Before I get into this, a disclosure: I am what I'd call an "accreditation apologist." I started my career in higher education at an accreditor, have had the opportunity to work for two, and have spent years collaborating with and learning from many others. I like accreditation. Not uncritically, but genuinely. I've seen what it can do for an institution when it's working well, and I believe it can be a real driver of innovation and improvement rather than just a compliance hurdle.

Now that being said, accreditation is overdue for an honest national conversation—one that deals in real incentives, real data, and real governance constraints. So yes: a negotiated rulemaking on accreditation could be a productive venue.

But the framing we’re getting, specifically from the April 23, 2025 executive order and the Department’s January 26, 2026 call for an “Accreditation, Innovation, and Modernization” (AIM) negotiating committee, doesn’t read like a good-faith attempt to understand how accreditation actually functions. It reads like a policy agenda built on selective examples, flattened assumptions, and a surprisingly persistent misunderstanding of the system it’s trying to “fix.”

Start with the executive order's opening premise: accreditors are the "gatekeepers" of federal aid. That's politically punchy. . . and incomplete. Yes, accreditation is a necessary condition for Title IV eligibility in most cases, and ED recognizes accreditors as "reliable authorities" on educational quality. But accreditors don't actually control the money. They confirm to ED that an institution meets accreditation standards, one of many requirements an institution must satisfy before it can administer federal aid. ED still makes the eligibility determination. States still have their own authorization requirements. That's the work of the Triad: states, accreditors, and ED each play distinct roles in a system of shared oversight of higher education. When we flatten that into a single lever called "accreditors," we guarantee bad diagnoses, and worse prescriptions. The executive order leads with that flattening, and the AIM committee scope follows from it.

Now zoom to the AIM committee scope. ED says it wants to: simplify recognition (including for “emerging” accreditors), examine credential inflation, guard against trade association influence, eliminate standards it views as discriminatory, and refocus accreditation on “data-driven student outcomes.” It will meet for two five-day sessions in April and May 2026. This is not subtle: the rulemaking agenda is an implementation pipeline for the executive order’s “student-oriented accreditation” principles—right down to the language about credential inflation and outcomes metrics.

So what’s the problem?

The problem is not the idea that outcomes matter. The problem is the willful simplification embedded in the premise that accreditors are primarily busy “compelling” ideological initiatives rather than doing quality assurance—and that the fix is to federalize a narrow definition of “good” outcomes and call it reform.  In the institutional accreditation lane, much of what the EO implies simply isn’t an accurate description of how review standards operate in practice. One example: the Higher Learning Commission has publicly stated its standards require compliance with applicable laws and do not mandate DEI training, programming, or curriculum requirements. You can argue with whether institutions should do those things - but that’s different from claiming an institutional accreditor is forcing them.

And while we’re clearing up misunderstandings:  the term "regional accreditor" is dead in federal recognition. ED eliminated the regional/national distinction in 2019 and has been pushing back on the language ever since, citing transfer credit barriers and licensure confusion. The accreditors themselves stopped using it. The problem is that "regionally accredited" is still embedded in institutional websites, state licensure regulations, transfer policies, and vendor materials across the country. And now ED is treating the persistence of that language as an accreditor problem. . . which is not accurate. The real holdouts are in state statute and institutional policy, places where ED has much less leverage and, it seems, much less urgency to do the harder work.

If we want accreditation reform that improves quality without turning peer review into a partisan enforcement mechanism, the AIM sessions in April and May are worth your time. Or at least your attention. Watch what negotiators mean by "data-driven student outcomes" and who's defining the metrics. Ask what gets measured and what gets quietly left off the table. Ask who benefits when "credential inflation" becomes an accreditor compliance target. Ask how "streamlining" recognition affects gatekeeping against low-quality providers.

And pay attention to what ED doesn't say. In negotiated rulemaking, the silences are often as informative as the proposals.  What questions get deflected, which stakeholder concerns get acknowledged versus noted-and-moved-past, and whether the negotiating text that emerges actually reflects the conversation that happened in the room. If the AIM process is genuinely open to being shaped by negotiators, that will be visible. If it's an implementation pipeline for a predetermined agenda, that will be visible too.