ACCOUNTABILITY OF COLLEGES AND UNIVERSITY

____________
AN ESSAY

Preface

Public Debate
Public debate about the accountability of all institutions in American society has been escalating for years, if not decades. In the 1990s, discontent with major institutions and their bureaucracies reached unprecedented levels.

Government has been the largest and most visible target of this discontent. In the last two national elections, the public made it clear that it wanted change. The Clinton Administration was elected in part on the promise to "Reinvent Government." Still not satisfied, voters in 1994 "reinvented" Congress, shifting party leadership in both the House and the Senate. State and local elections also produced sweeping changes. Today, political discourse is dominated by public demands for lower taxes, a balanced federal budget, term limits, and decentralization or privatization of public services.

Public discontent has also focused on medicine, business, the media, organized religion - and higher education. It is no surprise to find higher education on the list. Tuition increases make headlines each fall. For many citizens, access to colleges and universities, and to a brighter future, has become a fading dream. The public is expressing increasing concern about efficiency in higher education and the effectiveness and relevance of its curricula.

State officials, including governors legislators, coordinating boards, and appointed officers, have responded to these forces by focusing their higher education efforts on assessment, governance, and reporting issues. Several states have reorganized and decentralized their governance structures - New Jersey and, later, Minnesota are prominent examples. California, New York, and many other states have reduced spending on higher education programs, although funding patterns across the country are mixed.

At the federal level, the Department of Education struggled to implement new regulations required under Part H, the Program Integrity amendments enacted in 1992. This new law revised Title IV of the Higher Education Act, which authorizes federal programs of student financial aid. The new Part H statute significantly altered the role of federal and state government, as well as the role of private, voluntary accreditation, in their systems of accountability. Part H was a congressional response to fiscal issues raised by the increasing dollar volume of defaults in federal student loan programs. But it was also a response to policy issues of accountability.

At the same time, seven national organizations of higher education institutions joined with the six regional bodies that conduct institution-wide accreditation to form the National Policy Board on Higher Education Institutional accreditation, the NPB. This group deliberated on reform of the national accreditation system and in October 1994 issued a draft proposal to establish a new national body of accreditation. The NPB also called for wide dissemination and discussion of their proposal within the higher education community.

The Accountability Study
Although the subject of accountability in higher education had been brought to the fore, debate was fractionalized and lacking a solid foundation. There was little consensus on elements necessary for proper accountability. Some labeled higher education accountability a "non-system." Others saw a sprawling amalgam of uncoordinated accountability systems, consuming considerable resources but

Producing unsatisfactory results. There was also no agreement on principles to inform these multiple dialogues and to guide the many participants to an improved state of accountability for out colleges and universities.

It was this atmosphere that the Accountability Study was undertaken. In January 1995, the Andrew w. Mellon Foundation received a proposal - "A Study on the Accountability of Colleges and Universities" - to address these questions. The following March, the Foundation made an award to Columbia University to support the study. It was to be undertaken by three distinguished authors with extensive relevant expertise. Patricia Albjerg Graham, president of the Spencer Foundation and Charles Warren Professor of the History of American Education at Harvard University, Richard W. Lyman, J. E. Wallace Sterling Professor Emeritus and President Emeritus at Stanford University; and Martin Trow, Professor of Public Policy at the University of California at Berkeley. Columbia agreed to make available Gregory Fusco, Vice President for Government Relations and Community Affairs, to direct the study. (For biographical sketches of the authors and study director, see Appendix A.)

Columbia further agreed to hose the study and to provide the necessary support to move it forward to completion. The Spencer Foundation released the time and energies of its president, Dr. Graham, and provided funds for travel and other support.

The Essay
The essay was favored as the most appropriate vehicle for addressing the issue of accountability. Our review of the history of accreditation animates our essay in selected areas, but we did not discover enough new material on this aspect to warrant a separate section. Our essay focuses primarily on the learning process and on the internal means that institutions should use to assure proper accountability. It is not, per se, about accreditation or about government. We encourage readers chiefly interest in accreditation to stay the course and consider the entire essay. Likewise, the essay does not include a great deal about the federal government, and we say even less about state governments. We urge public officials interest in higher education to consider the primary thrust of our essay and to apply it to their particular circumstances. We believe that our essay provides useful analysis and diagnosis, practical recommendations, and significant principles to guide all those seeking proper accountability in higher education.

We, and our panel of experts, discovered several significant issues where there is not yet a consensus. One such issue is the proposal to shift institution-wide accreditation from its present regional basis to a revised alignment where each sector has a national accrediting body, for example, one for community colleges, one for research universities, etc. Having heard persuasive arguments both for and against this proposal, we cannot now recommend a solution. Another issue where consensus may be premature is the rapidly evolving area of "distance Learning: through new forms of electronic and interactive communication. Our conclusion here is that distance learning will change higher education in ways we cannot yet predict, but that the fundamental roles of educators and their responsibilities for teaching and learning should not be diminished.

Executive Summary

Notwithstanding their extraordinary diversity, our higher education institutions all share the central mission of student learning. We have placed learning, and the teaching that inspires it, at the heart of our essay. Learning is not easily measured, and we lack adequate tools and sometimes the willingness to undertake such measurement or to convey its results.

Accountability in American higher education has two hemispheres: internal and external. Internal accountability focuses primarily on academic concerns and is campus-centered, while external accountability provides evidence and assurance, largely to outside audiences, that institutional missions are being accomplished. Currently, these hemispheres contradict rather than complement one another. We find other significant faults with each type. We propose reforms for both hemispheres to strengthen them and to make them reinforce each other.

The central conclusions of our essay are that most colleges and university need to pay greater attention to teaching and learning, areas that are the proper focus of internal accountability; that improved accountability begins at home, so we propose more serious and candid reviews focused on the quality of education in each academic unit; and that institution-wide accreditation should adopt a process of audits of the internal quality-control efforts within the institution.

The audits we propose are a major innovation, but they cannot be put into place until institutions first reform their internal accountability. We recommend new forms of faculty-led internal reviews, new practices for academic administrators, and better institution-wide systems of internal accountability overseen by presidents, provosts, and senior academic leadership.

This new system of internal accountability will not operate properly unless institutions first nurture a climate of critical self-inquiry where candor and criticism can flourish and where each unit is allowed to express its own mission, its strengths, and its weaknesses. At a later stage in the review process, other institutional authorities may modify the mission or render different judgments about the unit under review. This improved internal accountability can lead to better external accountability through audits. The two spheres would reinforce, rather than contradict, one another.

Our proposed audits would build upon the current system of self-regulation, where private, voluntary accreditation agencies (principally, the six regional bodies) utilize peers to conduct an institution-wide review. The process would shift from an assessment of the quality of an institution to an audit of internal quality-control mechanisms of the institution. The institutional self-study would be maintained but would now focus on teaching and learning, on identifying weaknesses, and on the effectiveness of actions to address those weaknesses.

We strongly believe that the entire institution should be the unit of review, not a component or subunit. We are troubled by much of what we see in specialized accreditation, in particular by the actions of the law school accreditation body, which elicited an antitrust action by the U.S. Department of Justice. If specialized accreditation is to continue, it must feed into the general, institution-wide process and not distort the overall mission of the college or university.

In the 1990s, accountability has become a more urgent challenge for all sectors of American society: government, medicine, business, the media, organized religion - and higher education. Many are seeking evidence and assurance about the quality of higher education. When the response to supporters or a skeptical public is inadequate, critics become inpatient and trust in colleges and universities erodes.

Despite criticisms of higher education, public confidence remains high. We call this phenomenon the paradox of public esteem. In some sense, both the cheers and the jeers are justified. Across American, we see a sprawling array of colleges and universities with great merits; we also see serious but curable problems that need attention. We undertook this study to contribute to the public debate about accountability and to urge greater attention to teaching and learning.

Our essay considers the many elements of accountability: government regulation, the workings of private markets, and self-regulation, including accreditation by peers and the many forms undertaken by the institutions themselves. The latter include the efforts of trustees, faculty, and academic administrators led by the president or chancellor, as well as the internal reviews and mechanisms in place in every well-run institution.

