is, I think, one of the most promising structural remedies available to us. Let’s be clear, states have already done great work with their institutions on transfer. What I believe we can do is expand that work across state lines to best support and represent a very mobile student population.

The Discussion

A voluntary consortium only works if institutions have real reasons to join, so we have spent the last several months mapping what those reasons could be. They fall into four categories: enrollment and revenue (guaranteed transfer pathways, a shared marketing network, priority access to transfer-ready student data), accreditation and regulatory relief (a formal transfer-friendly designation, streamlined substantive change review, favorable treatment near sanctions thresholds), academic and reputational recognition (national awards, thought-leadership platforms at Commission events), and operational relief (shared equivalency frameworks so registrars are not rebuilding the wheel institution by institution).

On the standards side, the draft framework we are testing includes a 90 percent credit-acceptance floor for equivalent coursework between member institutions, a publicly posted and annually updated equivalency guide, a 30-day evaluation timeline with written explanations for any credit not accepted, a formal appeals process, and non-discrimination protections so acceptance decisions cannot turn on where a student came from. Institutions still retain 10 percent discretionary judgment, and faculty senates still control curriculum. The floor governs the transfer evaluation process, not what a course has to look like to exist.

We have also been honest with ourselves about where institutions will push back: fear of lost tuition revenue, concern about accepting credit from ‘weaker’ programs, worry about diluting academic standards, and unease about what this means for faculty governance. Every one of those concerns deserves a real answer, not a dismissal, and we are building the framework with those answers built in rather than bolted on afterward.

There is also a reason this conversation cannot wait. On May 21, the U.S. Department of Education’s Accreditation, Innovation, and Modernization committee, the same negotiated rulemaking process I have been tracking with you since the spring, reached consensus on a package of regulatory changes, including new federal requirements on transfer of credit. Under the agreed language, accreditors will be required to ensure institutions maintain policies that presume undergraduate credit will be awarded for coursework completed at another accredited institution with comparable content and learning outcomes, unless the institution can provide a written, student-specific rationale for denying it. Institutions will also face new disclosure obligations: telling students before they enroll or commit financially what credit will transfer, explaining any denial, estimating the cost and time to replace denied credit, and providing a real appeal. The Department is expected to publish a formal proposed rule this summer, with a final rule targeted for November 1 and an effective date of July 1, 2027.

I want to be clear about what that means for us. This has been a prevalent issue in higher education for a very long time. We are at an inflection point and have the opportunity to show the world that we are about students first and solve this issue on our own. I believe we have the strongest argument yet for building this Consortium well, and building it now. The federal floor that is coming will apply whether or not institutions have had any hand in shaping how it works in practice. A Consortium of our members with faculty driving the equivalency decisions gives our institutions a running start, a framework designed with them rather than handed down to them, and infrastructure already in place before compliance becomes mandatory rather than voluntary.

Progress Update

As of this writing, 195 institutions ranging from the very large to the small have joined us in developing the framework for the Consortium with our largest numbers being our Level I (associate degrees as their highest degrees) and our Level VI (four or more doctorates as their highest degrees). In July, we brought this conversation directly to the people who will have to live inside whatever we build. At the Summer Institute, department chairs, registrars, institutional effectiveness staff, and faculty content experts from across our membership worked through three questions using live polling, and we let the room vote in real time rather than asking them to react to a proposal we had already written.

On governance, the clear preference was a steering committee paired with subject-area committees, with representation across states, institutional levels, and public and private lines, and real opportunities for input rather than a seat at the table for show. On incentives, the runaway favorite was visible recognition: a ‘transfer-friendly institution’ seal that shows up on the website, on recruitment materials, and on the transcript itself, not a plaque nobody sees. And on the question of faculty trust, which drew the most decisive response of the day, the room asked us to create a formal Commission’s Fellows program that names and credits the faculty who do the actual work of evaluating equivalencies.

The Pruitt Perspective

Strip away the acronyms and the vote counts, and this comes down to two forms of trust that have to hold at the same time. Institutions have to trust that a consortium will respect their autonomy and their academic judgment, not override it. And students have to trust that a credit they worked hard to earn will not simply vanish the moment they walk onto a different campus. Right now, we are asking institutions to extend trust toward a structure that does not fully exist yet, which is exactly why the design work matters as much as the eventual standard.

The AIM rulemaking changes the calculation, but it does not change the principle. A federal floor on transfer credit is coming regardless of what we do. We can wait and let the Department define, entirely on its own, what compliance looks like for our institutions. Or we can build something better first, something shaped by the registrars and faculty who actually do this work, something that treats transfer credit as a matter of academic judgment and student trust rather than a checklist item. I know which one I would rather hand our institutions.

This is also, at its core, the same argument I made about negotiated rulemaking a few months ago. Accreditation should not become a federal compliance exercise. It is a peer-driven process grounded in professional judgment, institutional mission, and continuous improvement. A Credit Transfer Consortium, built with our institutions rather than around them, is how we keep that true even as the federal landscape shifts underneath us.

Students first. Always. That is the whole case for this Consortium, and it is why I think it is worth getting right, not just getting done.

Thanks for joining me In the Room. 

Dr. Stephen L. Pruitt