How Technology Could Modernize Accreditation in Higher Education

by Presidents Forum | Jul 10, 2026 | Innovation, Policy

How Technology Could Modernize Accreditation in Higher Education

Higher education has embraced technology to improve teaching, learning, and student support.

According to Alison Griffin, it’s time to apply that same thinking to accreditation.

In a policy paper for the American Enterprise Institute, Griffin examined how industries such as healthcare and financial services use technology to strengthen quality assurance. Her conclusion: higher education has an opportunity to move beyond periodic compliance reviews toward more continuous, outcomes-focused quality improvement. Her full paper provides additional detail on the framework and recommendations.

Learning from other industries

Healthcare and financial services use real-time data to identify potential problems before they become crises.

For example, hospitals monitor key performance indicators continuously, allowing leaders to spot bottlenecks and intervene quickly instead of waiting months for a formal review.

Griffin argues that higher education could adopt a similar mindset by using technology to monitor institutional performance throughout the accreditation cycle rather than relying primarily on episodic reviews.

Focusing on outcomes instead of paperwork

One challenge Griffin highlights is the sheer volume of documentation involved in accreditation.

Some accrediting reviews involve hundreds of thousands of pages of material, making meaningful analysis difficult and limiting opportunities for timely feedback.

Technology creates an opportunity to shift attention away from managing documents and toward understanding outcomes.

Institutions already collect data on student retention, completion, financial health, enrollment trends, and workforce outcomes. Rather than waiting years between reviews, those indicators could help institutions identify emerging challenges and respond sooner.

Using data to strengthen peer review

Griffin is not arguing for replacing peer review.

Instead, she believes technology can make peer review more effective.

If institutions identify declining performance through continuous monitoring, accrediting organizations could connect them with peer institutions demonstrating strong results in those areas, creating opportunities for collaboration and improvement rather than simply evaluating compliance.

Technology should reduce compliance—not add to it

Griffin cautions that technology should not become another layer of institutional reporting.

Instead, its purpose should be helping institutions identify issues earlier, improve student outcomes, and strengthen quality assurance without increasing administrative burden.

As Griffin puts it, continuous monitoring should help institutions “address problems before they become a crisis, not attempt to create a whole new compliance industry.”

The bottom line

Technology has transformed quality assurance in industries where continuous improvement is essential.

Griffin believes higher education has an opportunity to do the same by using data to identify challenges earlier, focus accreditation on meaningful outcomes, and create a system that better supports both institutions and the students they serve.

Transcript

Wes Smith (01:20.952)
Hey Allison, good to see ya. Welcome to the podcast.

Alison Griffin (01:31.353)
Great to see you, Wes. Thanks for having me.

Wes Smith (01:34.488)
Hey, I I know you’ve been doing a lot of thinking around accreditation. And we we’ve had we have you on the show to talk through a little bit about accreditation and about large cycle, what’s happening in higher education, especially in terms of technology and how that’s impacting everything. And that’s a kind of a new conversation for us. What what is technology doing in terms of accreditation? You’ve done some thinking on that. Can you tell us a little bit about what you’ve done there?

Alison Griffin (02:04.144)
Absolutely. So about a year ago, I was asked by the American Enterprise Institute to write a policy paper on a topic of my choosing related to accreditation. And the thing that struck me most about accreditation was that we don’t often talk about technology when it comes to quality assurance. And so I asked my colleagues at AEI if I could actually explore this concept in a little bit more depth. And so as I got in

To that research, that desk research, I started to uncover that there are a number of industries that rely on technology for their quality assurance frameworks and their processes in a much more intimate way than what any of our accreditors across the higher education landscape do today. And so I took the pen, truly pen to paper, and started writing on this topic. And what I uncovered.

was was pretty interesting, particularly when it comes to documentation that our institutions are creating and producing for the quality review process.

Wes Smith (03:16.758)
It it doesn’t surprise me that education isn’t on the cutting edge of quality assurance monitoring using technology, but what are some industries that that you found were more on the cutting edge?

Alison Griffin (03:29.26)
absolutely. So, well, the two that I spent some time exploring in depth were healthcare, not a surprise, and financial services, also not a surprise. The similarities with healthcare is that they have a joint commission that actually evolved from episodic site visits to ongoing quality assurance indicators.

one of the examples that I was able to learn a lot more about was at Johns Hopkins. They run this patient flow dashboard with 10 KPIs, and administrators are able to spot quickly bottlenecks instead of seeing that months later. And so I just started thinking about what if we were to apply that same concept in the institution context. You know, all of our institutions have.

KPIs or strategy frameworks, they all show up differently. But what if you actually built a dashboard where you started to see some of those bottlenecks in the data that might be coming through? You know, whether they’re financial indicators or whether it’s staff transition or even student enrollment numbers, where institutions could be a little bit more just in time responsive as opposed to months or years later.

catching some of these issues.

Wes Smith (04:59.054)
I love in in higher ed, we take our accreditations seriously. And there are so many people that want to see accreditation to protect, you know, consumers. That being said, there is no more important industry for quality assurance than healthcare. It it is literally life and death in healthcare. And and those KPIs are saving people’s lives, right? They’re saying, hey, we have a problem here. We need fast intervention.

And so you it sounds like what you’re saying is if it’s good enough for for financial services, if it’s good enough for the healthcare sector, why aren’t we taking some notes from that and figuring out how we can have faster intervention in higher education? Does that sound about right?

Alison Griffin (05:44.901)
That sounds about right. I, you know, I think today our creditors are asking institutions essentially like, how can we help you make your case? Whereas I started asking the question, like, what do the data actually show? And so, what do the data show? How can we start looking at the outcomes of our institutions instead of trying to fit into

What our quality assurance framework wants us to be.

Wes Smith (06:18.774)
Right, right. Okay, so if you’re if you’re applying this to accreditation and you’re you’re saying, okay, we have so much information, we can we can review it, you know, as in real time, essentially, and we can have faster remedies for troubling situations. Can you give us an example or two about what higher education is in a position to monitor right now?

on a regular basis that we don’t monitor.

Alison Griffin (06:50.64)
Sure. I’d like to start by just giving your listeners an example that I laid out in the paper. And that was my review of some Department of Education records and the requirement that they have for agencies, so the accreditation agency, to produce documentation on what they’re doing. And the example was one of the

regional accreditors, I guess now operating, of course, across regions, produced over 800,000 pages for their review. So you think about even half of that, right? We’ll take 400,000 pages. A single reviewer who is reading 40 pages an hour, it’s gonna take them five years to do that work.

Wes Smith (07:43.362)
That is wild.

Alison Griffin (07:45.307)
Right. And so that’s that’s the and this is probably not a topic for today’s conversation, but you know, that’s the federal government’s oversight of the accreditor. And then you think about the accreditors’ oversight of all the institutions and or programs in its purview. And so if if if our agencies, our accrediting agencies aren’t staffed to be able to do

You know, this review, we are leaving institutions without a review that provides them with the feedback and opportunity for improvement that they may actually be seeking. And so your question about, you know, what what could technology aid in right now? There are a couple of things I feel like our institutions are ready broadly to do.

So completion and retention from a disaggregated with a disaggregated approach. We are already collecting a lot of that information. It’s already broadly comparable. Those are some of our leading indicators that our institutions are looking at. So your retention drop shows up years before your graduation rate does. Great. So we can check that box. Economic outcomes.

