On January 23, 2026, the Council for Recognized Accrediting Commissions (C-RAC) submitted the following comments regarding the USDOE Accreditation Handbook:

January 23, 2026 

David Barker, Assistant Secretary 

Office of Postsecondary Education 

U.S. Department of Education 

400 Maryland Avenue, SW 

Washington, DC 20202 

RE: Docket ID: ED–2025–OPE–1009 

 
Dear Mr. Barker: 
 
The Council of Recognized Accrediting Commissions (C-RAC) appreciates the opportunity to provide comments in response to the Department of Education’s (ED’s) December 11, 2025, request for information (RFI) on updates to the Accreditation Handbook (Handbook). 

C-RAC represents seven federally recognized institutional accrediting commissions that are responsible for accrediting nearly 3,000 postsecondary, degree-granting colleges and universities across the United States. These include over 1,500 public, 1,100 private non-profits, and nearly 100 private for-profit institutions with a broad set of missions and constituencies. 

C-RAC’s members are the Accrediting Commission for Community and Junior Colleges (ACCJC), Higher Learning Commission (HLC), Middle States Commission on Higher Education (MSCHE), New England Commission of Higher Education (NECHE), Northwest Commission on Colleges and Universities (NWCCU), Southern Association of Colleges and Schools Commission on Colleges (SACSCOC), and WASC Senior College and University Commission (WSCUC). 

C-RAC believes the Handbook provides useful guidance for accreditors to comply with the Higher Education Act (HEA) and corresponding regulations. In the RFI, ED notes the “Handbook does not supersede applicable law or regulations; rather, it is intended to be a useful resource to describe in plain terms how to meet the Secretary’s Criteria for Recognition and submit a successful petition to the Department.” We agree with this intent, but note that there are instances in the current Handbook where this is not always the case. 

While useful, we believe there are many ways the Handbook could be improved as part of a broader effort to streamline the recognition process. In many cases, as highlighted below, this involves reducing the amount of documentation required to be submitted to ED as part of agency petitions while using other means to demonstrate compliance. We also believe the use of the accreditation portal could serve as a useful mechanism for better guiding agencies through the recognition process.  

Our recommendations for achieving this goal are captured in the following responses to the questions raised in the RFI, as follows:

Are there particular pain points that the Department should be aware of?  

The Handbook directs agencies to provide voluminous data to ED, including data already submitted as part of other existing requirements. In some cases, agencies are required to demonstrate compliance by submitting information on each of their institutions as part of their petition, whereas a representative sample would be more appropriate. In these cases, additional specific institutional information could be made available for compliance spot checking during file review, which is a far less burdensome process and would focus petition requirements on more general policy and forms.

Another solution for reducing paperwork is by expanding the use of case studies, where accreditors provide information about the same institution as it moves through various steps of the evaluation process. This is an efficient and effective way to assess accreditor compliance with particular regulations. 

There are also instances where submissions could be eliminated altogether because they provide limited value or establish requirements not reflected in law or regulations.

Below are specific examples of where such changes should be reflected in the Handbook: 

§ 602.11 Geographic area of accrediting activities

As part of its petition, an agency is required to provide:

• A copy of the notification to the Department of the change in geographic area of accrediting activities.
  • Such notifications are already in the possession of the Department.  
• Links to all locations where the agency has publicly disclosed the change in geographic area of accrediting activities.
  • There is no clear value in providing all such links versus simply ensuring each agency website provides such information. 

§ 602.15 Administrative and fiscal responsibilities. 

• This section requires a significant amount of data and information (not listed here) to be included as part of the petition as well as prepared for file review.
  • In lieu of these extensive requirements, agencies could provide illustrations of compliance with the regulations related to administrative and fiscal responsibilities. Such illustrations would allow for, but not require, the specificity of the information reflected in the current Handbook.
  • At a minimum, much of the information required in the petition, such as job descriptions of senior staff, financial statements, and annual budgets, as well as having “a roster of all individuals who in the past year participated on site visit teams, how many reviews each participated in, with an indication of the specific focus of each member on that team” should be moved to file review and not be required in the petition.
  • This section also requires a petition to include a “list of any site visits, agency decisions, or other reviews that had to be postponed during the prior two years and the reason for the postponement.” This information should be moved to file review.

§ 602.16 Accreditation and preaccreditation standards. 

• This section requires a significant amount of information to be included as part of an agency’s petition that is already provided to ED.
  • The Department may narrow this list to streamline the petition process.  We suggest the following information be removed as part of the petition:
    • A list of all programs or institutions granted preaccreditation during the recognition period and any actions on accreditation and their relevant dates for each.
    • A list of institutions or programs that have been approved to offer distance education, correspondence courses and/or direct assessment programs during the recognition period, if applicable. 
    • A list of institutions preaccredited or accredited by the agency that, by request of the institutions, do not have participation in title IV, HEA programs included in their scope of accreditation, if applicable under § 602.16(b).

