The American Association of Community Colleges (AACC) submitted detailed comments to the Education Department (ED) this week on its Notice of Proposed Rulemaking (NPRM) on accreditation, addressing areas such as transfer of credit and more.
As reported previously, the regulations emerged from a set of “negotiated rulemaking” sessions that occurred earlier this year. At those negotiations, Monty Sullivan, now interim president of the North Carolina Community College System, represented community colleges. The regulations are likely to be published in final form by November 1, allowing them to take effect next July 1. Some modifications to the NPRM may materialize, but they are not expected to be extensive.
By adding a raft of new requirements and procedures for accrediting agencies seeking ED approval for Title IV purposes, the NPRM would push the federal government into new territory in regulating higher education. Many of the specific provisions in the NPRM echo President Donald Trump’s Executive Order of April 2025.
“ED’s regulations should refrain from requiring accreditors to undertake practices that are not closely tied to institutional accreditation’s core quality assurance mission or otherwise required by law,” AACC President and CEO DeRionne P. Pollard said in the association’s comments, which were submitted with the Association of Community College Trustees. “While ‘quality assurance’ can legitimately mean different things to different parties, some of the NPRM’s proposed policies extend into areas that cannot reasonably be said to enhance ‘educational quality,’ straying beyond this essential role into other areas of regulation that are not authorized by the HEA or implied in its legislative history.”
Many other higher education groups sounded this cautionary note on the expansion of accreditors’ functions, including the American Council on Education, whose comments AACC also endorsed.
Transfer of credit advancements
AACC extolled the transfer-of-credit provisions in the regulations, which, as proposed, appear to create strong impetus, if not a mandate, for accepting credits from incoming students.
“The widespread rejection of transfer credits comes at a staggering cost to student aspirations and significantly undermines higher education’s overall efficiency,” AACC said in its comments. “Study after study has shown that the unjustified, often summary, rejection of community college credits has unreasonably, often cruelly, undermined the academic progress of community college students who transfer.”
AACC noted that in an ideal world, federal intervention would not be necessary, but, unfortunately, this is not the case. It’s important to remember that community colleges will be required to establish detailed policies for incoming transfer students and specify why incoming students’ credits are not accepted, if applicable.
The NPRM is also designed to facilitate the switching of institutional accreditation, a growing practice.
AACC concerns
AACC has noted several concerns about the proposed rule and asked for related modifications. In some areas, accreditors would be required to take on new or, in AACC’s view, inappropriate activities.
These include:
- Public institutions’ role in providing First Amendment protections.
- Determining the efficacy of institutional policies designed to “support, promote and appropriately prioritize intellectual diversity.
- Ensuring that institutions conduct cost/benefit analyses for all institutional expenditures.
- Introducing a new concept of “educational outcomes” in evaluating student achievement that may complicate the ongoing work of accreditors.
- Overseeing academic freedom practices.
AACC will keep members apprised of ongoing developments and provide a detailed analysis of the final rule when it is published this fall.