Trustees stand at a vital juncture of the internal and external hemispheres of accountability. We attribute the emergence of the controversy about accountability of colleges and universities in part to certain failures by governing boards. In most cases, governing boards need to know more about their institutions in order to better perform their duties. Some boards intrude on the proper roles of administrators and faculties, while other boards are too laissez faire. In particular instances, boards of trustees need to modify their size, methods of appointment, membership qualifications, or roles. All of these changes will require a delicate balance among trustees, the faculty, and the president. Presidential leadership here is key.

Our review of government regulations of higher education reaches a conclusion similar to broader reviews by others. Many regulations seek proper goals through inoperable means. They are intrusive, unnecessarily burdensome, and in need of major reform. Federal and state officials have already begun this task, and higher education should benefit. In regard to accountability, the Program Integrity provisions under Part H have been shown to have major flaws in both their legislation and regulation. We applaud signals from the Clinton Administration and Congress that new approaches in program integrity will be pursued.

Public debate about accountability of colleges and universities can be useful and can lead to expanded support. However, the debate has become fractionalized and lacks a solid foundation. We hope to advance a healthy debate by presenting five basic principles to guide improvements. These principles of accountability of higher education are: (1) External accountability must reinforce internal accountability; (2) "Do no harm"; (3) Respect diversity; (4) Academic responsibility is central; and (5) Accountability is a forward-looking responsibility.

The claim to special status, based on the conviction that only insiders could make informed judgments about their own work and that members of the profession require protection from ignorant assaults by nonprofessionals, is not peculiar to higher education. Self-regulation versus public regulation is an issue in every profession. But it is a particularly compelling issue in higher education, which occupies a singular and central position in the United States.

Higher education is one of America's greatest strengths and one of our country's most significant advantages in international competition. Attendance at college is a principal element of the American Dream. Our colleges and universities lead the world in two quite separate domains: research productivity and student access. America is the leading source of new knowledge in the world. In the last half-century, more than half of all Nobel Prizes have been awarded to scholars living in the United States; in the last decade, half of all citations in leading scientific journals were to U.S. scholars; and in 1990, half of all patents registered here were of domestic origin.

America also leads the world in the proportion of its population who have attended colleges and American colleges and universities. More than a third of adult Americans have attended post-secondary institutions, compared to one-fifth for Japan and one-tenth for much of Western Europe. Only Japan has a higher participation rate for men, but our overall rate is greater than Japan's because of the large enrollment of American women. A telling indicator of the strength of our colleges and universities is that many Japanese attend American colleges; in fact, they account for the second-largest contingent of foreign students in the United States. Currently, more than 85 percent of young Americans have high school diplomas or their equivalent, and about half of them are enrolled in college. Although upper middle-income students and whites are more likely to be in college than low-income blacks, this disparity has decreased over the past 35 years.

While American colleges and universities are the envy of the world, many Americans, both inside and outside academe, are critical of these institutions. And no criticism is more often voiced than higher education's claim to special status constitutes a refusal to be accountable.

Immediately, one must ask, "Accountable for what and to whom?" Institutions must be sure that they are meeting their own and the public's standards. While emphasis upon research, academic and professional programs, and community service may vary from institution to institution, all use internal means of one sort or another to maintain standards for their kind of institution. We call this campus-centered and largely academic process "internal accountability."

Likewise, institutions use multiple means to assure the public that they are accomplishing their chosen mission. They seek to provide evidence to the public that their students are indeed learning and that their institutions are serving the society wisely and efficiently. It is the same public that supports them by sending students, by hiring their graduates, and by providing both public and private funds for instruction and research. We call this process of public assurance "external accountability." From our review, we conclude that these internal and external mechanisms of accountability are in too many cases separate and contradictory. To improve accountability in higher education, we must strengthen the relationship between these internal and external hemispheres.

Student Learning
It is commonly and correctly cited that the strength and value of our higher education institutions stem in large part from their diversity. Though immensely varied, American colleges and universities hold one central goal in common: to help students learn. This goal is as critical to a two-year community college as it is* to a research university~ Rarely, however, do institutions attempt to discover whether or how much their students are learning.

Measurement of student learning in college or university studies is immensely difficult and precision is impossible. No test yet devised can really measure this learning. But in the face of the problems inherent in better understanding or measuring the benefits to students, faculty and administrators too often simply ignore the matter. Some faculty take the position that their job is teaching, and students are responsible for learning. Assessing learning in any meaningful way is considered difficult or simply unworkable, especially when a standardized method for all schools and disciplines is proposed. While challenging research questions in other areas attract the finest minds in academe (e.g., the Manhattan Project and the Human Genome Project), investigation of the essence of the undergraduate or graduate experience has not caught the attention of a comparable cadre of investigators.

Too often, faculty and administrators have merely asserted that student learning has occurred. Then the faculty was expanded to include high-salaried, high-profile scholars recruited to conduct research, and low-salaried, often part-time, members were hired to teach undergraduates. And finally, tuition was raised the following year.

Not surprisingly, the public, which includes the tuition-paying parents of students and the citizens whose taxes go to support the institutions directly or indirectly, does not find these explanations about learning entirely persuasive or these outcomes satisfactory. Outside groups regularly complain about the high-handedness of tuition increases, faculty who do not fulfill their obligations, inappropriate research expenditures, and too much or too little multiculturalism in the curriculum, faculty, or administration.

A Valued Result
The criticism notwithstanding, indicators of confidence in higher education remain impressive. Enrollments have grown in the last few decades, despite the shrinking pool of traditional college applicants and higher-than-inflation tuition increases. The income differential between high school and college graduates is large and continues to grow, which demonstrates the employment market's confidence in higher education. Whites with college degrees earn 41 percent more than whites with only high school diplomas; for blacks, the differential is even greater.

Private giving to higher education is growing substantially. According to the National Center for educational Statistics, gifts grew from $3.2 billion in the academic year 1980-81 to $7.8 billion in 1989-90 - a 66 percent increase in constant dollars. Nonmonetary support by alumni is enthusiastic and broadly based. Journalistic ranking systems of colleges and universities, albeit flawed, draw immense interest. Education ranks among the top three purposes of personal savings (along with housing and retirement). Opinion polls and focus groups continue to place a college education as a key goal. Academics justifiably point with pride to these figures and indicators.

Students keep enrolling, employers keep rewarding advanced studies, researchers keep making discoveries, and donors continue giving. Obviously, the public believes that higher education has significant benefits.

PARADOX OF PUBLIC ESTEEM
Why, then, is American higher education the subject of such high regard and consumer demand and at the same the subject of escalating, sometimes vitriolic, criticism and calls for greater accountability? - We call this phenomenon the paradox of public esteem. Other commentators have also noted this strange paradox. Soon after retiring from the presidency of Harvard, Derek Bok wryly noted: "It occurred to me to be so admired in other parts of the world while being so roundly criticized at home was a singular achievement for our institutions of higher learning."

International admiration is expressed in two ways: by the unprecedented flood of students from other countries and by imitation. In attempting to reform and improve their own systems, nations around the world have turned to us, the pioneers of mass higher education, for ways to open their systems both to competition and to cooperative arrangements. One much-copied innovation is our system of readily transferable units of academic credit. Nations, as they come to view higher education as critical to economic competitiveness, are also turning to us for help in extending higher education to a host of utilitarian matters. Ezra Cornell's celebrated pronouncement to found an institution "where any person can find instruction in any study" has renewed impact, resonating on a global scale.

The paradox about higher education does not end here. As Bok went on to point out, American higher education, while certainly flawed, is undoubtedly performing better in almost every category than it did 30 or 40 years ago, when criticism was negligible. So why do we find ourselves less culpable yet more inculpated? Bok believes that it is largely because higher education has remained aloof from the wave of efficiency and quality reforms that have swept over so much of the country's institutional infrastructure, from downsizing and TQM (total quality management) in the corporate world to the Clinton Administration's widely advertised program "Reinventing Government:'

The paradox can also be traced to the public's growing ambivalence toward the professions, a phenomenon of the last third of this century. Young people are entering the professions in record numbers, despite increasing criticism of these professions. Physicians, for example, once the unchallenged authorities in health care, find their judgments regularly questioned, by hospitals, regulators, legislators, insurers, and patients.

