Accreditation Q&A Explainer

Accreditation is a hot issue in higher education policy, and it is also one of the wonkiest. Since taking office, President Trump has pushed for sweeping reforms to the accreditation system. Most recently, he signed an executive order targeting existing accreditors and directing the Department of Education to authorize new ones.¹

But what is an accreditor, and what is accreditation’s role in higher education? What do accreditors have to do with student outcomes—and what (if anything) do they have to do with DEI? This memo addresses frequently asked questions about the accreditation system and proposed reforms.

What is an accreditor?

Accreditors are organizations tasked by the Higher Education Act (HEA) to ensure that higher education institutions that accept federal aid provide a quality education to students.² Colleges must be accredited to be eligible to receive Title IV funding, including federal loans and Pell Grants. Institutions and programs apply for accreditation through an agency of their choosing. If approved, they become members of that accreditor and pay annual dues and fees.³ Colleges do not have to be accredited to exist, but they must be accredited to receive federal aid.⁴

Accreditors are a key part of what is known as the “program integrity triad” of our nation’s higher education system. The triad is comprised of accreditation, which oversees institutional quality; state authorization, which allows a college to operate in a state; and the Department of Education, whose certification of financial responsibility unlocks Title IV eligibility after accreditor and state approvals.⁵ To become an accreditor, an organization must meet criteria and standards specified in statute and be recognized by the US Secretary of Education.⁶ An accreditor’s stamp of approval is meant to signal that a college provides a quality education to students. In addition, accreditors help institutions create goals for self-improvement, establish criteria for professional certification and licensure, ensure an institution or program’s financial stability, and help determine transfer credits.⁷

There are two types of accrediting agencies: institutional and programmatic. Institutional accreditors evaluate an entire college, and, in most circumstances, colleges and universities must be accredited by an institutional agency to receive federal financial aid.⁸ Programmatic accreditors evaluate specialized programs, and employers can require that employees have graduated from an accredited program.⁹ The Ohio State University, for example, is accredited by the Higher Learning Commission, an institutional accreditor, while its law school is accredited by the American Bar Association, a programmatic accreditor.¹⁰ There are 24 recognized institutional accreditors and 36 recognized programmatic ones that each oversee a range of schools and programs.¹¹ Some accredit a few dozen programs, while others, like the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC), accredit more than 750 institutions.¹²

How does a college or program become accredited? 

Becoming an accredited school is a lengthy process. After a college identifies an accreditor, the accrediting agency conducts a thorough review to determine if the school meets its standards and qualifies for accreditation (and thus for federal financial aid). Generally, an institution or program seeking accreditation must engage in a self-study process to assess its educational quality and success in meeting its mission, outline plans for improvement if applicable, and participate in an on-site review before the agency makes its determination.¹³

Accreditors are required by statute to set standards for specific areas: student achievement, curricula, faculty, fiscal and administrative capacity, student support services, recruitment and admission practices, and more.¹⁴ Agencies can develop standards beyond those required by statute if they follow rules for providing notice to constituents and responding to public comments.¹⁵ Institutions and programs must meet an agency’s standards to gain accreditation. After an institution or program obtains state authorization and an accreditor’s stamp of approval, it is then reviewed by the Department of Education, which can approve it to receive Title IV funding.¹⁶ Once accredited, an institution or program’s performance is continually reviewed by its agency through periodic reevaluations to ensure ongoing compliance with accreditation standards.¹⁷

How is accreditation different than state authorization?

To receive federal student aid, an institution must be accredited and have permission to operate in the state where it is located. Accreditation is intended to oversee educational quality and is handled by non-governmental organizations.¹⁸ State authorization, on the other hand, is the process an institution goes through to legally operate within a given state.¹⁹ When a college is granted authorization from a state, it must comply with state laws.²⁰ This is a crucial requirement because states can set and enforce their own higher education consumer protection laws.²¹

Both in-person and distance education offerings must receive state authorization.²² This can pose challenges for online programs, which can enroll students in multiple states with varied laws. Colleges with online programs can choose to participate in a State Authorization Reciprocity Agreement (SARA), which allows institutions to operate in multiple states without submitting an individual authorization application to each one.²³ However, it is important to keep in mind that under SARA, institutions are only held to the standards of their home state, which can limit other states’ ability to enforce their own consumer protection laws.²⁴ To be eligible to participate in SARA, a school must be institutionally accredited and have distance education included in its scope of recognition.²⁵

What does an accreditor do if an institution is failing to meet standards?