I think done really carefully, the measure to emphasize is actually the value-added earnings, the wage gain an institution generates relative to their cost of attendance, you know, not just raw graduate salaries. So, how do we start looking at some of those value-added metrics? And of course, there are institutions and systems that are starting to do that work, certainly given the federal rule changes around accountability.

I think we’re gonna start seeing that data emerge more readily. So that would be the second thing.

Wes Smith (09:43.51)
Right. I I love the focus on outcomes. accreditation has, you know, this this traditional approach, generally speaking, of taking a lot of time to review inputs. And getting to the outputs seems to be the most important thing we can do. You’ve named one that I think is just the highest level.

Output that you can measure, which is economic gain. You know, what what are the what are the impacts of you know this program from this institution on your bottom line as a consumer? So I think that we’ve we’ve hit on one of the most important outcomes. What other things could could you use technology to skip a lot of the inputs and get directly to the out outputs?

So we can focus on the most important things. Any other thoughts on that?

Alison Griffin (10:42.267)
So absolutely, I think one of I’ve been reading a lot of stories about this recently, but it are the financial health indicators and institutions that for years or in some cases a decade have been suffering through financial ups and downs. Of course, the economy impacts that, state funding, if you’re a public institution. But the surprising part to me is how many institutions now look back and say, wow, we

Could have caught that if we had only seen a full picture, if we could have only done some projections in a way that looked beyond three or five years. And so that financial health indicator, while not a learning outcome, it’s an outcome that students actually care about because it’s whether or not the institution that they’re attending is still going to exist.

One when they’re due to graduate, or two, when they want to come back 20 years as an alum. the other thing that I would suggest is that labor market alignment. So, you know, we have institutions that are collecting data. And in the case of public institutions, we have states and state systems, state agencies that are collecting information. How do we start filtering?

Some of that labor market information through an institutional mission. So I’m not even saying that we have to compare all the institutions in a single state. What if we started looking at them across Carnegie classification? Or we write? And so one, it’s a it’s an opportunity to also share information. I think that’s another place where accreditation could actually reform peer review.

Wes Smith (12:22.892)
Yeah. Interesting.

Alison Griffin (12:35.589)
I wouldn’t say we need to get rid of peer review. We need to leverage peer review in a wholly different way. So if you use technology to get after some of these indicators, get after your outcomes, you see a dip in performance. Wouldn’t you want to leverage the people in the network of higher education who are doing an excellent job at that indicator to come and be a collaborator with your

Wes Smith (13:03.17)
Yeah, absolutely.

Alison Griffin (13:04.177)
to improve on that outcome.

Wes Smith (13:06.604)
Right, right. That makes a lot of sense. some of our listeners out there, especially those who are very familiar with accreditation, I know what they’re saying right now. They’re saying, well, yeah, you can monitor some things, but you can’t monitor everything that accreditors do using technology. There are some parts of quality control that aren’t continuous. You know, there are new programs, there are, you know, seasonal enrollment, some things like that.

So what do you think the exception for continuous monitoring and input would be in the accreditation process, if there are any?

Alison Griffin (13:47.826)
So you’re asking of like the things that might be hard to standardize using another term. I actually I do believe it that one of the things that is hardest to standardize are the learning outcomes themselves, to be really honest. Like we don’t have a valid sort of comparable measure of what students actually learn across 4,000 wildly different institutions. And so pretending that we do.

Wes Smith (13:52.813)
Yes.

Alison Griffin (14:17.497)
Is almost like worse than admitting that we don’t. and so I I think that there is still room for improvement when it comes to those actual learning outcomes. And so I think recognizing that from the very beginning is really important. I would also say, you know, in in this environment of disagreeing better, you know, long-run sort of civic and just personal outcomes.

You know, the way in which people are finishing their program of study and contributing to their local community. I think that one, that’s not really something that accreditation is measuring now in a in a comprehensive way. And I do think that that’s something that is still hard to get after. So it’s almost like that return on investment that is fundamental to community building, I think is is really hard.

Wes Smith (15:16.226)
Yeah, that’s interesting. That’s that’s I I don’t see accreditation doing a lot of work in that area right now, but it you’re saying it it that’s a possibility.

Alison Griffin (15:16.266)
Alison Griffin (15:25.421)
Saying it’s I think it’s important, and I don’t know that it’s the role of accreditation. I think I’m saying that that is something that is still hard to standardize. I’m not sure that I would want accreditation to standardize that, but it would be interesting in this environment. again, where I think there is

opportunity for people when they disagree and they know how to disagree in a civil way than disagreeing uncivily and in an uncivil way. And I don’t know how we’re capturing that, but I think it would be important to to have a glimpse into that a little bit better than we do now.

Wes Smith (15:59.458)
Right. Yeah.

Wes Smith (16:08.3)
Yeah, it’s certainly a big issue in our society today. Okay, I’m gonna give you the last word on this. you you’ve done some thinking on it, we’ve talked through it. what would you say to our listeners is you know, your top takeaway and learning from from healthcare and financial services and other industries that we could bring and apply to higher education?

Alison Griffin (16:34.033)
So I would thank you for the last word. so I think the continua the idea of continuous monitoring should change behavior. So addressing problems before they become a crisis, not attempting to create a whole new compliance industry. And so my charge would be leverage technology where it can help make the process better.

For the learner and for the outcome, not adding another layer of compliance for the institution.

Wes Smith (17:09.358)
A fantastic on point for the president’s forum. You know, this idea of using technology to advance accreditation, make it more more relevant to the learner. That is right on message for the things that we’re working on in the forum. And we appreciate your insight on this and thanks for joining us today.

Alison Griffin (17:27.173)
Thanks for having me.

Wes Smith (17:30.454)
Okay.

Why Online Education Is Still a State-by-State Market

by Presidents Forum | Jul 8, 2026 | Policy

Why Online Education Is Still a State-by-State Market

Online education is often described as a national marketplace.

According to higher education analyst Phil Hill, the data tells a more nuanced story.

In his analysis of 2024 NC-SARA enrollment data, Hill found that online education is shaped less by a single national market than by a collection of state and regional markets, each with its own patterns, competitors, and policy decisions.

State markets shape student choice

While a handful of institutions recruit students nationwide, most colleges compete within distinct state and regional ecosystems.

For institutional leaders, understanding where students are coming from—and which institutions they are choosing instead—provides a clearer picture of the competitive landscape.

Hill argues that this type of analysis helps colleges move beyond broad assumptions and better understand the markets they actually serve.

Different states tell different stories

Hill groups states into three broad categories.

Some are “retention states,” where institutions offer enough online options that most residents remain in-state. Others, such as Texas and Florida, are large, highly competitive markets that attract institutions from across the country. Still others are “leakage states,” where many students leave the state to pursue online education elsewhere.

These patterns are often the result of long-term policy decisions, institutional investments, and workforce priorities rather than geography alone.

Why the data matters

For colleges, the data can help identify where opportunities exist, who the real competitors are, and which markets align with institutional strengths.

For policymakers, it provides insight into whether their state is meeting residents’ educational needs or losing students to institutions elsewhere.

Hill cautions against trying to replicate large national online providers overnight. Instead, he suggests institutions focus on programs that align with local workforce needs and build from their unique strengths.

The bottom line

Online education is not one national market.

Institutions that understand the dynamics of individual state markets—and design programs around student demand and regional workforce needs—will be better positioned to serve learners and compete effectively.

Transcript

Wes Smith (00:00.12)
Joining us today is Phil Hill from On Ed Tech. Phil, great to have you back.

