The Honorable Nicholas Kent
Under Secretary
U.S. Department of Education
400 Maryland Avenue, SW
Washington, DC 20202
Via: Public Comment Portal www.regulations.gov/document/ED-2025-OPE-1042-0002
Dear Under Secretary Kent:
The Northwest Commission on Colleges and Universities (NWCCU) – soon to be Northlight, appreciates the opportunity to comment on the U.S. Department of Education’s (Department’s) proposal to amend the regulations identified as Accreditation, Innovation, and Modernization (AIM): The Secretary’s Recognition of Accrediting Agencies: Institutional Eligibility Under the Higher Education Act of 1965, as published in the Federal Register via Docket ID ED-2025-OPE-1042 on August 20, 2026.
NWCCU was founded in 1917 as a voluntary, nongovernmental organization for the improvement of educational institutions, and has been continuously recognized by the U.S. Department of Education since 1952. We accredit a diverse membership of public community and technical colleges, four-year colleges and universities, tribal colleges, faith-based institutions, private institutions, and health-professions- or technology-focused institutions. As you know, our recent name change reflects a broader shift away from a regional identity as we continue to serve institutions on the basis of assessment of quality and student success rather than geography. We were recently re-recognized by the Department. Throughout the negotiated rulemaking process, we monitored the discussions closely while simultaneously revising our own Standards for Accreditation, and we believe our updated Standards leave us well-aligned with the expectations reflected in the proposed regulations.
Our membership has told us directly that our Standards make a difference: 91% of responding institutions reported that NWCCU Standards had significantly or somewhat improved their efforts to improve institutional effectiveness; 77% reported that the Standards contributed to increased student achievement data and transparency; and 74% reported that the Standards had a positive impact on student learning. We share this data because it informs the perspective behind the comments below.
We would also like to highlight our recent partnership with the National Accreditation Commission (NAC) as part of the Workforce Trust, which offers an innovative artificial intelligence (AI) driven system (AI Hub) that drives quality assurance for workforce training programs. We were the first institutional accreditor to publicly acknowledge and approve accelerated or reduced credit bachelor’s degrees and have implemented a process that is efficient and does not come at an additional cost to our member institutions. This work demonstrates that accreditation can support innovation and reduce institutional burden while maintaining quality assurance.
In addition to our own comments in response to the NPRM, we support the comments submitted by the Council for Higher Education Accreditation (CHEA).
Points of General Agreement
We support the Department’s overarching goals for AIM: modernizing accreditation processes; sharpening the focus on student outcomes, including lowering student debt, improving graduates’ access to living-wage employment, strengthening transfer of credit, and enhancing student protections; and welcoming new accreditors into the space to spark new approaches. We also support the reduced list of substantive change categories, which still allows for meaningful review of institutional quality and resources while reducing accreditation cost and burden for institutions.
602.24(e) & 668.43(a)(11) Transfer of Credit: We support the Department’s approach to more effectively facilitate transfer of credit. We recognize, however, that this change will require institutions to invest additional time and cost to review credit that may not previously have fallen under their transfer policies, determine whether it now does, and document and provide written rationale on earlier timelines for every transfer credit decision that results in denial. We ask that the Department account for this transition cost as it finalizes this provision, and to provide a reasonable implementation period and flexibility for institutions to develop the processes necessary to meet these new requirements.
Points of Concern
602.16(a)(1) & 602.17(a) Bright-Line Standards and Institutional Mission: Evaluating institutions in the context of their individual missions is central to accreditation, which is why we are concerned about the shift from requiring accreditors to “set forth clear expectations” to requiring them to “establish requirements.” A one-size-fits-all, bright-line approach to setting requirements risks displacing the mission-based review that allows accreditors to evaluate institutions fairly across very different institutional types.
We are specifically concerned about the impact of labor-market-outcome requirements and related analyses on tribal institutions within our membership. These institutions serve student populations that are often not well reflected in state labor market data, and requirements built around that data risk penalizing institutions for a data gap rather than for institutional quality.
602.17(a)(1)(E) Education and Economic Returns Analysis: This provision would require the agency to independently review education and economic returns aligned to a program’s credential level, length, and occupational context relative to the total cost of attendance. This review appears duplicative of work already performed by the institution and the state, particularly in the many cases where the federal government, the state, and the institution already partner to secure and analyze reliable data.
602.17 & 602.23 Enforcement of Federal and State Law: Accreditors should not be positioned as enforcement bodies for federal or state law; that responsibility should remain with federal and state authorities. Our own academic freedom and freedom of expression standards already create the conditions for dynamic campus environments, and we do not believe new measures on viewpoint diversity, or a requirement that accreditors determine which viewpoints are unlawful, are necessary or appropriate.
602.16 and 602.17 Duplication of Institutional and State Analysis: Many of the proposed changes in these sections would require accreditors to conduct separate, independent analyses of the sufficiency of institutional resources, the administration of student aid, the costs and benefits of institutional resources, and student achievement outcomes in academic programs. As a member of the Triad, we believe the more appropriate role for accreditors is to review the analyses that institutions and, often, states have already conducted with deeper resources and fuller context, and to ensure those analyses are being performed and appropriately used, rather than to replace them.
602.15(e)(2) Agency Governance and Decision-Making: This provision would require that an accreditor’s decision-making body have no employment relationship with member institutions. NWCCU has recently expanded its public membership beyond what is required, and we rely on the collective expertise of our Commissioners, including those with institutional experience, to develop and approve effective policies and Standards that ensure rigorous, quality evaluation. Existing conflict-of-interest policies already protect the agency from biased accreditation decisions, and we ask the Department to reconsider this requirement in light of those existing safeguards.
Provisions Warranting Clarification
602.15(d) Common Templates and Forms: We ask the Department to clarify that language permitting agencies to cooperate with the Department and other accreditors on common templates and forms is not intended to be, and should not be construed as, an antitrust violation.
As a final point, we want to share our support for the Department’s efforts to streamline an institution’s ability to change accreditors. We believe strongly in an institution’s ability to work with accreditors that support the fulfillment of their mission. Institutions should have the opportunity to move more seamlessly from an accreditor that is not supporting their mission to one that will. We also support the Department’s efforts to streamline the process for new accreditors. We recognize that new accreditors will support greater innovation and opportunities for all institutional accreditors.
NWCCU appreciates the opportunity to comment on these proposed regulations and welcomes the chance to discuss any of these points further. Please contact me at president@nwccu.org if we can provide any additional information.
Sincerely,
Selena M. Grace
President
