Dr. Peter Smith has penned a second instalment in his series on the “Gainful Employment” ruling. I’ve reposted it below, with Peter’s permission. 

The first instalment can be found here. My interview with Dr. Smith is available here

Degree Qualifications Framework: The Academic Quality Solution that Gainful Employment Fails to Achieve, by Peter Smith

As Frank Donahue pointed out in his Chronicle of Higher Education article on June 21, the newly released Gainful Employment regulation is an indirect assessment of higher education quality presented as consumer protection. And, problematically, it is narrow in scope, defining quality as the ability to get and hold a job in the field you have degreed in.

The rule is poorly conceived. (See my preceding blog posting.) It holds the institutions in question accountable for something they do not control – employment – while giving them a pass on something they do control – quality. This leaves untouched a golden opportunity for the country’s regionally accredited institutions, the regional accreditation associations, and the Council for Higher Education Accreditation. That is, to put transparent, institutionally-defined academic quality and continuous improvement at the heart of the accreditation process.
As we enter the age of mass, lifelong higher education, academic quality will be defined by a transparency to learning outcomes that are assessed through a consistent, reliable, and valid process. At the heart of the process will be learning outcomes at the course and program level that are tied to rubrics for assessment internally as well as external standards for validation. This type of a process has three great advantages.
  • First, by focusing on learning outcomes and their assessment, it leaves the teaching/learning modality wide open, protecting a diversity of approaches to teaching and learning.
  • Second, it would require institutions to make clear claims about what their learners know and are able to do and also link those claims to credible third party standards. This would, in turn, allow for third party audits of the learning outcomes and institutional claims. This links the institution’s reputation to its academic practices and the achievement of learning outcomes by its students.
  • Third, it leaves the design of the outcomes, rubrics, et. al. at the institutional level, making the college accountable for disclosing how it is doing its academic business, how well it is doing that business, and what the quality assurance/continuous improvement process is that assures it.
Hence it is decentralized, accountable, and metric-driven within the on-going accreditation cycle. As decentralized as it is, however, it needs a flywheel, organizing coherence. We need to develop a consistent framework for the articulation of degree and certificate programs. It does not have to be uniform, raising the specter  of “one size fits all”. It does, however, have to be consistent, using common language, definitions, assumptions, and processes.
Enter the Lumina Foundation, with its “Degree Qualifications Framework” project. This conversation, including a wide variety of institutions from all regions, holds the promise of doing what Gainful Employment has not done, establishing a rough consensus on how to establish and evaluate consistent academic quality using one of the best traditions of higher education, institutional continuous improvement and accreditation. By focusing on learning outcomes connected to external standards and emphasizing institutional responsibility, the degree qualifications framework project shifts the focus from where and how the learning occurred to how much has been learned and how well it has been learned. While promoting the quality agenda, the project also shifts the conversation away from credit hours and towards learning achieved, thus raising the possibility of a more efficient degree attainment process requiring less time and money to attain the degree (see KNEXT.com as one example).
These elements – transparency, outcomes, continuous improvement, and external evaluation – are the keys to organizing the rapidly-changing landscape that surrounds and suffuses American higher education today. And rather than depending on a top-down regulatory approach, it promotes decentralized accountability tied to academic performance. That is a good thing. Colleges should be accountable for what they control: academic quality.


  1. As always, Peter makes the apparently complicated simple to address. Some of us can remember visiting academics from other institutions giving positive as well as critical advice, who would not fudge issues as their personal reputations were also at stake. Costs were shared as the visitor would in turn be visited. Allied with clearer graduate destination data, this could be an understandable AND creditable bench mark. However, the cynic in me fears the vested interests of ‘professionals’ in accreditation organisations, colleges wanting to ‘spin’ their way out of trouble, and good old inertia. Thanks for this Keith, Peter identifies that the real problem is not one of several possible solutions, but possibly one of will.


  2. Thanks for the comments, Paul. Certainly I see the opportunity for institutions to act defensively and “spin” their way out of bad assessments. Hard to avoid in any system, I imagine.
    My initial reaction to the gainful employment concept, as it is being framed in the US context, is that, first, it strikes me as a political response to criticism from the tax-base. Those that are charged with regulating the institutions do not want to be in the position of explaining why tax revenues are going toward educating people that are unable to pay back their (tax-payer funded) student loans. As you know, this became something of a hot topic in early 2011.
    Second, the gainful employment regulatory model will be harder to satisfy for those schools that cater to lower economic classes – such as, and in particular, those that attend for-profit schools. Again, most of the criticism that emerged in early 2011 was directed at for-profits whose students pay relatively high fees (primarily due to lack of state funds supporting the schools) and who often have the weakest capacity for obtaining high-paying jobs upon graduation (due to their lower academic abilities, etc).
    Peter Smith understands these issues as well as anybody – and it is for this reason, that I have been republishing his work on this site. While I’m not a policy wonk, I know enough about these issues to know that the long-term implications of these debates are significant.


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