Phil Hill (00:06.847)
Yep.

Phil Hill (00:18.345)
Yeah, it’s great to see you again. Always enjoy these conversations.

Wes Smith (00:22.146)
Yeah, these are interesting. This one’s a really interesting conversation to me. You’ve you’ve done some in-depth analysis on some NC SERA data. I kind of feel like a a a serious nerd right now saying that this is very interesting to me. And the the interesting thing is your in-depth analysis on NC SERA data. But forgive me for that. we there are there are there are dozens of dozens of us out there. So what what’s the key key takeaway to this data?

Phil Hill (00:46.571)
Hey guys.

Phil Hill (00:51.253)
Well, the key takeaway is first of all, this is a valuable resource. I mean, the fact that you have this state authorization reciprocity agreement and then the group collects this data and shares it, it’s a great community service. And as you look at it, you it makes it even more clear you don’t have an a single national online market. You have a bunch of state and regional markets.

And only a handful of players really span across all of the states. So the big takeaway is the fact that it’s valuable. And for any school that really wants to understand its position and where students are coming from and which states and who are you competing against, you can’t do better than this, than this data. And it’s important to think about your market. The second thing I would say, if you don’t mind me going on a little bit of a

Mini rant. California, for political reasons, never joined the reciprocity agreement. They did that. They wanted to maintain different consumer protection approaches. But one of the downsides of that is it’s a downside for the California institutions. California is not a member. Therefore, their institutions do not report data to NC SERA.

Wes Smith (01:48.81)
Yeah, please do. No, please do.

Phil Hill (02:15.561)
Yet their students, if they go to another school that’s out of state, that is reported. But that creates a blind spot. So one of the frustrating things is California institutions, public and private, would really benefit if that state would join. I don’t think they’re going to, but there’s it’s just ridiculous. And it does the opposite of helping consumer protection based on how they do it.

Wes Smith (03:32.877)
We have some we have some indicating data on students from California that go to other institutions that are out of state, but we don’t have the same richness of data for those California students who stay in state. Is that right?

Phil Hill (03:50.42)
Yeah, that’s correct. And so what I did is I didn’t want to have a complete blind spot for California institutions because they are so important. So in the case for those institutions, I substituted the iPads distance enrollment data. The problem is for out of state students taking online programs in California institutions, we don’t know which state they came from. All we can say is they’re out of state.

Wes Smith (04:16.392)
yeah. Yeah, okay.

Phil Hill (04:19.955)
So it’s a partial blind spot by the way that I combine the data.

Wes Smith (04:25.409)
You’ve done your best to overcome it, but there’s still some data that’s lacking there. Got it, got it. Okay, that makes sense. especially for our California listeners. If they’re if they want to listen and evaluate your analysis, they’ve gotta remember it’s a caveat that that’s the one thing you can’t tell.

Phil Hill (04:29.183)
That’s that’s correct. Yeah.

Phil Hill (04:39.517)
Yeah, and I th I’m the only one that I know of who’s sort of combined these two approaches so it’s not an either or, so hopefully it’s valuable for them.

Wes Smith (04:47.339)
Right, right. Okay. Well, so describe the the three categories of states that that you’ve put together. I I know that I know that you’ve done a lot of work on that, and you have strategic out-of-state targets, you’ve got retention states, and you’ve got leakage states, but explain to our audience what that means and how you’ve how how you’ve categorized them.

Phil Hill (05:08.879)
And I should probably describe it the way I’ve categorized it is sort of a public policy type of view, where that a lot of state policymakers and schools in states, you don’t like to see your students going to programs out of state, at least too much. Why aren’t we serving our own residents? You take that argument. So that’s sort of the basis of it.

And if you do that, you get one group who in Arizona, where I live, is a good example. Is you have multiple in-state institutions who offer online programs, you know, the Arizona State, the University of Phoenix, all of these, but you’re serving your own residents. They have plenty of online options within that state. You have big states, California, Florida, Texas in particular.

That are so big and concentrated, that’s the target states. So if you have an online program, you would love to get California students and Texas students because it’s just such a big source. That makes those states quite competitive or the competition for those students. And then a third is the other side of it saying leakage states.

Wes Smith (06:23.351)
Okay.

Phil Hill (06:28.415)
These are states that for public policy or various reasons, they just don’t have a whole lot of online programs available for their own residents. And therefore a large percentage go out of state. And the one that I had in the original post that you referred to was the state of Washington. So look at just how big Western governors is within the state of Washington.

Now there’s historical reasons for that. That was one of the earliest universities using Western governors, and it was almost like a flagship state presence for them. But so you have different types of states, and it very much points back to state policy and the schools and how competitive they are within there. So you have different markets, but you have different types of state policies as well.

Wes Smith (07:23.799)
Well, at the president’s forum, we just have s you know, a lot of institutions who who have, you know, this online capability. And they’re operating in multiple states. Some of them are, you know, we have California based that that have a lot of you know in state possibilities, but also national. you know, you mentioned WGU and SNHU out there with national presence. What this this

Phil Hill (07:33.472)
Yes.

Wes Smith (07:53.632)
analysis that you’ve done, what kind of of an impact do you think it should be having on these institutions? What what should presence form institutions be looking for in this data?

Phil Hill (08:07.871)
Well, hopefully I’ve made the data digestible and more easily available. So it’s not just individual business analysts within your institutions who get what’s happening. So you have a wider ability to see the data. And you start seeing things such as if we want to be competitive for this mention Washington, well then which schools are already serving Washington State students? Where are they already going? So who is our

Actual competition. Texas, highly competitive as well. So if you’re trying to serve Texas students as a target market, whether you’re in state or out of state, the biggest thing to say is how am I doing? Who are my I use the word competitors, but where are students already choosing to go? And therefore, try to better understand the decisions that students have.

Wes Smith (08:57.708)
Mm-hmm.

Phil Hill (09:04.117)
Who are they trying to think of when they for those who want an online program? What are my choices? And quickly realize it’s not going to be the same answer in Arkansas that it’s going to be in Michigan or Arizona or somewhere else. It’s very localized. So you need to be able to, if this is our market and here’s where we’re going, for these students who are, what are their choices really? That’s what I’m trying to make it easier to understand.

With this analysis.

Wes Smith (09:35.82)
Right. Well, okay. So now flip it to a state policymaker. So we clearly there’s a reason that institutions want to understand what’s going on in each state, especially the states that that they have a where they have a lot of students or they seek to have a lot of students. But for a policymaker from any given state, what does this information help them do?

Phil Hill (10:02.229)
Hopefully it gets out of get them past the initial shallow level of understanding. And maybe that doesn’t sound right, but what I hear so often at state policy level is we can’t keep sending our students to southern New Hampshire. We need to serve our own residents and some of our investments. Well, you need to go beyond that. You know, is it really southern New Hampshire? Is it Liberty Is it, you know.

University of Maryland Global Campus, how many students are doing this. So it’s basically for state policy. It’s again to go past the surface level understanding, but it’s true, it it should sort of inform do we need to invest more? That’s where I’ve heard people using this already. Hey, I love these charts. I want to take it to the legislature when we’re arguing for money.

And here’s why should we should be serving these students. We shouldn’t just be quote unquote sending them out of states. So it’s in that debate about how much do you invest and try to serve these residents where that type of where the data should be valuable.