Annual opinion surveys conducted by Louis Harris and Associates since 1966 reflect a general loss in confidence in our national institutions. The surveys, focusing on such institutions as higher education, the military, medicine, law firms, the White House, Congress, the press, and television news, have produced an aggregate index of public confidence. For the base year 1966, this index was established at 100. By 1980, the index of public confidence fell to 45, and it reached a three-decade low of 39 in both 1994 and 1995. Higher education is no exception to this trend. A difference Harris scale reveals a similar drop in public confidence in colleges and universities. In 1966, 61 percent of respondents expressed a great deal of confidence in these institutions. This figure tumbled to 36 percent in 1981 and to 27 percent in 1995. Both measures highlight the same trend: in 30 years, institutions in general and higher education in particular have lost more than half of their public confidence.

Higher education does not lack for critics, and they find a ready audience. Both Charles Sykes's Proficam and the late Alan Bloom's Closing of the Anw7ican Mind - very different attacks on academia - were best sellers. And many pay heed to the words of government officials like William Bennett and Lynne Cheney, who criticize colleges and universities for neglecting the classics and succumbing to political correctness.

Higher education's response to public criticism is dearly inadequate. We tinker with the curriculum, but do not ask basic questions about its adequacy in times of rapid change. We resist moves to try to assess higher education. Too often, higher education seems to be saying, "Trust us. We know what we're doing. We're doing it right, and if you don't think so that's simply because you don't understand."

Perhaps a key to unlocking this puzzling paradox may be found in a pair of studies done in 1993 and 1995 in California by the Public Agenda Foundation for the California Higher Education Policy Center. In-depth interviews with some 30 opinion leaders, mostly from outside higher education, produced strong criticism of higher education, pessimism about its future, and skepticism as to its leaders' willingness to take a long, hard, honest look at its shortcomings and to make serious efforts to overcome them. In short, these prominent and well-informed individuals echoed many of the critics' indictments. However, a survey of the California public at large, produced a sharply different picture. The public showed little knowledge of or concern for the inside workings of colleges and universities; what they cared about was making sure that they and their children could attend them. They worried, not about the quality of higher education, but about admission, tuition costs, and the availability of student financial aid.

The results of these studies are not encouraging. While informed criticism may still be the province only of a minority, there are good reasons to listen to this prominent group. What they think today, the general public may think tomorrow, albeit in less sophisticated terms. Furthermore, a public fearful of being priced out of the market is unlikely to look favorably upon those who appear to be setting the prices, namely the leaders of higher education.

What are we to make of the paradox of public esteem in relation to the need for academic accountability? It is probable that both admirers and critics are right. Many observers have remarked that any list of the world's 10 or 20 strongest universities would be dominated by American institutions. Yet many of the familiar criticisms of higher education are justified, despite the existence of honorable exceptions. Professors work hard, for the most part, but their devotion to teaching is often inadequate. Achieving change in academia is difficult hence such proverbs as: leading a faculty is like herding cats; trying to change a university is like trying to move a graveyard; and the vote in the faculty was 98 in favor, 2 against, so the proposal lost.

Of course, it is futile to try to reconcile the critics and admirers. In a system marked by so much variety, anyone can find things to admire and things to lament. This helps to explain why the more polemical critics show little concern when their factual errors and misstatements are exposed; they believe that they could easily find less vulnerable evidence to support their attacks. Indeed, too many people on both sides appear to have adopted the attitude, "Don't bother me with facts."

The clamor for accountability has little to do with the strengths of flaws of our system of higher education. It has everything to do with the public's general dissatisfaction with institutions and the broad demand that these institutions be more responsive to the public's needs. Over and over, it has been documented that Americans feel they have less control over these institutions than they once had, and that they are impotent to remedy the wrongs they encounter at the hands of big, seemingly impenetrable bureaucracies and political structures. Higher education has no immunity from the accountability that the public is demanding of all of its institutions.

Academic accountability is needed whether we are hearing cheers or jeers. Higher education cannot afford to take accountability for its most vital functions seriously only when it is feeling threatened. If the United States has the best higher education on the face of the Earth, the academic community ought to be capable of devising improved methods of accountability that protect institutional autonomy and academic freedom and that gain the country's confidence.

MARKETS AND GOVERNMENT
In our pluralistic society, private markets are interwoven with governmental activity. Accountability in higher education is an example of this complex relationship, with governments, markets, and self-regulation operating simultaneously. Markets play a key role in higher education accountability, although certain inherent market imperfections limit that role. Fortunately, the burden of establishing accountability need not rest entirely upon government regulation, private markets, or private accreditation that is based on self-regulation.

Government
Government holds colleges and universities accountable in various ways. While government oversight is a natural and appropriate result of public funding, some wide-ranging regulations do hinder higher education, perhaps unintentionally, and should be addressed. Of course, no one is proposing that we remove these institutions from the jurisdictions of the Occupational Safety and Health Administration or the National Labor Relations Board. The day when colleges and universities enjoyed immunities from government regulations is long gone.

Our principal concern in this essay is accountability for teaching, research, and public service (especially teaching and research) - the core activities of colleges and universities. It is here that proposals for new government regulations engender the most unease, often dismay. Attempts at government regulation of higher education in other countries demonstrate how much havoc can be caused. The British example is particularly poignant. A close relative to our system, British higher education has a proud history of institutional autonomy, now seriously impaired.

The U.S. Department of Education's attempt to draw up regulations implementing Part H (the 1992 Program Integrity amendments to federal student aid programs under Title IV of the Higher Education Act) provided alarming evidence that it can happen here. The amendments mandated new roles for state government and private, voluntary accreditation agencies as agents enforcing federal standards. Many colleges and universities found that this approach intruded on their autonomy over policy issues like graduation and withdrawal rates. It also appeared that state inspectors or regional accreditation groups could gain control over curriculum, admissions, and faculty qualification issues. The initial regulation proposed by the U.S. Department of Education extended these intrusions and included burdensome and contradictory paperwork for certification and eligibility under federal student aid programs. Only through an unprecedented lobbying effort was higher education able to substantially moderate the draft regulations. And as we write this essay, significant discontent remains, which is evidenced by pending congressional changes in the implementation of these amendments. Both the executive and the legislative branches are signaling additional and welcome changes in Part H and the whole federal approach to program integrity.

It is neither right nor reasonable to project no role at all for the federal government in academic accountability. We believe, however, that the federal role should be limited to the recognition of private, voluntary, institution-wide accreditation agencies that can conduct the kind of audits of internal institutional mechanisms that we proscribe below. We also acknowledge the parallel need in nonacademic areas for the fiscal oversight required to assure financial integrity of programs supported by public funds. The lesson of the unfolding developments under Part H and its regulations is not that higher education should have no accountability to the government. Rather, the lesson is that useful means of accountability must recognize the true nature of the learning process as well as the characteristics of the institutions where it takes place. In short, the glove must fit.

While colleges and universities are very different from commercial enterprises, most general federal regulations are indifferent to those differences or to the administrative and financial problems that flow from them. Many of these regulations are a heavy and often unnecessary burden on higher education. They are a quiet tax. They do not engender public discussion of weighty issues, such as affirmative action or accountability, but they are an important concern for every university administrator facing stable or declining budgets and growing enrollments and research costs. The most troublesome regulations are not even designed with higher education in mind; they are the casual swipe of the dinosaur's tail as it wheels around to face larger and more powerful adversaries, in most cases big business and industry.

Among the most onerous of these regulations are those bearing on the management and disposal of toxic wastes, the provision of access and services for physically handicapped and disabled people, and the ill-fitting accounting requirements for federal research grants. In all these cases, indeed in most areas covered by government regulations, academics have little quarrel with the underlying purposes of the legislation or regulation. Rather, their quarrel is with the unnecessary burdens of compliance and reporting. University research scientists are required to manage and account for their grams of toxic chemicals through the same elaborate procedures designed for tons of industrial waste. The length and detail of research proposals and their post-award reporting would turn scientists into accountants, at the expense of their science and at a loss to us all.

Often, equally effective but less costly solutions are available to campuses but are unallowable under the regulations. These problems arise when federal regulators fail to make sensible distinctions among the different sectors being regulated. Hidden costs to colleges and universities are burdens that shift vital resources from more fundamental missions. At a time when governmental regulations of all kinds are under critical review, it is appropriate to revisit those that bear on colleges and universities.

