What Colleges and Universities Are Facing as Accreditation Changes Unfold

If you work in accreditation, institutional effectiveness, or higher education leadership right now, you probably do not need anyone to tell you that the ground is shifting and the pendulum is swinging.

The U.S. Department of Education's August 2026 Notice of Proposed Rulemaking on Accreditation, Innovation, and Modernization (91 FR 53940) could, if finalized, significantly change how accreditors are recognized, how institutions demonstrate quality, and how much choice institutions have among accrediting agencies.

At the same time, colleges and universities are navigating state-level policy changes, increased political scrutiny, financial pressures, enrollment challenges, and growing public questions about the value of a college degree. All these components together feel like much more than another regulatory cycle. This will impact everyone, not just those in higher education.

I have been thinking about what all of this means for institutions beyond the language of the proposed rule itself. What will leaders need to do differently? What should institutions be preparing now? How and when must we resist the temptation to overreact before we know what the final requirements will be? When there are significant changes to anything we are used to, it is easier to overreact than to patiently wait; we want to get ahead of the curve. There is still considerable uncertainty, but uncertainty does not mean we cannot prepare, we just need to be smart in the way in which we do it.

A Changing Relationship Between Institutions and Accreditors

The proposed federal rule touches nearly every part of the accreditation relationship. Among its more significant provisions are an increased emphasis on student outcomes, including return on investment and wage data; easier pathways for institutions to change accreditors and for new accreditors to enter the market; new expectations involving academic freedom and intellectual diversity; changes related to faculty staffing and evaluation; and tighter independence requirements for accrediting agencies themselves. There is a lot for institutions to consider.

The immediate challenge is that these are still proposed rules. They are subject to public comment, the final language may change, and legal challenges are certainly possible. This makes it difficult for institutions to decide what actions need to be taken now and what they can wait for until the final regulation is published. In my professional opinion, it is essential to focus on readiness rather than compliance.

This is probably not the time to create entirely new systems around requirements that have not been finalized. However, it is absolutely an appropriate time to examine whether your existing systems can answer the questions that are increasingly being asked about quality, outcomes, cost, and value. This isn't something the federal government should have to tell us as leaders to do, as we should already be concentrating on these important elements.

The institutions I worry about least are not necessarily the ones trying to predict every regulatory change. They are the ones that already know their data, understand their improvement processes, and can explain why their programs provide value. These components are just part of their academic culture, not something that must be added on.

Outcomes, Return on Investment, and the Data Challenge

In my perspective, one of the most consequential shifts is the growing expectation that accreditation decisions be grounded more explicitly in demonstrated student outcomes, including employment, earnings, debt, and return on investment.

For many institutions, this presents a very practical problem: our systems were not necessarily built to answer those questions. Or, if there are these capabilities at the institutional level, there is a lack of data to support these efforts.

Institutions may have strong enrollment reports, retention dashboards, graduation data, and assessment systems while still struggling to follow students beyond completion. Data may live across multiple offices and systems that do not communicate with one another. Small programs may have cohorts that make wage data difficult to interpret. There are also legitimate questions about whether salary alone adequately captures the value of professions such as teaching and other forms of public service.

These are not reasons to dismiss outcomes data. They are reasons to become more thoughtful about it. Before institutions rush to create another dashboard, I would start with some fairly basic questions including: What do we already know about our students and completers? What don't we know? Where does the information live? Are we actually using what we collect? If not, how can we make this part of our process?

Those questions matter regardless of what ultimately appears in the final regulation.

More Choice in Accreditors Also Means Added Responsibility

If the accreditation landscape becomes more competitive, institutions may eventually have choices that would have been difficult to imagine even a few years ago.

Greater choice can certainly create opportunities. It may encourage innovation, reduce unnecessary barriers, and allow institutions to consider whether their accreditor continues to align with their mission and needs. Changing accreditors is not simply an administrative decision but can impact the entire way an institution enrolls candidates, functions fiscally, and assesses student outcomes.

These decisions can also affect federal financial aid, state authorization, specialized and programmatic accreditation, institutional reputation, transfer relationships, and numerous other systems. It also raises questions about how institutions will determine whether one accreditor is truly a better fit than another. For many presidents, chancellors, boards, and senior leadership teams, this may be an entirely new type of governance conversation.

That means institutions should begin thinking about the criteria they would use before they are faced with a decision. They should be thinking about the larger picture: What would matter most, cost? Mission alignment? Outcomes expectations? Review cycles? Institutional flexibility? Reputation? Student protections?

More choice is valuable only when institutions have a thoughtful way to evaluate the choices available to them. Additionally, these decisions need to be part of a longer-term growth plan, not just for immediate satisfaction of rules that aren't cemented.

Academic Freedom, Governance, and Political Scrutiny

The proposed expectations involving academic freedom and intellectual diversity put accreditation in an increasingly complicated space. Institutions are being asked to navigate educational mission, academic freedom, First Amendment considerations where applicable, institutional governance, and changing federal and state expectations, all while different stakeholders define these concepts very differently.

At the same time, accreditor expectations involving diversity, equity, and inclusion are facing new federal constraints. This is an area where I think institutional leaders should be especially careful about reactive decision-making. Policies should certainly be reviewed for clarity, consistency, and alignment with applicable law. However, institutions also need to remain grounded in mission. Accreditation requirements may change. Political environments will certainly change. Institutional mission should provide some continuity through both.

The goal should not simply be to rewrite policy every time the regulatory environment shifts. It should be to ensure that institutional policies are clear, defensible, consistently applied, and connected to the educational commitments the institution says it values.