Wes Smith (11:13.677)
So, Phil, I know you’ve been around this for a long time in this ed tech world. And so now I’ve got a question. it’s it’s I think sophisticated state policymakers would probably ask this question, and that is it takes a lot to create an in-state option that could compete with some of these programs who have been working on this for decades now. it is is that

Phil Hill (11:37.866)
Yes.

Wes Smith (11:40.894)
Does your would your data show that that is accurate? Number one. And number two, is it worth the investment for a state to have an option to compete with with other options that are have been at this for a really long time and have have kind of, you know, they’ve they smoothed out the process for students? Tell me what you think about that.

Phil Hill (12:06.011)
well, the data does go back to 2015. So you have a historical basis and you could look at any institution and say, when did they start? And yes, the big national brands, you’re going to find the answer was in the 2000s, most likely, or early 2010s, or with some of them back in the 1990s. But what would I do as a state policy maker? I would say the choice is not a binary, do we go for.

online students nationwide. You probably miss that bus just from a if you build it, they will come mentality. What you have the opportunity is to say, we know our local workforce. We know this specialization is what we really need for not only our students, but also for our local workforce. And we can serve our students better because we know them and and we’re right here. So specialization

And you know, thinking of what makes us unique, and part of that uniqueness is your local workforce and how to how to serve them. That’s where the opportunity is. So can you still get into the national market, if you will? Yes, you better be patient. Yes, it’s possible, but there’s a lot more opportunity to target specific programs and specific strengths of your college or university.

system, if you will.

Wes Smith (13:36.632)
So I I mean one of the big takeaways for me in in this conversation and based on, you know, your analysis is it it really is it’s not as clear cut of a national conversation as most people believe. It it is very much driven by regional markets or even state level markets.

And if you’re not playing at the state level and understanding the dynamics there, you’re probably missing a lot on this. Is that is that what you ended up with?

Phil Hill (14:10.571)
Yeah, I yes, that that is definitely the way to interpret it. And it is interesting looking at the data. Although you’ve self-identified, you’re a data nerd, so you naturally look at this, but there’s a pretty rich story about each of the individual states and where students are, and usually when you look at it.

You’re able to start saying, look at that school in this position. I remember that was a decision that was made in 2012. And so it starts to tie in historical decisions as well as you look at it. but yeah, as I said, it’s not a binary decision, it’s which students.

Wes Smith (14:52.951)
Phil, give us an example of that, of of something that you can look back to and see the history and that’s why this th these numbers look the way they do.

Phil Hill (15:02.761)
Well, I mentioned state of Washington. Early on, they didn’t it’s not just that Western governors set up an online presence in Washington. The state encouraged it. This is our approach to online education. And that really ramped up Western governors in that state. So so that’s one example. You have states such as Arkansas, where they, you know, combining their e versity and then they acquired Grantham University and

Wes Smith (15:22.111)
in Washington. Okay.

Phil Hill (15:32.572)
The state system is really trying to serve students more. That’s another decision that you start to see in the data. Now that’s more recent, but you definitely see that in the data as well. And I guess another one, the global campuses like UMass Global, they now the that was an example where they came out saying we can’t keep sending our students to southern New Hampshire. And I think initially they might have been.

too much of a it’s us versus them. But as the programs developed, I think they’re starting to see some changes in how the students are actually getting served. But it’s those types of decisions that you see. One other that I’ll mention, again, coming from Arizona, there’s an HR component to it. This is almost Silicon Valley for online education. So you have so many people who work in this area, that’s where you’ve had

A Arizona State, University of Phoenix, Grand Canyon University, Rio Salado, now University of Arizona Global Campus, which is now University of Arizona, but they’re all co located. And so this is a unique state because you have so many providers here right in the same area. And you get a unique thing.

Wes Smith (16:50.507)
That’s one thing that popped when I was looking at the data is that Arizona is, you know, just I mean, it’s the national leader with regard to online education. There’s it’s it’s hard to debate that any other state has an you know, anywhere near the type of influence that that Arizona does.

Phil Hill (17:06.983)
And the range of providers offering different programs coming from Arizona. Yeah, that is quite unique.

Wes Smith (17:14.463)
Right. You know, New Hampshire has one and Utah has one. And so you get you get the idea that Arizona has you know half a dozen that are come that have come together to provide this and it shows up in the data.

Phil Hill (17:18.227)
Yes.

Phil Hill (17:28.393)
Yeah. And and this goes, by the way, it goes back to my mini rant about California. California institutions, I bet they would love to be able to see this which state students are going where and how do we stack up. So that’s part of the reason there’s a lot of schools in California who are doing online. They would do a lot better if they had better visibility into this.

Wes Smith (17:51.125)
Yeah. Yeah, absolutely. Well, Phil, this has been very interesting, super clear and useful data. We appreciate you taking the time to come and talk to us about it. We’ll we’ll of course link your article in the show notes. Where can our listeners find more information about this if they’re just, you know, looking for it?

Phil Hill (18:10.751)
Well, the on ed tech newsletter is a short answer, but I will point out that I’ve actually recently for premium subscribers to the on ed tech newsletter, on ed tech plus, I’ve actually created a enrollment an enrollment data tool that’s interactive that’s available. So the NC SERA data, the iPads distance enrollment data, you can do your own filtering and sorting and even pick.

Let me look at my school and my peers and see how they compare. So it’s on ed tech, but in particular, the pr there’s now a premium version that’s a data explorer that you could get a lot more out of this.

Wes Smith (18:52.481)
Fantastic. Fantastic. Okay. Well we’ll we’ll send our our listeners to on ed tech to to check this out. And Phil, we look forward to having you back on the show very shortly, I’m sure.

Phil Hill (19:04.841)
Yeah. Well great. I enjoyed this as always.

Wes Smith (19:07.714)
Thanks, Phil.

Why Earnings Alone Cannot Define Higher Education Accountability

by Presidents Forum | May 8, 2026 | Policy

Why Earnings Alone Cannot Define Higher Education Accountability

Why the accountability debate is more complicated than it looks

Higher education accountability is increasingly centered on earnings outcomes. The assumption is straightforward: students earn a credential, enter the workforce, and their salaries reflect institutional quality.

But Glenda Morgan argues the reality is far more complex.

Earnings are not produced by institutions alone. They are shaped by geography, labor markets, career pathways, industry structures, and personal choices. Treating salary as a direct institutional output ignores the broader systems that influence economic outcomes.

That distinction matters because accountability systems shape policy, funding, and which programs institutions choose to sustain.

Why earnings are not a clean institutional metric

A graduate’s salary reflects more than where they studied.

Regional differences play a major role. Urban and rural labor markets produce different wage outcomes, even for students with similar credentials. Cost of living also affects salary structures. The same graduate may earn dramatically different wages depending on location.

Career pathways matter too. Some professions have highly structured salary trajectories, while others develop more gradually over time.

Morgan’s argument is that earnings are a systems-level outcome, not a simple cause-and-effect institutional measure.

Why median earnings can distort accountability

Median earnings simplify complexity into a single number.

That can obscure important differences between programs and professions. High-variance programs may produce both very high and very low earners. Low-floor professions may provide critical public value despite lower salaries.

Morgan also argues that earnings snapshots fail to account for long-term trajectories. Some fields produce immediate returns, while others develop more slowly over the course of a career.

Research shows that liberal arts graduates, for example, may initially earn less than engineering graduates but eventually narrow or surpass those gaps over time.

What accountability systems should measure instead

Morgan argues for a more nuanced accountability framework.