Markets and Their Limitations
Markets are important agents of accountability. Just as teaching is not the only core activity of higher education, students are not the only customers whose market preferences play a part in making colleges and universities accountable. As mentioned above, the employment market is a key indicator of the value of higher education, but this market also serves an important accountability function. Users and beneficiaries of university research are also part of the higher-education marketplace. The dominant supporter of university research is the federal government, which uses a highly competitive peer review system. This is a specialized "market" designed to maximize public benefit by using expert to judge the quality of proposals. Corporate research support is a more conventional market; here, support is directed at university research judged to have clear links to corporate objectives. University research also develops highly trained personnel, linking the research process back to employment markets. Campus cultural events and activities, including university press publications, now expanding to include electronic media, are another class of higher education services that, in varying degrees, must pay heed to the market. Institutions compete vigorously for faculty, both with other colleges and universities, and with alternative employers, principally government and business. The most visible market in higher education is competition for students. Each year, some 14 million Americans choose to invest their time, energy, and money in colleges and universities.

Though market forces play a significant role in making higher education institutions accountable, these forces have their limitations. A market performs satisfactorily only when customers are well informed. Like other organizations in competitive markets, educational institutions are under constant temptation to overstate the value of their "products." We have seen some recent and untoward examples of this, in the strenuous efforts of colleges and universities to improve their standing in thecontroversial but widely heeded ratings published by U.S. News and World Report. Institutions, for instance, have juggled admissions statistics to make it appear that they are more selective than they really are. Such behavior has invited criticism and contributed to cynicism. In this arena, higher education must assume the role of Caesar's wife. Integrity in providing information is certainly close to the heart of the academic ethic, closer than is the case, say, in the soft-drink or entertainment industries. Fortunately, most academics feel this more or less instinctively and are therefore probably more ready to accept rigorous standards for themselves than many others who function in the marketplace.

Even if well informed, most consumers of higher education, especially its central teaching and learning activities, are not in a position to assume the major burden of accountability. For one thing, many conditions that are extraneous to the core academic functions of a college play significant roles in customer choices. Geographic location, price (the total cost to the student and family), quality of athletic programs, social prestige, and the physical attractiveness of the campus all influence a student's choice of college.

Furthermore, it is not condescending to point out that making discriminating judgments concerning the quality and relevance of academic programs is beyond the capacity of most consumers. In competitive sponsored research, this is clearly recognized by the respect paid to peer review. It is not the purchaser of the reach who conducts peer review but the professional equals of the researcher. As for teaching and student learning, peer review is far from unknown; many academic departments and schools invite professional colleagues, either from within or without their institution, to visit and comment upon their performance. But in many institutions, such monitoring of performance is by no means common, and in some it is nonexistent. In such cases, the market cannot fill the gap.

Measuring Outcomes
This realization has given rise to an increasing clamor to apply quantitative measures of academic outcomes to guarantee educational quality for consumers. Among the most vocal on this topic are the Education Commission of the States (ECS) and other state officials. The November/December 1994 issue of Change, the magazine of higher education, was largely devoted to such "assessment."

Faculty members tend to resist this pressure almost instinctively, and various reasons are given. It is difficult to measure the value added to student learning from such factors as teaching quality. As Howard Gardner's research has demonstrated, individuals learn in widely differing ways; no test captures these differences or is equally fair to all who take it. Those who have taught undergraduates for years point-out that college graduates often realize only many years later what they learned in college. We all cherish the belief that higher education encourages lifetime learning. If so, how is that to be measured? At what point in their lives are consumers of higher education best able to judge the benefits they have derived from this "product"?

Faculty resistance can, of course, be overdone. To deny that anything provided by higher education can be measured and the results effectively communicated to prospective consumers is strange doctrine for academics to promote. Do they really believe that no progress has been made in this admittedly tricky field of behavioral science? If so, what does that say about the capacity to learn and to provide mechanisms to assist learning? Some of the internal processes for self-assessment that external auditors will want to examine will surely include measurement. Indeed, this is one of our reasons for stressing the need for accountability to begin at home, within the institutions themselves. For we have seen what measurement imposed from outside can do, and it is not encouraging.

THE ROLE OF TRUSTEES
The fundamental task of a board of trustees or regents is to protect the interests of the institution and the public. This is accomplished by assuring the college or university's performance as well as its fidelity to its mission, guaranteeing its integrity, and protecting its autonomy. Put crudely, the public is assured that it is getting its money's worth, and the institution is assured that it will be free to do its job without undue interference in its affairs. But institutional autonomy has been eroded by regulatory interventions from all levels of government. Private self-regulation of voluntary accreditation is under attack both for ineffectual performance and for meddling in the affairs of colleges and universities beyond its mandate. And while demand for higher education has never been greater, public unease about its performance is widespread and vocal. The current ferment over issues of accountability in higher education therefore carries an unavoidable implication: overall, boards must somehow be falling short of accomplishing their missions.

Two American Innovations
Boards of trustees or regents constitute one of the most distinctive features of American higher education. The early colonial colleges were modeled on the constituent colleges of Oxford and Cambridge Universities. These were governed by their Fellows - i.e., the scholars who were members of the college. But such faculty governance was not possible in the new colonies, where it was difficult for the founders of a college to find one person qualified to be the president. The rest of the teaching staff consisted of new graduates, who taught for a few years until they could locate a parish in need of a minister.

As an alternative to governance by the Fellows of the college, colonial founders developed the lay board of trustees, a corporate body consisting of clergy and civic leaders who would take responsibility for the fledgling institution. The first two colonial colleges, Harvard College and the College of William and Mary, each created two such bodies, but almost all the later institutions settled for one.

From the paucity of qualified scholars, then, came two American innovations: the lay board of trustees and its partner in governance, the president, an office with no analogue in European universities or English colleges. This new office was destined to play an important entrepreneurial role in the freewheeling development of American higher education, especially in the 19th century.

Trustees: Mission Impossible?
We have long outgrown the circumstances that gave rise to these inventions. And the many faculties have come to have considerable power in their own right. But locating ultimate responsibility in a lay board remains the general rule in our colleges and universities. Thus, in any consideration of accountability of these institutions, the role of the board is pivotal.

The tasks of the board have become enormously difficult, for all the familiar reasons: the size and often bewildering complexity of institutions; the multiplicity of institutional missions, especially in the case of the research university or "multiversity"; ever greater demographic diversity; cascading technological change; and constrained resources in all sectors and at all levels. Add the underlying reality that, in the post-industrial information age, higher education has become absolutely central to accomplishing their society, and it is no wonder that established methods of governance have come under stress.

Boards themselves have changed, especially in the state-supported sector. The emergence of great multi-campus systems has created a problem of distance between the board and the programs and activities for which it is accountable. If the board has few members (as public-sector boards generally do), and if it has become politicized (as too many have), the task of guaranteeing the integrity of each constituent campus can become impossible. Because the task appears beyond the capability of the existing governance structure, governors and state legislators are tempted to move in, with disastrous consequences for institutional autonomy. In what may be the extreme case, the community colleges of California, the legislature has reportedly been micro-managing the system for some time. Where board authority has been undercut, or corrupted by its own internal politics, the board can neither effectively demand accountability from the campus faculty and administration nor provide it to the public.

Boards of trustees in private institutions have changed less than those in the public sector, though they are hardly less stressed by the pressures on the institution. It is worth noting that sheer survival is far more often an issue for independent colleges than for those supported by the state. Legislatures may cut budgets, wreaking havoc in public colleges, but the continued existence of the institutions is all but assured by the facts of political life.

Treaties of Nonintervention
As usual in discussing postsecondary education, it is hard to generalize about board performance. Cliches abound. Even when a board meddles ferociously in the running of the college, its members pay abundant lip service to the doctrine that a board may monitor performance but must try to manage. Criticism of boards often focuses on such situations. But deplorable as breaches of the "monitor don't manage" doctrine are, failure to monitor effectively may well be more common and more damaging to the claim that boards can assure accountability. The Association of Governing Boards stated in 1995, "Trustees of private institutions are still too often recruited for their ability to both 'give and get' money - as ambassadors of goodwill and spokesmen for the institution's public interests. They see themselves primarily as volunteers, ready to give good advice and bear witness, but not really prepared for the task of governance."