Educator Preparation Cannot be an Afterthought

For those of us working in educator preparation, these institutional changes carry an additional layer of complexity. Educator preparation programs already operate within overlapping systems of accountability: institutional accreditation, specialized accreditation through organizations such as CAEP or AAQEP, state program approval, licensure requirements, and P-12 partnership expectations. Changes at the institutional level will inevitably move into programs.

If an institution changes how it measures outcomes, educator preparation will be affected. If institutional policies governing faculty evaluation, transfer credit, academic freedom, or research integrity change, programs will need to respond. If an institution ever considers changing accreditors, the implications for specialized accreditation and state approval need to be understood before, not after, the decision is made.

This is why educator preparation and other professionally accredited programs need a seat at the table during institutional planning. Program-level accreditation expertise is not peripheral to these conversations. In many cases, it may be one of the institution's strongest resources. Programs accustomed to demonstrating completer outcomes, licensure results, employer feedback, stakeholder engagement, and continuous improvement have been doing outcomes-based quality assurance for years. Institutions should be relying on that expertise now.

What Institutions Should Focus on to Remain Grounded

Despite all of the uncertainty, there is meaningful work institutions can undertake now that will remain valuable under almost any version of a final rule:

• Know your outcomes data-Understand what you can currently conclude about completion, employment, earnings, licensure, debt, and program-level value, and where the gaps are.
• Engage in the process-The public comment period exists for a reason. If proposed provisions could create unintended consequences for your students, programs, faculty, or institution, contribute to the conversation.
• Bring your board into the discussion. Accreditation is increasingly a governance-level issue. Boards should understand the changing landscape before major decisions arrive on their agenda.
• Look at your continuous improvement systems. Ensure these are helping people make decisions or primarily producing documentation for accreditation.
• Connect institutional and program-level work. Specialized and professional programs may already have sophisticated systems for tracking outcomes, engaging stakeholders, and demonstrating improvement. Do not recreate those systems somewhere else in the institution without first looking at what already exists.

With all of that, I would add one more: Do not create unnecessary compliance work in anticipation of requirements that do not yet exist. Preparation and overreaction are not the same thing.

Continuous Improvement Matters

Periods of regulatory change can make accreditation feel even more compliance-driven than usual. When requirements are uncertain, our instinct can be to collect more data, write more policies, create more committees, and document everything just in case; however, more documentation does not necessarily create more quality.

A functioning continuous improvement system gives an institution something much more valuable: the ability to adapt. If you understand your outcomes, regularly examine your evidence, involve the right stakeholders, make decisions based on what you learn, and document the changes that follow, you are much better positioned to respond when external expectations change.

That is true whether the change comes from the Department of Education, an accreditor, a state agency, a licensing body, or your own institutional priorities. That is why I continue to believe that the best preparation for accreditation change is not building a better compliance system. It is building a stronger, more collaborative improvement culture.

A Word of Perspective

There is no question that periods of regulatory change are exhausting. For those responsible for accreditation and institutional effectiveness, it can feel as though the expectations shift just as soon as we have figured out the previous ones. It is worth remembering what sits underneath all of this:

Accreditation exists because there is a public trust attached to higher education; the expectation that a degree or credential represents meaningful learning, appropriate quality, and an opportunity that has value for the student who invested in it.

We can, and should, debate how that quality is measured, who should measure it, how much authority accreditors should have, and where federal oversight should begin and end. Those are important conversations. Institutions do not need to wait for those debates to be resolved before asking themselves some fundamental questions:

• Are our students succeeding and how do we know?
• Can we demonstrate the value of what we provide?
• Do we use evidence to make our programs better?
• Could we explain that story clearly if someone asked us tomorrow?

Institutions that can answer those questions are not simply better prepared for the next accreditation rule; they are better positioned for continuous improvement. Ultimately, that is the work that matters.

Point to Ponder

I want to leave you with this: If the accreditation requirements changed tomorrow, which parts of your institution's quality assurance system would continue because they genuinely help you improve and which would disappear because they exist primarily for compliance? The answer will significantly reveal how prepared your institution really is for what comes next. If your institution or program is working through these changes and considering how to strengthen its accreditation or continuous improvement systems, I welcome the conversation.

References

• U.S. Department of Education. (2026). Accreditation, innovation, and modernization: the secretary's recognition of accrediting agencies. notice of proposed rulemaking, 91 FR 53940. Federal Register. https://www.federalregister.gov/documents/2026/08/20/2026-17001/accreditation-innovation-and-modernization-the-secretarys-recognition-of-accrediting-agencies
• Inside Higher Ed. (2026, August 26). 3 key changes in trump's new accreditation rule. https://www.insidehighered.com/news/governance/accreditation/2026/08/26/3-key-changes-trumps-new-accreditation-rule
• Higher Ed Dive. (2026). Education department proposes accreditation overhaul. https://www.highereddive.com/news/education-department-proposes-accreditation-overhaul/828333/
• Association of Governing Boards. (2026). AGB policy alert: U.S. department of education releases proposed accreditation rule for public comment. https://agb.org/news/agb-alerts/agb-policy-alert-u-s-department-of-education-releases-proposed-accreditation-rule-for-public-comment/
• Nixon Peabody LLP. (2026, August 21). Education department issues notice of proposed rulemaking for higher ed accreditation. https://www.nixonpeabody.com/insights/alerts/2026/08/20/education-department-issues-notice-of-proposed-rulemaking-for-higher-ed-accreditation
• McGuireWoods. (2026, August). Department of education proposed rule would transform U.S. higher ed accreditation system. https://www.mcguirewoods.com/client-resources/alerts/2026/8/department-of-education-proposed-rule-would-transform-u-s-higher-ed-accreditation-system/