Completion rates should play a larger role, particularly given the scale of students with some college but no credential. Time to degree also matters because delays increase cost and debt burdens.

Geography, labor markets, and career variation should be incorporated into outcome measures. Accountability systems should recognize that different programs produce different types of value and different earning trajectories.

Most importantly, institutions should be evaluated using multiple measures rather than a single earnings metric.

Why this matters for public policy

The design of accountability systems influences institutional behavior.

If metrics are too narrow, institutions may reduce investment in socially valuable professions with lower earnings outcomes. That could worsen shortages in fields like teaching, counseling, and social work.

The challenge for policymakers is to build systems that value outcomes without oversimplifying how education, labor markets, and society actually interact.

Read Glenda Morgan’s article “Earnings Data Are Driving Policy—and Misleading It” for more insights.

Transcript

Wes (00:26.786) Morgan, thank you for joining us today and welcome to the President’s Forum Podcast.

Glenda Morgan (00:47.604) Thanks and it’s a pleasure to be here.

Wes (00:50.488) Hey, your article argues that it isn’t just a measurement of earnings that’s the problem. It’s actually a causality problem. So it’s very detailed in laying that out for us, but earnings are being attributed to institutions when they’re actually produced by systems. Can you explain that to our listeners and tell us a little bit about why that distinction matters?

for how we design accountability in public policy for higher education.

Glenda Morgan (01:26.25) Sure, yeah, you know, in a lot of the accountability discourse that’s going on, earnings are often treated like a clean institutional output. know, somebody goes to college or university, they graduate, they have earnings and they’re seen as a, you you’ve got cause and effect. But actually what happens is much more complex than that, is that somebody goes to university, they take one of a variety of different kinds of programs.

and then they graduate. But what they actually earn is a product of all different kinds of things. It is a product of where they graduate, are they going to be living in urban or rural kind of setting, but also what kind of a job they’re going into. Some jobs have very determined pathways, others are much more flexible.

And so you’ve got these multiple causality things going on and so what people are actually earning after they graduate is the result of multiple factors all acting together. So it’s not just cause and effect. It’s a highly complex kind of a system. So holding one aspect of that responsible for the outcome is just a crazy sort of setup.

you know, because what’s actually happening is you’ve got all kinds of things interacting to produce a highly variable.

Glenda Morgan (03:21.268) It makes sense to everybody, you know, where you live is going to determine what your costs of living are. And it also sort of determines what you’re paid. I mean, it’s so ingrained in us to understand that, but somehow it hasn’t made its way into the metrics yet. You know, it’s not just urban and rural. It’s also, I mean, there’s a regional aspect that I didn’t write about because my colleague Phil has written about that. But where you live determines a lot of

your costs but it also determines where you’re paid. I used to work for Gardner and they actually you know it was a fully remote company but they actually linked your your salary to where you were living. There were high cost places and low cost places.

Wes (04:05.432) Yeah, that makes sense. Well, in this paper, you also mentioned you described three types of programs that have very different earning structures. And the three programs that you lay out are pipeline programs, high-variance programs, and low-floor programs. First, can you just describe what each those are, each program is for our listeners? And then…

I’d love to get into some of the details of measuring those and why one single median measurement doesn’t quite work.

Glenda Morgan (04:43.114) Sure, as we go on, just want to be sure to call out Ithaca, which my little article was based on their research. Ithaca SNR did some great research on South Carolina, but it’s broadly applicable. So much depends on the kind of the program and then the pathway out of that program for graduates out of there. And they identified three. So the first one are pipeline programs. This is where

You graduate from a program and your pathway is pretty determined. You’re something like nursing where, you know, there are a couple of different paths you can take, but it’s pretty set. And your salaries are in some ways determined by that pathway. And so they’re somewhat predictable. Another one is engineering, you know, how you progress and where you go. You you’ve got certifications and things like that that you do, but it’s certainly set.

And then you’ve got much more flexible kinds of programs. Sorry. High variance programs. this, you know, with a pipeline program, your career and what you’re going to do after you graduate are are largely determined by the program that you’ve done.

Wes (05:58.563) high variance programs.

Glenda Morgan (06:15.136) With high variance programs, it’s less a profession than a set of opportunities. So something like business and even computer science, I would argue, are high variance programs. So they’re not only in terms of what you’re actually going to do is going to vary a lot. You can go to lots of different kinds of places and it’s really up to you in terms of what you’re going to do and what you’re going to make of that, but also your salary, what you’re actually paid.

is going to determine is going to vary a lot. So you’re to have a huge variation in terms of earnings and pathways and occupations. It’s really not determined by the actual degree. It’s determined by what your interests are and how you progress in that. I, for example, I have a PhD in political science, you know, and

you could have become, I could have become a professor or I chose to become an industry analyst and it’s the ultimate high variance kind of programs. And then you’ve got low floor programs and these are sort of, they’ve got elements of both of those in that there’s a big variation in terms of what people do, but earnings are traditionally fairly low. So things like social work, counseling,

often the arts as well. So there’s a lot of variation in terms of what people do, but the floor tends to be pretty low as well in terms of what they make.

Wes (07:49.358) Could we lump in like teaching, mental health programs? Yeah, okay. So these are programs that we actually really do need.

Glenda Morgan (08:03.59) Absolutely, yes. You know, as a society, we rely on those kinds of things. But they have traditionally been paid less. In part, you know, there’s somebody who writes about librarians, for example, who talks about vocational awe, you know, where everybody really admires what they do, but they aren’t prepared to pay for it. And so you’ve got these low-floor kinds of things.

Wes (08:31.79) Okay, so when you take a median, when you just break that down and take one number out, how does that not yield the accountability that we’re actually looking for?

Glenda Morgan (08:47.914) So, you know, people often think about medians as being better than averages and they are, but, you know, they aren’t accounting for the variation across that. Particularly, I think the most egregious example is the high variance programs because a median is just telling you, you know, the middle of between the bottom and the end. And it’s not sort of really telling you in general how people are going to do there, but they’re certainly not capturing

the value of the input as well. There’s a logic breakdown there because what people are earning is determined by the system, not by the actual input of the beginning. It’s just the beginning point that we’re putting a lot of emphasis on and it’s not really a valid measure of anything.

Wes (09:44.674) Well, it just seems that those three different types of programs could create a little bit of a problem having, just evaluating that one number, particularly at the end of the day, when you’re looking at social value of some of these low floor careers and the credentials that are required for that.

Glenda Morgan (10:10.014) Yeah.

Wes (10:14.146) We have, you can’t get rid of all of these credentials because they don’t provide you the economic return that some other careers might because you need them for society. How do you deal with that?

Glenda Morgan (10:28.82) Yeah, you know, that’s a slightly different thing than I argued in the piece, but I think, you know, we have to think about what we need as a society. I remember, as it happens, I’m South African originally. And there was this sort of amazing moment where I sort of understood things in a much deeper kind of way. I was just before I came to the US, it was the end of apartheid.

And as it happened, I went to the University of Cape Town, one of the best universities in the continent of Africa. And I remember hearing a conversation and it was a time of rapid change. There was this guy who was on the Board of Governors, the Board of Regents of the University of Cape Town. He was a businessman, very successful. He said,

My job is to understand the role of the university. And so, for example, in the College of Medicine, we have to provide doctors to the whole of the society. And, you know, as a businessman, I understand inputs and I understand outputs. And if we only get one kind of input, we’re only going to have one kind of output.