Colleges must meet certain standards and criteria to be accredited, and agencies periodically review institutions to ensure that they remain in good standing. If an agency finds that a college is out of compliance with any standards, it is required to take the following steps.²⁶

First, the accreditor issues a written warning to the institution or program that it is out of compliance and sets a timeline by which it must come into compliance.²⁷ That timeline can include checkpoints to monitor progress.²⁸ If the institution or program fails to meet standards in time, the agency must take an adverse action, like revoking its accreditation.²⁹ An agency may maintain the institution or program’s accreditation until it has the time to finish teaching its current students through graduation or help students transfer to a new school.³⁰

For example, the New England Commission of Higher Education (NECHE) placed Bay State College on probation in 2022 for failing to meet two standards.³¹ The accreditor withdrew the college’s accreditation the next year after it determined that Bay State would not meet standards by the end of the probationary period.³² In its official letter terminating the college’s accreditation, NECHE cited concerns about an enrollment decline and a budget deficit.³³

These general procedures are specified in the HEA, and other details not described in law are left up to the accreditor to determine and codify in its own procedures and standards. This means that there can be differences in how accreditors sanction institutions that violate their standards.³⁴

What do accreditors do to address programs or colleges with poor student outcomes?

Every accreditor sets its own standards to address programs or institutions with poor student outcomes. The HEA requires accreditors to set standards for “success with respect to student achievement.”³⁵ However, neither the statute nor the Department of Education specifies which student success outcomes or benchmarks agencies must consider when reviewing an institution’s quality. In fact, the HEA prohibits the Secretary from establishing explicit criteria for agencies that are not written in statute.³⁶ For example, the Secretary cannot mandate that agencies require institutions to graduate at least 50% of students to maintain their accreditation. As such, statute leaves the door open for agencies to accredit institutions and programs with a variety of student outcomes at their discretion. Some accredited institutions graduate more than 90% of students a year, while others have single-digit graduation rates.³⁷

What role do accreditors play in debates and policies related to DEI?

The law doesn’t allow the Department of Education to interfere with accrediting agencies’ efforts to set their own standards. The HEA states: “Nothing in this chapter shall be construed to permit the Secretary to establish criteria for accrediting agencies or associations that are not required by this section. Nothing in this chapter shall be construed to prohibit or limit any accrediting agency or association from adopting additional standards not provided for in this section.”³⁸ The HEA does not require agencies to create or apply standards related to diversity, equity, and inclusion, nor does it prohibit accreditors from choosing to do so.³⁹

Some accreditors have established DEI standards for accreditation. Following the Trump Administration’s executive order on DEI in accreditation, some of these agencies have responded by removing mentions of and requirements related to DEI.⁴⁰ A major institutional accreditor, the Western Association of Schools and Colleges Senior College and University Commission, paused its DEI requirements.⁴¹ Other agencies have told institutions that they will not be reprimanded for failing to comply with DEI standards.⁴² The American Psychological Association, and the Association to Advance Collegiate Schools of Business revoked their DEI standards.⁴³

It is important to remember that accreditation is a voluntary process.⁴⁴ Not every accreditor has DEI-related standards, and if an institution disapproves of its accreditor’s DEI standards, it could seek to change accreditors.

Are states or the Department of Education allowed to tell colleges to change accreditors?

Several states have passed laws mandating that public institutions change accrediting agencies on a set schedule.⁴⁵ This approach would appear to conflict with the HEA, which conditions that membership to an accrediting agency must be voluntary.⁴⁶ However, Republican lawmakers in Florida and North Carolina, for example, have enacted legislation that requires state colleges and universities to change agencies after a certain number of years, as part of stated efforts to reduce accreditors’ power over public institutions.⁴⁷ Most Florida and North Carolina institutions are accredited by SACSCOC, an agency with which both states have engaged in political battles.⁴⁸ The legislation moves public institutions away from that accreditor’s oversight. The University of North Carolina system is even “exploring the idea” of creating a new accrediting agency with other public university systems, which would further distance the state’s public colleges from traditional accreditors.⁴⁹

The HEA mandates that accrediting agencies be comprised of a voluntary membership of institutions.⁵⁰ If institutions are forced to change accreditors because of state policies, one can argue that the decision is not entirely voluntary. After Florida’s state law took effect, the Biden Administration claimed that the law “potentially undermines the voluntary nature” of accreditation and clarified steps that institutions must go through to change agencies.⁵¹ However, a May 2025 Dear Colleague letter from the Department of Education stated that the Trump Administration does not interpret a requirement to change accreditors in order to comply with state law as constituting an involuntary membership.⁵²

Can the government “fire” accreditors? What happens if it does?