Higher education has often bridged its gaps by tacit treaties of nonintervention. For example, faculty refrain- from placing heavy academic burdens on undergraduates, and the undergraduates do not object too strenuously if the faculty's primary interest is research and arcane scholarship. In the case of governing boards, the treaty is between the faculty and the president, and it reads: "Well oversee the finances, both incoming and outgoing, and well leave you free to run the academic side~" This has suited the interests of both parties. The board, consisting largely of experienced business people, deals confidently with financial matters, but feels uncomfortable with questions involving the academic disciplines, and is readily satisfied simply to be kept more or less informed about the curriculum. The faculty is pleased to be left free to protect its own interests on the academic side.

But the old division of labor no longer seems feasible in an era of dwindling resources and shrinking budgets and when higher education is being criticized for its laggard performance in restructuring, downsizing, and re-engineering. The main business, even of the most complex multiversity, is academic after all. One can hardly expect the board to cope with the new fiscal urgencies while delegating the management of the academic core of the institution entirely to the faculty. It remains of the utmost importance that regents and trustees refrain from substituting their judgment in academic matters for that of the trained academics who constitute the faculty. But on major questions of resource allocation and planning, the board cannot escape its responsibility and must therefore be involved.

Faculty members are understandably suspicious of attempts to apply techniques developed in the corporate world in academe. Labor-saving technology has rarely been successfully adapted to teaching. Academics often argue this point with the analogy of a symphony orchestra: you can't save money by dropping the third movement of Beethoven's Fifth Symphony or eliminating the oboists and viola players. Faculty especially distrust adapting corporate ideas about efficiency to an enterprise whose "products" are so difficult to assess. While it may be entirely possible to determine how much a student has benefited from a training course in automobile mechanics - how much value has been added - how can one measure the value of a course in, say, ethics, where the benefit may not be apparent until 20 years later? Such arguments may seem dispositive to faculty. But they appear self-serving and (ironically!) obscurantist to business-trained trustees.

A Delicate Balance
It is necessary to step warily when dealing with boards and faculties; emotions can run high on both sides, with the institution's president caught in the middle. The danger is that if boards, presidents, and faculty do not deal with these issues forthrightly, they will either fester or be resolved in an ad hoc fashion, without deliberate decision. A prime example is the proliferation of non-tenure track appointments as a means of saving money and increasing flexibility in the curriculum. Tenure survives, but applies to a steadily shrinking percentage of the teaching workforce.

One need not be an advocate of corporate-style number-crunching in higher education or of making resource-allocation decisions entirely by the resulting numbers to recognize that enrollment statistics, graduation rates, and the like must be taken into account. When it is questioned whether every campus in a multi-campus system must teach every subject from the introductory to the doctoral level, the faculty cannot simply stonewall.

Nor, on the other hand, can trustees undertake much closer supervision of academic planning and management without being better equipped to make sound judgments in academic matters.

The conclusion of the recent Association of Governing Boards/Pew Higher Education Roundtable is probably right: these problems can only be resolved through a collaborative effort involving presidents, faculty leaders, and trustees, carried out steadily over time, not as an exceptional bit of crisis management.

Other Improvements
If boards of trustees or regents are to make this work, attention will have to be paid not only to board members' preparation for participating in academic planning and decision-making but to board composition and methods of appointment. Boards of state-supported institutions generally need to be larger and less political. Six to nine members are too few for coping with the complexities of exercising trustee oversight of academic planning and budgeting. Furthermore, devices designed to screen out patronage appointments and to moderate partisan elections are badly needed in many states. In contrast, some boards of private colleges and universities need to he smaller and less unwieldy. Some need to place less emphasis on collegial comfort and avoiding dissension at all costs, and to place more emphasis on tough policy making.

The campus community, particularly the faculty, needs to be weaned from the view that it is always to their advantage to have the board be as inactive as possible. Board somnolence is not an asset over the long run. If the campus is manifestly not accountable to the board, other and less friendly entities are likely to demand accountability.

The institution's president obviously plays the most important single part in all of this. The president is in the best position to ensure that the board is supplied with enough reliable and candidly stated information. Presidents must resist the temptation to play' the board and the faculty against one another, telling each that the other is the problem.

Only a knowledgeable and completely engaged board has a chance of protecting institutional autonomy against overregulation, whether by public or "voluntary" bodies, carried out in the name of accountability. Sadly, few governing boards now have the structure, expertise, or determination to accomplish this vital task. But their mission is not impossible. Trustees and those who select them can do a better job. Presidents and faculty can begin to collaborate so that all players understand their proper roles in advancing appropriate accountability and enabling boards to accomplish all their vital and interrelated tasks.

TRANSFORMATIONS AND PATHOLOGIES Thirty years ago, just as higher education began its greatest expansion, American faith in the professions was high. As Kenneth Lynn observed in the Fall 1963 pages of Daedalus, the journal of professional intellectuals, "Everything in American life, the professions are triumphant. Thorstein Veblen's sixty-year-old dream of a professionally run society has never been so close to realization." Like many professorial prophecies this one was also doomed.

The Changing Professoriate
Only a few decades ago, professors in research universities were mandarins preparing the new generation of professionals, and as such they occupied positions of prestige unknown to their predecessors and unlikely to be achieved by their successors. This generation of faculty, who came of age after World War H and joined universities in great numbers in the 1960s, experienced their careers at an anomalous time in the history of American higher education. Unlike their predecessors, many of these research university professors found solidarity with others in their disciplines, not primarily with others in their institutions. Their main concern was often with the advancement of knowledge, not with the advancement of their institutions. These university faculties made little progress in diversity of race or gender until the last decade.

The intellectual vitality these professors brought both to their studies and to their institutions contributed powerfully to the eminence and the transformation of America's research universities. Vannevar Bush found in 1940 that ten universities accounted for half of all the research and engineering hinds, and Clark Kerr observed in 1963 that 20 such institutions accounted for half the funds. By 1990,32 institutions accounted for the same proportion of funds. The number of Carnegie-designated research universities is now 125. As the research university became the most influential model for higher education, the culture of academe spread nationwide, with commitment to the profession replacing commitment to the institution. Research-oriented faculty sought their peers in other institutions who were investigating similar questions. Teaching-oriented faculty found peers in their unions, professional associations, and national meetings. Administrators attended innumerable conferences throughout the country, often in Washington, D.C., and participated in myriad organizations with full-time employees who represented higher education in the nation's capital.

Increasingly, the research university professor's time was spent on activities related to the profession, not to the institution. In the standard vocabulary of campuses, teaching was a "load" research an "opportunity:' Professors defined their "work" not as their teaching or their institutional service but rather as their research, as in "When can I get back to my work?" Often, the college or university, which sought to increase its prestige by employing nationally recognized faculty, colluded with such faculty by reducing their teaching assignments and eventually those of other professors. This action suggested that professional identity and research productivity were more important than campus-based activities, such as teaching and counseling undergraduates or participating in the ongoing intellectual life of the institution.

Pathologies of Academic Life
In recent years, many books and articles have made sweeping charges of widespread corruption in higher education, painting a picture of an academic guild that has little interest in teaching and an inappropriate concern for its own perks and privileges. We do not agree with those sweeping attacks; we know many academics, indeed whole institutions, that maintain high standards of scholarly commitment and academic performance. These charges do not take into account the enormous variety of institutions and the equally great variation in their missions and character.

One need not share the apocalyptic views of such critics to acknowledge that there are persistent pathologies in academic life, violations of its own norms and of society's reasonable expectations of colleges and universities. These failings occur, and we agree that they must be corrected.

Derek Bok has sharply criticized the practices of using untrained graduate students to teach undergraduates and of placing foreign teaching fellows with limited English skills directly in the classroom. He further bemoaned the practice of appointing faculty without due regard to their teaching skills and then rarely reviewing the quality of their instruction. Most of all, he condemned the meager attention given to making the learning process more effective.

The relatively light teaching obligations of teachers in research universities are meant to provide research scholars and scientists the time they need to pursue knowledge. For academics actively engaged in research, there is never enough time, and their hours free from teaching are fully engaged. Indeed, these academics ordinarily spend more than 60 hours a week on teaching, research, and the myriad activities that go with a distinguished academic career. But even in the best research universities, many faculty are not doing research or pursuing serious scholarship. Most universities provide people who are not doing much research die same light teaching obligations that are properly accorded active researchers. Academics in such universities do not accept - or are not asked to accept - a balance of teaching and research that reflects what they are actually doing. Universities need to develop a more differentiated distribution of labor that reflects the actual work of its academic staff, one that can vary over time as their interests and energies change.