So we need multiple kinds of inputs in order to provide doctors for all the different parts, know, for rural, for plastic surgeons, for orthopedic surgeons, for all these different kinds of things. And so I think in terms of our accountability, we need to think of the same sort of thing, inputs and outputs, you know, we need social workers, we need teachers, we need these kinds of things. So we need to make sure that we produce them because we’re going to hurt if we don’t.

Wes (12:23.086) Right, right. Well, you know, that’s clearly the the when you’re talking about we don’t just measure inputs. We do want to look to outcomes. You’re I mean, that’s speaking President’s forum language. We’ve been talking about that for a long, long time. But look, we can’t just we can’t measure accountability by, you know, the way that education is provided, whether that’s in person or online or.

Glenda Morgan (12:34.208) Yeah.

Wes (12:51.16) We can’t just look to the inputs, but inputs and outputs can both be important. Boiling it down to one specific earning number is more complicated than it seems, but let’s get to the, if we’re redesigning this system, tell us what you would build if it were a ground up build on accountability. Well, how would you do it?

Glenda Morgan (13:16.734) We’ve got 43 million Americans with some college no credential. And I think…

Wes (13:49.538) Ha

Glenda Morgan (14:14.472) you know, you can have the best earning credential in the business, but if you’re not actually getting the credential, it’s not going to help you. So I think, you know, including more metrics there, including completion, time to degree, those kinds of things, you know, is sort of is part of that. And really developing a more nuanced measure of that. So including regionality.

including urban versus rural, those kinds of things. So that’s sort of how I would start to design it more from the ground up. But I would put heavily an emphasis on if somebody actually is going to college that they’re coming out of it with a degree or a credential of some sort.

Wes (15:01.878) I love that thinking and that does get forgotten when it’s just one metric after, if you’re just looking at earnings, you’re not seeing all of the non-completers and the cost to the system that that is.

Glenda Morgan (15:15.455). Yeah, no, absolutely. And then they’re stuck with the debt often. And it’s just a sort of nightmare. So I want that to be part of the part of that sort of calculation, but also, you know, thinking also in terms of where people going and how they’re doing. The other thing we haven’t talked about is also time, which I wrote about in the in the article is that, you know, a snapshot in time is not going to give you a

a great measure because some of these professions, for example, the pipeline things are relatively high earning right out the gate, whereas other ones are slow brewing. So there are studies that show that right out the gate engineering graduates earn much more than say, science people. But in the long term, the liberal arts actually catch up and overtake.

I think just looking at snapshots in time is problematic. You need a longer term measure.

Wes (16:26.22) I’m glad you brought that up because that’s a huge variance and it’s really important to capture. It’s hard to capture. It’s very difficult. I don’t know if there’s a clean way that you can do that, but your point is some of these take a much longer time than five years out your credential. They brew over a career.

Glenda Morgan (16:44.768) Yeah, absolutely. Yeah, no, absolutely. And, you know, going back to the median issue, I’ve just been rereading Todd Rose’s The End of Average. And a lot of people have some issues with the book, but I sort of really like it. It’s that, you know, when you’ve got things that don’t correlate, you’ve got multiple measures that don’t correlate, just using an average really gives you a bad result. You know, he uses the example of

Wes (16:55.086) Mm-hmm.

Glenda Morgan (17:10.096) airplane cockpits. Originally they were designed for the average person but turns out nobody’s actually average. Because you’ve got these multiple measures, know, and so we need to sort of bring multiple measures into things instead of using that median of just the earnings.

Wes (17:28.398) Right, well this has been a very interesting conversation Morgan. We will direct our listeners to your piece on this so they can read all the details and we would love to continue this conversation as things move forward with accountability during this administration and future administrations. We really appreciate your thinking about this.

Glenda Morgan (17:37.269) Bye.

Glenda Morgan (17:51.134) my absolute pleasure and lovelies to speak with you. Okay, thanks.

Wes (17:54.616) Thanks, Morgan.

Accreditation, Innovation and Modernization (AIM) Week One Negotiation Update

by Presidents Forum | Apr 27, 2026 | Policy, Uncategorized

The Department of Education’s proposed accreditation reforms represent a fundamental shift in federal oversight, moving from a compliance-driven model toward one focused on student outcomes, institutional value, and market competition.

At a high level, the administration asserts that the proposal would reduce regulatory burden, expand accreditor competition, and strengthen federal guardrails for legal compliance and consumer protection, while emphasizing program-level outcomes and return on investment.

Week One Negotiation Update

The first week of negotiated rulemaking underscored both the scope and complexity of the proposed changes.

Discussions were anchored in a 151 page draft regulatory text released by the Department earlier this month. By the end of the week, negotiators had worked through approximately two-thirds of the draft (97 pages), leaving substantial ground still to cover in the second week of negotiations scheduled for May 18 – 22

While the Department introduced some revisions in response to committee feedback, those changes were described as primarily structural rather than substantive, suggesting that little progress has been made on consensus. Key areas, including outcomes-based accountability, legal compliance expectations, and accreditor flexibility, continue to generate significant discussion and, in some cases, concern among negotiators.

Department Goals with the NPRM

Affordability and Efficiency:
Expectations that institutions demonstrate cost-effectiveness and support credit mobility and lower-cost delivery models. Accreditors review the institution’s cost-benefit analysis of support services and facility operations/expansions.
Transparency and Consumer Protection:
Enhanced disclosure requirements and stronger accountability for institutional integrity and Title IV fraud procedures.
Focus on Outcomes and Value:
Increased emphasis on program-level outcomes, signaling a stronger federal focus on return on investment.
Less Process, More Flexibility:
Streamlined accreditation requirements and fewer procedural constraints, with greater institutional flexibility to select or change accreditors.
More Competition in Accreditation:
Expanded pathways for new accreditors and reduced barriers to switching, creating a more competitive and less geographically defined accreditation landscape.
Heightened Legal and Compliance Expectations:
Integration of federal legal and constitutional compliance into accreditation standards, including nondiscrimination and First Amendment considerations.

Next Steps:

Second week of Negotations scheduled for May 18 – 22

Resources:

Grad PLUS: What the Latest Change Means for Graduate Students

by Presidents Forum | Apr 24, 2026 | Policy, Video

Grad PLUS: What the Latest Change Means for Graduate Students

What changed with Grad PLUS loans

The Department of Education recently updated its guidance on how Grad PLUS loans are treated under new lifetime borrowing limits.

Previously, institutions were told that Grad PLUS loans would not count toward the $257,500 lifetime cap. That guidance has now changed. For students no longer eligible under legacy provisions, prior Grad PLUS borrowing will now count toward that cap.

This shift introduces immediate implications for how graduate education is financed.

Who is most affected

The impact will be concentrated among students in higher-cost graduate programs.

This includes students in medical, dental, counseling, and doctoral programs. Part-time doctoral students may face particular challenges, as longer timelines can increase cumulative borrowing.

Students who previously used Grad PLUS loans and are returning to school are also at risk. They may reach the cap before completing their program.

What institutions need to do now

Institutions will need to adjust quickly.

Financial aid teams should revisit awarding and packaging strategies, especially for students enrolling in upcoming terms. Advising will also need to shift. Students must understand how prior borrowing affects their remaining eligibility.

Clear communication will be critical. Institutions should prepare to re-advise students and update financial plans in real time as guidance evolves.

What to watch next

The timeline is tight.

Final regulations are expected at least 30 days before the effective date of July 1, 2026. That leaves a narrow window for institutions to prepare and for students to adjust their plans.