The president cannot unilaterally “fire” an accreditor. The Department of Education can terminate an agency’s recognition, but such a decision could take years to finalize. Department staff and the National Advisory Committee on Institutional Quality and Integrity (NACIQI), a bipartisan advisory committee that reviews accreditors, can each independently recommend that an agency’s recognition be terminated.⁵³ The Senior Department Official (SDO) overseeing accreditation then reviews the recommendations and determines whether to terminate the agency’s recognition as an accreditor, limit the agency, or let it continue as a recognized accreditor.⁵⁴ If the SDO moves to terminate or limit the accreditor, the agency can appeal the decision to the Secretary of Education.⁵⁵ The Secretary then reviews the appeal and the rest of the accreditor’s record, and if they decide to revoke recognition, the agency can contest the decision in federal court.⁵⁶

The Accrediting Council for Independent Colleges and Schools (ACICS) is the agency that most recently lost federal recognition. The process to terminate its recognition spanned three presidential administrations (including a court case in the middle that restarted the process) and finally ended in 2022.⁵⁷ The institutions or programs accredited by an agency that loses recognition receive an 18-month window to find a new accreditor, during which they remain eligible for federal financial aid.⁵⁸ President Trump has threatened to “fire” accreditors, which makes the process sound quick and easy.⁵⁹ But terminating an accreditor’s recognition can take a while, and the Department of Education must follow the procedures outlined in statute and regulations.

What are some common critiques of accreditation?

Advocates across the political spectrum have gripes about accreditation, but they have different ideas for how to fix the system.

Many right-leaning advocates are focused on overhauling the accreditation system by removing DEI standards and recognizing new agencies. President Trump signed an executive order that directs the Secretary to monitor, suspend, or terminate an agency’s recognition if it requires institutions to engage in DEI initiatives, and to recognize new accreditors.⁶⁰ These calls for ridding accreditation of DEI and recognizing new agencies are not new. Thought leaders from conservative think tanks have long supported prohibiting agencies from including DEI requirements, and in recent Congresses, Republican members introduced bills to prevent agencies from implementing DEI policies.⁶¹

These advocates argue that recognizing new agencies would give institutions more choice, which they claim could drive improvements and speed up the pace of innovation in higher education.⁶² For right-leaning advocates, expanding the marketplace of accreditors should let institutions pick an agency that best fits their mission, limit undue influence from specific agencies (like those with DEI standards), and help new colleges enter the market.⁶³ Some argue that new agencies could even promote better outcomes if they specialize in accrediting college with strong economic returns.⁶⁴

In comparison, left-leaning advocates prioritize holding agencies more accountable for accrediting schools with abysmal student outcomes.⁶⁵ Some advocates recommend that accreditors be required to set minimum standards for outcomes, use reliable data to measure student success, and make data publicly available.⁶⁶ The Biden Administration proposed that accreditors be required to create student success benchmarks for the institutions that they oversee, without specifying what those benchmarks should be and allowing for variation and flexibility.⁶⁷ But the changes were not finalized before the end of President Biden’s term and did not go into effect.

Rather than focusing on adding more agencies, left-leaning advocates have sought reforms to strengthen accountability for currently recognized agencies. In their perspective, adding new agencies, even if they are outcomes-focused, does not change how the accreditation system evaluates student success—while an agency could claim that it prioritizes outcomes, it is only required to abide by the minimum statutory requirements that do not require strict standards for student achievement. Therefore, they argue that reforming regulations around currently recognized agencies would be a better path to improve student outcomes and protect taxpayer dollars.

Advocates have different strategies to accomplish accreditation reform, but there is a shared understanding that this system does not work as it should. Both right- and left-leaning organizations are concerned about poor student outcomes, using taxpayer dollars responsibly, and ensuring that institutions deliver on their promise of a quality education.⁶⁸ These areas of common ground should open opportunities to work through solutions to improve accreditation.

What’s next for accreditation?

It remains to be seen whether and how the Department of Education and Congress may act to align accreditation policies and regulations with President Trump’s executive orders. Following the Department’s recent Dear Colleague letter on the approval process for changing accreditors, we could see more institutions start to request to change accreditors. Up next on the accreditation agenda is an upcoming NACIQI meeting, for which an agenda is forthcoming. Six new members (of 18 total) will join NACIQI in October 2025, and the Department released requests for nominations for those positions. Accreditation remains a complicated part of higher education policy, but its future will be anything but uneventful.