The chronic difficulty of deleting anything in academia is often cited by business leaders and legislators as evidence that these institutions lack the will and the ability to undertake needed reforms. Higher education enjoyed unbridled growth in the 1960s and 1970s, making it easier to allocate assets. In the 1980s and especially the 1990s, budget cutting has been the trend for many institutions, but we have not yet developed useful methodologies to "downsize:' Often, we cut the "best with the rest" rather than experience the internal turmoil of evaluating each department and applying an overall vision of the institution's future to today's fiscal realities.

Much has been said about the incompatibility of research and teaching or the neglect of teaching by a research-oriented faculty. Research and teaching are not inherently at odds; on the contrary, the close connection between teaching and research has been a source of the preeminence of American research universities throughout the world. Undergraduate education is weaker than it should be, not because of research, but because of the lack of status and attention teaching is given by the academic community. Despite institutional staff development offices and a substantial body of knowledge about improved teaching, few academics use those resources. They are left to graduate students and new appointees. Colleges and universities need to attack these problems by encouraging or requiring faculty to improve their teaching skills and by linking their rewards more closely to their performance in teaching as well as in research.

The quantity and quality of our university research is the envy of the world. But in recent years, claims of scientific fraud have grown. While a few cases receive great attention from legislators and the media, they represent a very small share of the total research effort. Internal policing mechanisms of the scholarly disciplines can apply career-ending penalties to those clearly found to have acted fraudulently in their published research. But the grey area between initial accusation and definitive proof needs more attention and rigor. The evidence, often conflicting, must be carefully examined by competent experts. However, this must not drag on indefinitely. When the process stalls, and institution hesitates to apply appropriate penalties, public trust erodes and is very difficult to restore. Both academics and the academies need to find better ways to police research; leaders of research teams need to take more responsibility (not just credit) for the work of their junior colleagues and for the products of their laboratories and research teams.

A perennial complaint against American higher education is the incoherence of the undergraduate curriculum. Part of this problem lies in the flexibility of the credit/elective system, which has its own substantial merits. The undergraduate curriculum must constantly reflect the explosive growth in knowledge. It must also contend with a lack of consensus in higher education and the greater society on what constitutes an educated person. This can lead to a "logrolling" process among academic departments, which does not produce a first-rate curriculum. Reforms of the undergraduate curriculum may be in order, but our strong view is that they must be made by each institution in light of its own character and mission. Efforts by outside accreditation visiting committees to force curricular changes is one of the most serious criticisms we have beard of the accrediting agencies.

The issues precipitated by the changing professoriate and the pathologies we present are not very susceptible to improvement by forces distant from the academic life of the institution. Rather, they demand that institutions have the means to discover such problems for themselves and the will and the structures to make needed reforms. This depends on candor, honesty, confidentiality, and, above all, the development of an internal culture of self-scrutiny and self-criticism. This must be strengthened in most institutions of higher learning. Herein lies the basis for improved systems of internal accountability.

But we are not content, nor do we believe those outside academe will be content, to state that these internal means should not be subject to external review. We propose a revised system of audits by external experts. The audits would assure all interested parties, within and beyond the campus, that quality education is being provided. These audits should determine that the academic authorities and the faculty effectively operate internal reviews that improve academic quality and actually locate and rectify internal shortcomings.

DUAL HEMISPHERES OF ACCOUNTABILITY
We have already described our understanding of the concept of accountability in higher education, stressing that it has two interrelated components, or hemispheres. In external accountability, there is the obligation of colleges and universities to their supporters, and ultimately to society at large, to provide assurance that they are pursuing their missions faithfully, that they are using their resources honestly and responsibly, and that they are meeting legitimate expectations. In internal accountability, there is the accountability of those within the colleges and universities to one another, which involves not so much the provision of evidence and argument to justify their trust and support, but rather detailed evidence of how they are carrying out their mission, how ell they are performing, what they are doing to assess their own effectiveness and identify where improvement is needed, and what they are doing to make those improvements. External accountability is something like an audit, giving ground for confidence and continued support, while internal accountability is research, inquiry, and analysis by the institution into its own operations, aimed primarily at improvement through investigation and action.

We believe that both hemispheres of accountability are desirable and necessary. Our central question is: how can the forms and practices of external accountability reinforce rather than undermine good internal accountability?

Existing Forms of Accountability
There is no lack of accountability by American colleges and universities to the larger community: it takes many different forms and is addressed to many different audiences. The question is whether these are the right forms.

Current external accountability includes regional accreditation, specialized accreditation, federal regulations covering broad sectors of society (such as employment issues or public health and safety), federal regulations particular to higher education, state and local regulations (also covering broad sectors and those particular to higher education), and state coordinating bodies (which vary considerably among the states). External accountability also includes public reports published by the institutions themselves, consumer guides, quality rankings, ranging from those prepared by academic bodies (e.g., the National Academy of Science) to those prepared by popular magazines (e.g., U.S. News and World Report), and bond ratings produced by specialized organizations in connection with institutional borrowing in financial markets. External accountability is also governed by the economic markets or quasi-markets discussed above, where institutions compete for students, faculty, gifts and private grants, public funds, other research support, and the status that flows from success in all these marketplaces.

Internal accountability also has myriad forms, including oversight of boards of trustees or regents; the work of academic administrators including presidents, chancellors, provosts, and deans; the actions of faculty both as individuals and collectively through committees; and the many internal processes of institutions designed to assure quality as well as fidelity to the institutional mission. These processes include the appointment and review of faculty, the admission and grading of students, the assessment of research and scholarship (where that is within the institutional mission, and which is founded in peer reviews of several types), and ongoing internal reviews of the curriculum, courses, and instruction. This last set of reviews includes collective judgments of departments or faculties in subunits of the institution, student opinion surveys on faculty and courses, efforts toward improved assessment of student learning, and specialized administrative units that assist faculty in reaching and organizing their class work.

America's 3,700 colleges and universities vary not only in what they view as their mission but also in how vigorously they pursue those missions. Put differently, they vary in what they conceive of as "academic excellence" and also in how seriously and successfully they pursue that excellence. Let us emphasize three key points: first, responsibility for the quality of work in a college or university ultimately lies with the faculty and administrators of that institution; second, the maintenance and improvement of that quality rests largely on internal procedures for discovering and correcting weaknesses and failures in the institution and its component parts; and third, the efforts of colleges and universities to improve themselves will be strengthened by a system of external audits of those procedures.

INTERNAL ACCOUNTABILITY
Many internal accountability activities are in the hands of the faculty. Senior academic administrators have the task of monitoring and overseeing the various quality-control activities. Unlike deans and department heads who lead subunits, presidents, academic vice presidents, and provosts have responsibility for the quality of the whole institution. Their efforts toward strengthening and monitoring quality keep those mechanisms alive and functioning. Academic leadership, in large part, entails ensuring that these mechanisms are functioning as they ought and are not captured by the communities they nominally regulate.

These mechanisms of quality maintenance in universities are largely invisible to outsiders and require a large measure of trust on the part of the supporting society. Even when the rules and procedures are public knowledge, the operation of those procedures often rests on professional or expert judgments that are arcane or obscure in nature. In the best institutions, much time and energy is spent trying to insulate the crucial acts of judgment - with respect both to staff and students - from any biases, which cumulatively could affect the quality of teaching and research. But not all universities, departments, or academics maintain the highest performance standards or the best quality-control mechanisms. This partly accounts for the sheer number and variety of these mechanisms.

Toward Better Teaching
An external academic audit should review an institution's procedures for dealing with difficult cases of faculty failure. Solutions to some kinds of failures by teachers may be beyond the reach of "instructional improvement" and may require personal counseling, a leave of absence, and in extreme cases, separation from the university. There may be other responses open to the institution through its health and psychiatric services. These rare events are among the most difficult and delicate problems facing colleges and universities. But it is not kind to either the teacher or the students to turn a blind eye on the problem.