There is also ongoing uncertainty. Recent guidance has already shifted once, and additional changes remain possible.

Transcript

Wes (07:33.942) Amy, welcome to the show and let’s get right to it. The Department of Education just reversed course. Graduate Plus loans will now count toward the new lifetime borrowing limit under the one big, beautiful bill. What does that actually mean for students that are trying to finance their graduate education? Maybe we should start with, give our listeners background on what happened and then let’s answer that question.

Amy Glynn (07:56.885) Yeah, so when we’re talking about those new lifetime borrowing caps, the department had previously told schools that graduate plus loans would not count towards the $257,500 lifetime cap established under OB-3. In a webinar last week, this guidance was shifted and schools have been told that once a student is no longer eligible for the legacy provisions, previous borrowed grad plus loans will count against that lifetime cap.

And this is a really significant change for institutions that are serving those non-traditional students who are trying to fund their education. They are at severe risk of losing access to all Title IV aid for graduate programs because we know those funding sources are limited to the student loan portfolio.

Wes (08:43.118) Interesting. Okay, so give us the students who are most affected by this.

Amy Glynn (08:47.796) Yeah, students at greatest risk of having to stop out because of this change are going to be those in some of our more costly programs. If you think about things that are in the medical field, dental, our counseling programs, doctoral students, all doctoral students, but especially ones who are enrolled part time. Obviously, it’s our students who previously borrowed Graphic Plus looking to return to school.

And those are individuals who are going to face potential challenges by hitting that lifetime cap. Because the cap never resets. Even if a student has repaid or paid down their student debt, the cap is established and once you hit it, you lose access to those funding programs.

Wes (09:32.342) Interesting, interesting. Okay, so we know that students have to be aware of this now. And that also, I mean, you speak from an administration perspective. You’ve been there on the ground working in financial aid. Tell us what institutions need to know about the change.

Amy Glynn (09:36.448) Thank

Amy Glynn (09:49.044) Yeah, it’s one thing to understand the change. They probably need to shift their advising and their packaging, their financial aid offers that have been established, especially for students that are in these affected populations who are taking courses this summer, but especially students who are starting in the fall in a more traditional sense.

And so they need to understand the provisions. They need to establish a communication protocol to advise or re-advise students. And they need to be prepared to be incredibly nimble because this guidance could change again. You we thought we had a pretty clear understanding based on good faith negotiations that these loans were not going to count against a student’s cap. And this reversal

has significantly changed things and created a level of uncertainty in the knowledge that we did have around negotiations that are on an incredibly aggressive and tight timeframe already.

Wes (10:54.242) So speaking of the timeframe, let’s conclude with some details on the timeframe. What does it look like moving forward?

Amy Glynn (11:01.374) Yeah, so final regulations are supposed to be published a minimum of 30 days before the effective date. Effective date is July 1 of 26. So the time frame is pretty fast and pretty furious and is coming at us real quick.

Wes (11:18.624) Amy, thanks for your time. It was very clear and very useful.

Amy Glynn (11:22.443) Thanks Wes.

What Presidents Need to Know About Workforce Pell and AHEAD Rulemaking

by Presidents Forum | Apr 20, 2026 | Policy, Video

What Presidents Need to Know About Workforce Pell and AHEAD Rulemaking

What is changing with Workforce Pell

Workforce Pell is not just a new funding stream. It represents a shift in how institutions design and deliver programs.

The focus is on working adults, military-connected learners, and students who are re-skilling. These students are mobile, outcome-focused, and balancing multiple responsibilities. Institutions that succeed will treat Workforce Pell as an expansion of what they already do well, not as a separate initiative.

What presidents should prioritize now

Building Workforce Pell programs at scale requires three core capabilities.

First, program development must move faster. Institutions need governance models that allow for rapid iteration as workforce needs change. Second, strong employer partnerships are essential. High-quality programs depend on direct industry input to remain relevant. Third, institutions must have the infrastructure to track completion and job placement outcomes in real time.

Programs must also be designed with stackability in mind, giving students clear pathways to continue learning without losing momentum.

How accountability is shifting

Accountability frameworks are moving toward earnings and outcomes, but the design details will determine whether they work.

If metrics focus too narrowly on short-term earnings, institutions may be discouraged from supporting students who continue into additional credentials. Stackable pathways, which are central to Workforce Pell, do not always produce immediate income gains.

A student-centered accountability system must account for how working learners actually progress, including re-enrollment and continued education.

The risk of getting accountability wrong

There is a real risk of overcorrecting.

If accountability frameworks become too complex, institutions may pull back from offering Workforce Pell programs altogether. That would limit access for the very students these policies are intended to serve.

At the same time, weak accountability undermines trust in the system. The challenge is to strike a balance that protects students while preserving flexibility and innovation.

What to watch beyond Workforce Pell

The broader AHEAD rulemaking signals a long-term shift toward outcomes-based policy.

Institutions should pay close attention to how cohorts are defined, how long outcomes are measured, and whether continued education is properly accounted for. These details will shape how programs are evaluated in practice.

There is also growing concern about implementation complexity. Even well-designed policies can slow innovation if institutions lack the data infrastructure to execute them effectively.

What this means for institutional strategy

This moment is less about the direction of policy and more about execution.

Institutions that align program design, employer partnerships, and data systems will be best positioned to succeed Those that cannot adapt quickly may struggle to participate at scale.

The opportunity is significant, but so is the need to get the design right.

Transcript

Wesley Smith (02:24.214) Today I’m joined by President’s Forum Policy Director, Cam Mortenson, and Policy Fellow, Amy Glenn. We’re here to break down what presidents need to know about the ahead rulemaking. Cam and Amy, thanks for joining.

Cameron Mortensen (02:44.092) Thanks Wes, happy to be here.

Amy Glynn (02:46.029) Thanks so much for having me.

Wesley Smith (02:48.206) Hey, so let’s start with the first question right out of the box. What should presidents prioritize to build workforce Pell programs that work at scale, especially across states and for mobile and working learners? Amy, what do you think?

Amy Glynn (03:03.553) Yeah, so when I think about Workforce Pell, I don’t think about it as a new program. I think about it as a shift in how we operate and expand what we’re already doing really well. Like you said, the students that’s designed for our students who are reskilling, working adults, military connected, parenting students, right? They’re mobile, they’re balancing a lot, and they’re really outcome focused. So the questions for presidents, I really think are three key ones. Can your programs…

Can your program development model support the speed and agility that you need? Can your governance process accommodate iteration at the speed and need for the program relevance? And do you have the infrastructure to track and meet the completion and placement metrics? So this means really having flexibility in how our programs are built and revised, along with strong employer partnerships. Some of those highest quality programs rely deeply on that industry partnership and insight.

And we don’t want our policy to unintentionally limit that. It also means, like you said, consistency and engagement across states because students aren’t confined to one place. Universities that are used to leveraging NC-SARA to minimize state authorization burden are really going to need to ensure that they have a framework in place if developing those programs through distance education to meet those state unique needs.

and understand that their programs may not be authorized in all states because labor market and workforce demands are different. So like the most important thing is it’s about design with the learner in mind, stackable programs, clear pathways and strong support, which is exactly what our institutions are really great at already.

Wesley Smith (04:47.05) Right, right. like your emphasis though. I mean, this will be a little bit of something to navigate when it comes to scaled institutions that are operating in 50 states.

Amy Glynn (05:00.105) Absolutely.

