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ERIC Identifier: ED446329
Publication Date: 2000-07-00
Author: Bobby, Carol L. - Capone, Lucien, III
Source: ERIC Clearinghouse on Counseling and Student Services Greensboro NC.

Understanding the Implications of Distance Learning for Accreditation and Licensure of Counselor Preparation Programs. ERIC/CASS Digest.

Accreditation and licensure standards, which have been built around the traditional classroom paradigm for delivery of higher education, must shift radically to accommodate the use of new distance learning technologies. Furthermore, the movement from teacher-centered to learner-centered environments results in a need for the accreditation and licensure paradigms to be reevaluated in order to (1) remain relevant, (2) carry out their original functions of accountability, quality assurance, and consumer protection, and (3) not impede the development of distance learning programs.


Accreditation standards have traditionally evaluated identifiable physical facilities, faculty-to-student ratios, library holdings, support staff, and budgets as well as course syllabi, faculty credentials, history of graduates, and the like. These types of standards are collectively referred to as inputs assessment and measure the capacity of an institution or program to carry out its educational mission. But, are these standards relevant in a distance learning environment? For example, in the case of a virtual university how would an accreditation site visit be meaningful when all the accreditor will see are offices full of humming and whirring computer disk drives? Faculty-to-student ratios have little meaning when any number of students can pursue an on-line course without time and place constraints. There also may be no library to visit if access is provided either to computerized databases or to libraries by way of the Internet.

In the 1980s, some farsighted accreditors began shifting from inputs assessment to outcomes assessment standards that evaluate the success of the institution or program in accomplishing its mission. More specifically, outcomes assessment evaluates how well the institution or program transfers knowledge and skills to students. However, there has been resistance to this shift and progress has been slow. First, it is harder to do. It is much easier to count faculty, clock hours, and review budget figures than it is to determine if those inputs are leading to successful outcomes. Second, some view inputs standards as tools for protecting faculty lines, workloads, and resources -- a position that often infuriates administrators. Third, outcomes assessment has been viewed as the province of agencies that certify or license individuals to practice.

But these objections are based on an unnecessarily narrow view of outcomes assessment that, if done correctly, can perform the critical function of determining whether changes are needed in the inputs. Additionally, there is growing pressure from the U.S. Department of Education (1997) and the Council for Higher Education Accreditation (1998) to require validation of standards in terms of relevancy to outcomes. Finally, since distance learning defies the application of many traditional input standards, it will force accreditors in the direction of outcomes assessment. When learning occurs via new delivery methods, accreditors must ask new questions regarding what constitutes quality education. They must review their existing standards against these questions and revise the standards to insure quality within the new learning paradigm. Such questions include the following:

* First and foremost, what is being accredited? Is it an institution, a program of study, a delivery system, or something else?

* Who are the faculty? What support is provided to faculty who engage in distance learning?

* Who are the students and how are they evaluated? How do students interact with faculty? Is the delivery system accessible to disabled students?

* What instructional designs best fit with the mode of education delivery? How are labs and clinics conducted?

* What library facilities are available?

* How is privacy of student data, verification of student identity, and protection of intellectual property secured?

Once the fundamental questions have been answered, standards should be examined to determine if they adequately assess the appropriate factors without constraining innovation.


Unlike the collegial peer process that lies at the heart of accreditation, licensure of educational institutions and programs is usually conducted by bureaucrats under legislative mandate. There is nothing collegial about it. Although licensing laws prescribe "standards," these differ from accreditation standards in that they focus on amenability to legal process, fiscal accountability, and compliance with state and federal laws. However, accreditation and licensure have become commingled because many licensing laws require accreditation as a condition of licensure.

Because each State has legal authority to regulate education within its own borders, there are at least 51 different regulatory schemes (including the District of Columbia's) with which a distance learning program may have to contend just to operate within the United States. This multiplicity of regulations presents difficult problems for distance learning programs desiring to offer courses across jurisdictional lines. Identification of the applicable regulations, multiple applications and fees, periodic audits and reporting to each jurisdiction are just a few obstacles to be overcome (Western Governors Association Design Team, 1996). Identifying a state's regulations can be daunting because most states make no explicit mention of distance learning in their regulations. Reference must be had to broader rules governing out-of-state and nonpublic educational institutions. After the relevant set of regulations has been identified, it is not always clear that those regulations will even apply to a given distance learning program. In most states the institution must have some physical presence within the state before the requirements apply. But the definition of physical presence varies widely. Many states exercise jurisdiction only if faculty or administrative personnel are present within the state (Goldstein, 1998). Others exercise jurisdiction if academic credentials are granted to residents within the state. A few assert jurisdiction if instruction is given to state residents by correspondence, telecommunications, or electronic media.

The scope of regulation varies also, ranging from simple registration of institutions and programs to requiring that highly specific standards be addressed within a complex application process. An example of the latter is Florida, which requires a four-step process moving from temporary licensure to "provisional level one" to "provisional" and finally to "regular" licensure.

Accreditation could provide a valuable service in reducing these regulatory burdens if licensing agencies would accept accreditation as satisfaction of most licensing requirements. This approach pares down those requirements to such things as providing the address of a registered agent for service of process, proof of insurance, and other such guarantees of legal and public accountability.


The historical reason for accreditation and licensing in the United States has not changed. The public's need for reliable information about education programs is even greater in the distance learning environment. Accreditors should be empowered to think creatively and cooperatively, so their standards and processes remain relevant and foster the development of quality distance learning programs. The following recommendations are suggested.

1. Rewrite standards to make them outcomes versus inputs oriented. Accreditors should review standards to determine if they unnecessarily impede innovation in the design and implementation of nontraditional delivery systems. Standards should be written to assess outcomes rather than inputs.

2. Educate the public about accreditation of distance learning. As the Internet makes it easier for fraudulent diploma mills to prey on the public (Guernsey, 1997), accreditors must recognize that the demand for information will not go away. Accreditors must educate the public about their standards and quality assurance processes and inform them about questions they need to ask.

3. Encourage cooperation and collaboration between and among accrediting agencies and licensing authorities. Accreditors and licensing agencies should be encouraged to cooperate to reduce duplication of effort by educational programs that cross regional or programmatic boundaries. Laws could be rewritten to accept accreditation as satisfying some licensing requirements.


Because the paradigm for delivery of higher education is shifting so markedly in the distance learning environment, accreditors and licensure authorities will face new challenges in determining what constitutes quality education. Standards that have traditionally quantified inputs must be altered to measure student learning outcomes. However, knowing where, when, and how to alter standards is not easy. Accreditors and licensing authorities have had little time to define what constitutes good practices and standards for distance learning programs. It is imperative that accreditors and licensing authorities immediately begin working together to create a quality assurance system that is relevant to new learning environments and protective of the public's interest.


Council for Higher Education Accreditation. (1998, September 28). Recognition of accrediting organizations: Policy and procedures. Washington, DC: Author. (Available from CHEA, National Center for Higher Education, One Dupont Circle, NW, Suite 510, Washington, DC 20036-1135)

Goldstein, M. B. (1998, June). Regulatory implications of distance learning: The external environment. Paper presented at the annual conference of the National Association of College and University Attorneys, Philadelphia, PA.

Guernsey, L. (1997, December 19). Is the Internet becoming a bonanza for diploma mills? The Chronicle of Higher Education, pp. A22-A24.

U.S. Department of Education Procedures and Criteria for the Recognition of Accrediting Agencies, 34 C.F.R. SS 602.20-.30 (1997).

Western Governors Association Design Team. (1996, July). The policy environment for implementing the Western Governors University. Denver, CO: Author [On-line]. Available:


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