Poor teaching needs to be identified if it is to be addressed. Students and colleagues may help in identifying it, but they are less helpful in doing anything about it. On that score, there is no substitute for strong academic administrators, department chairpersons, or deans. They have the broader responsibility and can act in the name of the institution. Academic authority, wherever it is located, justifies itself in part by finding ways to encourage liveliness, innovation, and creativity in teaching, in taking steps to recreate it where it has declined, and in acting decisively in the rare event it is required. All parties must be compassionate, but they also must consider the interests of the students, who may find themselves forced to study under teachers who may be doing them more harm than good.

Academic audits administered by an external accrediting agency can strengthen academic authority internally by insisting that it show evidence of a culture of inquiry and self-criticism, one that leads to action toward a stronger and more effective institution.

Internal Reviews
The two hemispheres of accountability address two quite different aspects of higher education. Internal accountability should be focused on learning and improving. It should address the question: Is the work in the institution up to its own standards? In the United States, those standards vary substantially, intentionally so, among different kinds of institutions, even within the same class or category of institution. This variability is the essence of American higher education and major source of its strength.

Each institution projects an idea of its goals and missions, how it will pursue them, and what standard of performance it will try to achieve or surpass. Internal reviews are central to an institution's efforts to sustain that standard by subjecting its own processes to critical examination. The aim of self-evaluation by a college or university is to learn what is going on in its own departments, laboratories, and classrooms, and then to try to improve the quality of that work on the basis of what has been learned.

External accountability has been focused on explanation and justification. Evaluation in this realm demonstrates to outsiders - usually elected officials and government administrators or private donors - that what is going on inside the institution is worthy of their support. It demonstrates that the institution is using its public and private funds appropriately and effectively. Such outsiders are almost never competent at evaluating teaching and research inside the institution. If the essence of internal evaluation is discovery (what is going on and how it can be improved), then the essence of external evaluation is persuasion (convincing outsiders that the institution deserves support).

The dissociation between these two kinds of assessment - the fact that they are conducted in different ways, answer to different criteria, and produce different kinds of evidence and arguments -leads to a lack of trust by outside authorities regarding the institution. Where trust is high, assessments based on what the institution learns about its own operations can also serve to legitimize and persuade, with the persuasion embedded in the trust. By contrast, where trust is low, the necessity for persuasion is high, since the internal evidence is not accepted outside as an adequate description of reality.

Why is it so important to keep these two kinds of assessments distinct? Because there is a danger that over time the criteria an institution uses to assess itself for external authorities will become the criteria by which it judges itself. For the most part, those criteria are the wrong ones to use - simplified and often simply Else statements about institutional outcomes and products that cannot be verified. If taken seriously and internalized, these claims of efficacy and efficiency would distort the institution and divert it from improvements.

Assessments of departments and schools aimed at improvement rather than justification must be chiefly internal and carried out by academics and academic administrators within the college or university who are close to the department in question. They can be supplemented by visiting academics, experts, and practitioners who are also committed to the welfare of the institution rather than some external agency or budget office.

Elements of Internal Accountability
Given the diversity of colleges and universities, there is danger in recommending a one-size-fits-all policy of accountability in higher education. Nevertheless, our study and experience suggest a number of elements common to most effective systems of internal review. The crucial factor in academic improvement lies in the creation of an institutional culture marked by self-criticism, openness to criticism by others, and a commitment to improving practice. The institution must conduct regular and routine reviews of every teaching and research unit every five or seven years. Routinization of reviews removes any suspicion or stigma that might attach to units "under review." Review committees should be appointed by an academic administrator and be composed chiefly of members from other parts of the institution who are competent to assess the quality of the work of the unit under review. Such reviews may involve people from outside to provide additional disciplinary or technical competence when needed. Reviews should begin with a self-study centered on exploring the unit's weaknesses and plans for improvement, rather than on providing a persuasive justification for its existence, practice, and budget. Reviews need to explore the unit's own sense of its mission and standards of excellence and may include other relevant information, such as rankings by external agencies, records of employment of graduates, etc.

Reviews should aim to help and support the unit; they should be primarily diagnostic. Of course, the unit's successes, failures, and overall performance should be judged. Reports by the review committees may not be directly linked to budget, though over time, they will provide central administration with information helpful in making budgetary decisions. Reports should be held initially in strict confidence by the recipients, be they members of a review committee and senior academic administrators or a senate committee (where that is the practice). But the review process and report content should later be available to the external audit group, as we propose below. The value of such reviews depends heavily on the candor and truthfulness with which the unit explores its own work and identifies areas of improvement. A climate of candor and self-criticism will exist only if the review process does not unfairly punish the unit for pointing out its own weaknesses.

Administrative officers in extreme cases should take a weak or paralyzed department into receivership by bringing in a chairman from outside the department and giving him or her extraordinary powers. Recurrent departmental reviews, where they are done well, can be effective both in motivating departments to review their own operations and in giving them useful advice and criticism. At the same time, they provide administrative officers with the kind of detailed knowledge necessary to make budgetary decisions. If internal assessments of an institution, its departments, and its research centers are to be more accurate and fruitful than those done by outside accreditors, it is necessary that they be done well and that the institution subject itself and its units to serious and recurrent internal review, with real consequences. The loss of institutional autonomy is both cause and consequence of the abdication of responsibility by colleges and universities for managing their own affairs, namely, maintaining high-quality teaching and research.

Audits Rather Than Assessments
We propose that the institution-wide external reviews by private accreditation agencies adopt the form of an audit of the internal review procedures. Private accreditation plays a vital role as a counterpoint to government regulation and as a protection against political interference and attacks on academic freedom. However, its present form tends to set the two hemispheres against one another. The serious and candid internal reviews that we propose simply will not emerge from the current process that asks that an institution show its best face to skeptical outsiders.

What could external accrediting bodies do that would strengthen rather than undercut an institution's efforts at monitoring and improving its own practice? Our answer is to urge institution-wide accrediting bodies to transform themselves from organizations that purport to accredit the "quality" of the institution into bodies that determine whether the institution has in place procedures and practices that enable it to learn about itself, its weaknesses as well as its strengths, and to use that knowledge to address those weaknesses. They would be changed from bodies that review and advise institutions to bodies that audit the institution's own quality-control policies and procedures and the institution's own internal improvement efforts.

The effort now applied to self-study documents and external review visits would be more productively applied to the kind of internal reviews described above and to an external visiting team, charged with determining that sound internal review processes are in place and producing concrete results. All the internal reviews in the world are useless if they do not change the academic life of the institution for the better. There is always room to improve the quality of education, so long as the diversity of institutional missions is respected.

We have discussed the strengths and weaknesses of our private, voluntary accreditation system with experts across the country, reviewed considerable writing on the subject, met with federal officials in the legislative and executive branches, followed the efforts of the National Policy Board on Higher Education Institutional Accreditation, and explored the issues among ourselves.

Accreditation as we have known it is clearly in flux. The legislative and regulatory environment is shifting, and efforts continue within the higher education community to consider and then to erect a new system.

The current institutional accreditation process has the potential to intrude on institutional autonomy and is unlikely to induce real improvements in academic programs. At its worst, the current accreditation of colleges and universities is an odd combination of arrogant intervention and irrelevant ritualism. Even at its best, current accreditation encourages self-justification rather than self-critical candor by the institution under review. Virtually all strong and large institutions enter the process with absolutely no expectation that their accreditation can be removed. Smaller and more unconventional institutions are more vulnerable to the threat of withdrawal and can be inappropriately pressed to alter their legitimate missions. The advice offered by knowledgeable peers after a brief and often hectic visit varies in quality. We are disturbed by reports that this "advice" is sometimespressed upon the unwilling institution in a coercive way.

Financial auditing is analogous to our proposed system: external financial auditing bodies chiefly serve to advise other external interested parties about the soundness of an institution's financial procedures and about the effect of those procedures on institutional finances. A financial audit ordinarily does not tell the institution what business it should be in, what its range of products should be, or whether its marketing division is effective. A financial audit describes how well the institution is looking after its own financial condition, including how much it knows about its own financial processes, how well it addresses serious financial irregularities, and how well it is protected against theft and fraud. Audits are useful safeguards, but they are no substitute for the proper management of any organization, be it a college or a corporation.