Wesley Smith (05:01.56) Cam, what are your thoughts on presidents? What should they be prioritizing as they build towards Workforce Pell eligible programs?

Cameron Mortensen (05:10.32) Yeah, to play to continue on the cross state functionality piece is as as the laws written programs eligible for work for spell are going to be have to be approved by the state’s governor.

So it’s going to be really important for states and institutions to create a system where programs, especially those delivered online by institutions across the country, can be reviewed and approved so that students learning across the country are able to access these funds for programs that are relevant in more than just one state. So we’re going to need to all work together, states, governors, states, and institutions, in order to find the way to most efficient.

efficiently do that.

Wesley Smith (05:54.402) Yeah, right. mean, that’s going to be, hopefully, we can piggyback on, Sarah, or some other system that gets us essentially consensus from the states on what programs should meet these requirements and what programs don’t. I guess the tension there is

It’s really designed for local workforce as well. I don’t know if there is an easy resolution to this other than saying collaboration is really, really important as we move forward. Any thoughts on that, Amy?

Amy Glynn (06:31.062) that’s a big one to tackle. I agree with you absolutely, collaboration is key. We are already seeing states roll out proposed legislation and language that would have different accountability measures than the federal government would have different requirements. And so really trying to figure out how to find a solution that is elegant.

and well positioned to protect both students and institutions will be really important in seeing success in workforce Pell implementation.

Wesley Smith (07:10.518) Yeah, lots of work left to figure these things out, especially on 50 state operations. Let’s talk about a little bit, though. You mentioned states are working on some accountability, and the accountability framework is tough to say exactly what it should be. But tell us, we’re at the president’s forum, so we care about student-centric accountability frameworks. What does that look like? How can we do that without blocking innovation?

Amy Glynn (07:39.629) Yeah, I think the key here for the accountability conversation is about balance. We have to get the balance right. We absolutely want to protect students and ensure quality, but we also have to make sure we’re not building something so complex that institutions pull back from serving those students. And so one thing that’s really important is recognizing

how working learners actually move through education and getting our voice into the conversation about establishing these metrics. So with these programs, the goal is actually to increase access to stackability of the credentials so that students can re-enroll quickly.

their earnings won’t always show up in a straight line. So schools should not be penalized for having a student move more quickly into a subsequently related program. So if we don’t design these metrics carefully, looking at who’s included, when we measure, we risk missing the real value of the programs, especially for the non-traditional working adult. And so when you think about this,

Fairness really matters, right? Institutions serving students online or across states should not be at a disadvantage to traditional brick and mortar institutions. And right now there really is a risk of that. So at its best, accountability should create clarity and trust, but still leave room for institutions to respond to those workforce needs. And we need to work with our federal partners and the state partners in that triad to make sure that happens.

Wesley Smith (09:12.216) Well, I mean, to your point, the whole reason Workforce Pell was considered a necessity by legislators, by Congress, Congress thought, hey, we have some pathways to opportunity that aren’t necessarily four-year or bachelor’s or associate degrees. Whatever those look like right now, they’re not that. They’re short-term credentials that could work. And the idea here is to make these accessible to as many people as we can.

The risk that we run is with accountability frameworks that are too robust, do you actually discourage people from moving in that direction and programs from qualifying for those? But at the same time, you want to make sure that if you are putting federal dollars and investing those behind them, you get it right and you do have workforce opportunities that result in it. So Cam, tell us what your thoughts are on accountability. How do you strike that right balance?

Cameron Mortensen (10:11.43) Yeah, I think Amy’s point on on credential stacking is really important because if we set up an accountability system that is tracking the is always tracking the income of students right as they come out of programs, we’re going to de incentivize.

institutions that are encouraging students to continue their education after these workforce training programs. And I don’t think that’s necessarily the motive that we want to give. as Amy said, we really want to be student focused. We want to focus on we all I also think it’s really important that we have an accountability system that does focus on outputs rather than delivery method or other sorts of inputs. But there’s just really important nuances such as

the credential stacking.

that we need to make sure we get right. I think one other point is we don’t want to have a constantly, we don’t want to constantly be moving the goalposts. Let’s get, let’s set up a system and let’s stick to it and let’s take the time to make sure we get it right. Actually, I don’t want to say stick to it. I, I’m going to reset that part. let’s, let’s take our time to set up a system that we can all feel good about and is, is bringing true accountability, which, which we support, but let’s get it right. And let’s not try to

rush into something that will lead us to having to change it soon after.

Wesley Smith (11:37.548) Right. You did say something, Kam, that every time I hear it, I want to say amen while people are mid-sentence to it. And that is we should be working with outcomes, not inputs, when it comes to accountability. We shouldn’t be telling institutions how to get the right outcomes. We should be judging them based on their outcomes. And that’s just one of the fundamental principles that the President’s Forum has been.

advocating for decades now at this point.

Let’s let me let me move us to the final question and that is I want to look beyond workforce Pell and I want to look at other aspects of the ahead rulemaking What should institutions watch for? In any other regard Let’s not let’s put workforce Pell aside and look at other issues that that ahead addressed

Wesley Smith (12:39.382) Amy, why don’t you lead on this?

Amy Glynn (12:41.182) Yeah, so as we look what’s coming through the AHEAD and the AEM negotiations, I think the president should really be focused on how accountability is taking shape in practice. We know the direction. There’s going to be a stronger emphasis on earnings and outcomes, return on investment. We’ve seen it in AHEAD, obviously, in the accountability framework. We’ve seen it in the accreditation negotiations.

But the details really matter. How cohorts are defined. How long is data aggregated? Whether we’re accounting for students who continue their education. Those are things that are really going to determine whether these metrics actually reflect reality. The other thing I’d watch for is complexity. There’s a risk of building something that’s technically sound, but really hard to implement given our outdated data structure.

And that can slow down innovation, especially for workforce programs that need to move quickly. And then just making sure that all of this aligns with how students actually progress today, especially in our stackable pathways. For me, it’s more, it’s a moment less about where policy is going and more about whether we got the design right.

Wesley Smith (13:58.776) Right. I love your point about complexity. It’s getting it right, being right theoretically is a lot different than being right practically and driving outcomes for students. And complexity has that ability to kind of suffocate innovation if we spend too much time on the complexity of measuring outcomes. So we’ve got to get that. We’ve got to have solid outcomes, but we have to do it in a way that doesn’t suffocate innovation.

Cam, tell us anything to add to that. What else should we be looking for in the ahead rulemaking?

Cameron Mortensen (14:36.848) Yeah, I mean, just as far as kind of a schedule goes, there’s obviously a lot happening right now as far as higher education regulation executive rulemaking goes. The public comment period for the workforce Pell portion of AHEAD just closed. That’s what we’ve been talking about today. We are also going to get an NPRM, a notice of proposed rulemaking on the accountability measures that were considered in the AHEAD rulemaking.

that this is published, we’ll have finished the first week of that accreditation, innovation, and modernization or AEM negotiation. And then the next session of that will be taking place in May the 18th through the 22nd. So there’s a lot going on right now, a lot that we as the President’s Forum are following and will be involved in. So definitely stay tuned and we’re always happy to hear others’ thoughts and input as well.

Wesley Smith (15:36.142) Thanks, Cam. Thanks, Amy. We appreciate you joining us and giving us some insight on Workforce Pell specifically and what’s next in the ahead rulemaking.

Cameron Mortensen (15:46.374) Thanks.

Amy Glynn (15:47.319) Thanks for having me.

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