This analogy is only an analogy; the intellectual life of a college or university may rest on its financial probity, but it is much more complex than its finances. The forms of an academic audit by an accrediting agency, as distinct from their current review practices, still have to be worked out.

However, it would at least differ by focusing chiefly on the institution's own procedures for learning about and addressing its academic weaknesses. That focus, we believe, lies within the competence of external committees. The process would still start with an institutional self-study, which would detail the institutional quality-control and improvement procedures. Every five or ten years, the institution would be asked to report evidence that it has developed a culture of self-scrutiny and self-improvement and how it has done so. Approaches of institutions will vary with their character and missions, though some uniformity must be adapted by the accreditation bodies, which also could also play a role in improving methods of internal accountability for all institutions.

On the whole, we believe, as do many others, that the American system of higher education is the best in the world. But we also believe that many, perhaps most, colleges and universities do not attend adequately to the quality of their own work. Institutions can and should be encouraged to improve their capacity to discover and remedy their own weaknesses. Audits of accrediting bodies can provide that encouragement. Moreover, we believe these audits can be as tough and searching as good external financial audits. An institution can worry less about encroachments on its autonomy if the accrediting agency is not asking about its mission and governance, but about its capacity to study itself and improve itself on the basis of what it learns. Egregious and persistent failures to meet those tests should be met with the ultimate sanction of withdrawal of accreditation.

The issue, then, is what should be the nature of the relationship between a college and an accrediting agency. Audits, in our view, are greatly superior to accreditation reviews. While they focus on strengthening the institution's own efforts, they also can serve the external accountability function, attesting to outside agencies, not least the federal government, that the college or university in question is worthy of support, for example, financial aid to students. In academic audits, as we have described them, the two distinct functions - of supporting institutions while also judging them and reporting those judgments to outsiders - would not be at odds with each other, but would be compatible. This inspires our strong recommendation for the replacement of the current accreditation reviews with audits of the institution's own quality-control procedures and activities.

There are problems with replacing reviews and advice-giving with academic audits as the main function of these revamped accrediting bodies. The chief problem, in our view, is the tendency for what a European scholar has called "epistemic drift," the propensity of institutions of all kinds to modify their character in response to social rewards and temptations. The academic community would have to be alert to this and to guard against audits reverting to the old habit of telling institutions how to improve themselves. A new constitution for these agencies must be dear enough to discourage that drift of function.

We urge a return to the heart of the matter how to improve the quality of education found in our colleges and universities, while making those institutions more accountable to their external constituencies and internal participants. Current discussions in America about accountability of higher education have centered on external rather than internal accountability. That is ironic because we may have more external accountability than we need (though not all of it of the right kind), whereas many institutions have inadequate systems of internal accountability.

NEW SYSTEMS OF ACCOUNTABILITY
As we near the end of this century, the national mood toward higher education is shifting from demands to enlarge research and enrollment to demands to preserve and document institutional effectiveness. Taxpayers, legislators, executive branch officials, donors, students, and parents all want to be assured that colleges or universities are providing a good education. They seek evidence that this is so, and they are dissatisfied with the evidence they are now seeing.

Specialized Accreditation
The landscape has become littered with new investigations aimed at providing that evidence and assurance. The U.S. Department of Education now recognizes more than 80 accrediting bodies; most of them specialized in one field or discipline. We support continuation and strengthening of Institution-wide, voluntary accreditation by peers as the principal means of external accountability.

But we are troubled by the views of our expert advisors and by our own observations regarding the work of the specialized accrediting groups. Some experts advised us that they would not mourn the passing of these specialized agencies, although we consider this outcome entirely unlikely. Most specialized agencies are tied to specific professional programs, such as law, business, social work, or teacher education. They set standards for programs and visit campuses to see if the standards are met. The processes are frequently dominated by professors of those disciplines, outsiders who too often show greater concern for salaries and other perquisites than for evidence of effective education. It was this attitude that led to the 1995 U.S. Justice Department action limiting the power of American Bar Association accreditation review teams to raise faculty salaries through the accreditation of law schools. The extraordinary intervention of the justice Department signals serious problems with the present forms of specialized accreditation.

If specialized accreditation is to continue, it should shift its activities to strengthened internal reviews focused on learning. These reviews could be audited by external peers, including scholars, practitioners, and clients. In addition, these specialized reviews could feed into the general reviews of the whole institution, so long as they do not unduly distort its overall mission. Graduates of specialized programs could be assessed by their various professions, as now occurs with lawyers and bar exams, doctors and medical boards, and teachers and certification.

The unit of analysis for accreditation should be the institution itself, not some separately designated program, school, or department. The responsibility for the institution lies with its faculty, administration, and board. They must consider the overall well-being of the institution, not just some part or unit of it.

The Accountability Matrix
The present accountability matrix is so complex and redundant that it appears about to collapse under its own weight. (The Council on Postsecondary Accreditation has already done so.) This matrix includes a system of regional accrediting associations, specialized accrediting associations, state legislatures seeking surveillance over institutions, the federal government "recognizing" the accreditors and private groups attempting to "certify" the accreditors, federal regulations, financial audits, rating systems, institutional publications, bond ratings, and multiple market forces, plus the essential monitoring of its own activities that institutions must assume themselves. This enormous and unwieldy apparatus produces unsatisfactory results as well as demands for still more accountability. An additive solution would produce even worse results. We need a simpler solution that would strengthen learning and improve public assurances.

Our principal proposal for reform is to strengthen internal accountability while shifting the focus of institutional accreditation towards external audits. We have also put forward in this essay many ideas for modifying boards of trustees, for reducing regulatory burdens, and for strengthening teaching. In sum, our proposals and recommendations would reduce redundancy, simplify the process, clarify roles and responsibilities, and provide better public assurances. But most of all, they would focus on improving teaching and learning, the central and unifying mission of all higher education.

To accomplish such aims, we urge the establishment of five fundamental principles of accountability. If generally accepted and adopted, these principles could maintain our unquestioned strengths in research and access, and at the same time, assure and improve the educational quality of institutions.

PRINCIPLES OF ACCOUNTABILITY
PRINCIPLE l: External accountability must reinforce internal accountability.
As we have argued, direct efforts by external investigators to assess or measure academic performance are fraught with danger. Either they may damage the very processes under review, or they may cause the academic community to substitute meeting the expressed needs of the regulators for meeting the real needs of students, the beneficiaries of research, and the learning public. This remains true no matter how much a concern for learning outcomes may have replaced monitoring of performance based on inputs, such as the number of volumes in the library or the number of Ph.D.s on the staff.

There is a vast difference between an educational institution that monitors its own performance effectively and one that does not. Institutional self-knowledge is crucial, and it is woefully inadequate in too many colleges and universities. A determination to act on the basis of such knowledge is uneven at best; no profession instinctively loves either self-monitoring or self-improvement when these involve changes to familiar and comfortable arrangements. These circumstances win not be altered simply because measurement of some academic outcomes has improved and may improve further.

The fact remains that meeting the demand for accountability is in the self-interest of any college or university. This understanding does not come about naturally or automatically within the campus community. It is the task of leadership, particularly presidential leadership, to promote it. Such understanding will be needed if external reviews are to be focused, as we urge, on assuring the presence and the effective functioning of internal mechanisms of accountability, rather than on direct assessment of institutional performance by external reviewers.

Assuring the presence of effective internal processes through external audit provides the best hope of achieving that balance between institutional autonomy and public responsibility that true accountability requires.

PRINCIPLE 2: "Do no harm."
This ancient precept applies with particular force to policy aimed at establishing the accountability of higher education. Few would argue that the present function of specialized accreditation meets this test and even fewer that regulation by government does.

Taken from the Hippocratic Oath, the medical profession's most venerable set of precepts, this is perhaps the most oft-cited principle for policymakers. Clark Kerr reminds us that a quarter-century ago, Eric Ashby, vice chancellor of Cambridge University, proposed a Hippocratic Oath for professors. Perhaps this idea should be revisited.

Be it understood, however: "Do no harm" does not mean or imply, "Whatever you do, don't disturb the status quo." Harm to social institutions results as often from passivity in the face of change as it does from hyperactivity.

PRINCIPLE 3: Respect diversity.
Among the chief reasons for establishing "Do no harm" as principle of a