Much of the information required to be submitted per the following sections should instead be part of a file review. In cases where the purpose of these specific submissions is to understand the process used by the agency, a case study, along with additional illustrations from institutions that meet the specific criteria included in the regulations, is appropriate for documenting compliance.

§ 602.12 Accrediting experience

As part of its petition, an agency is required to provide:

• A list of all institutions and/or programs that the agency has accredited or preaccredited during the previous five years, including their geographic location, credential levels included in the preaccreditation or accreditation, the dates on which the institutions/programs applied for accreditation/preaccreditation, and the dates on which the institutions/programs received accreditation or preaccreditation, if accreditation or preaccreditation has been awarded. 

§ 602.18 Ensuring consistency in decision-making. 

As part of its petition, an agency is required to provide:

• A list of institutions or programs that received permission to be out of compliance with standards, for a period not to exceed three years, during the period of recognition and the reason for permitting the non-compliance. 
• A list of institutions or programs to which retroactive accreditation decisions were applied during the period of recognition. 
• A list of programs or institutions that the agency has determined are using innovative program delivery approaches and/or that were assessed under alternative standards, policies, and procedures, if applicable, during the period of recognition. 

§ 602.19 Monitoring and reevaluation of accredited institutions and programs. 

As part of its petition, an agency is required to provide:

• Copies of notifications to the Secretary for institutions that have experienced an increase in headcount enrollment of 50 percent or more within one institutional fiscal year, if applicable. 
• A list of the institutions or programs that have met the agency’s definition of significant growth, if applicable, and documentation demonstrating the agency’s actions and response to institutions experiencing significant enrollment growth. 

§ 602.20 Enforcement of Standards 

As part of its petition, an agency is required to provide:

• A list of institutions or programs against which the agency has taken an adverse, probation, show cause, or an equivalent action during the recognition period, if applicable, and if so, the length of longest program at the institution or the length of the program, for a programmatic agency, the action taken, the date the action was taken, communication with the institution or program, including the written timeline for coming into compliance, and any resolution or subsequent final action. 

§ 602.22 Substantive changes and other reporting requirements. 

As part of its petition, an agency is required to provide:  

• A copy of a substantive change review (application, correspondence, and decision letter) for each type of substantive change request made during the current recognition period. 
• A list of substantive change requests made by institutions, the status of those requests during the current recognition period, and whether each was subject to notification. 
• A list of additional locations that have been opened during the current review period, if applicable, and whether each was subject to prior approval. 

§ 602.24  Additional procedures certain institutional agencies must have. 

As part of its petition, an agency is required to provide: 

• A list of institutions required to submit a teach-out plan and/or teach-out agreement during the recognition period, whether a plan or agreement was required, when the plan or agreement was submitted, and if applicable, a date of closure for the institution.

§ 602.26 Notification of accrediting decisions. 

As part of its petition, an agency is required to provide: 

• Links to all locations where the agency provides written notification to the public of any action or final decision taken against an institution or program. 
• For each institution or program against which the agency has taken probation, show cause or an equivalent, or an adverse action during the recognition period, include a list of all actions the agency has taken for the institution or program in the previous five years (including warnings, monitoring requirements, or other actions). 

§ 602.28 Regard for decisions of States and other accrediting agencies 

As part of its petition, an agency is required to provide: 

• A list of institutions or programs for which the agency received information about an action by a State or another accrediting agency as described in § 602.28(b), along with the dates of subsequent review and action taken by the agency, if applicable. 

What policies or practices should be updated in the current version of the Handbook from February 2022?  

In addition to policies referenced in the above question related to “pain points,” other areas should be updated from the current version of the Handbook. Specifically:

• Where there is flexibility, the Department should give factors that delineate the parameters of consideration. This ties to the compliance reports and monitoring reports. The monitoring report is more “optional” but there is no indicator of when and how those determinations are made. If anything, they could give guidance around when a monitoring report might be required because the regulations make it discretionary with substantial compliance. See § 602.34.
• There needs to be greater consistency in expectation of evidentiary documentation required in the petition and the file review. 
• There should be a shorter timeline in the recognition process overall so that agencies are not in a continuous process of preparation for petitions or compliance reports over the five-year cycle. In addition, the overall length of recognition should be extended beyond 5 years in cases where an agency is deemed to have lower risk based upon their prior record of compliance. This would reduce time and cost on the part of both agencies and the Administration. 
• The e-recognition portal should be leveraged to provide the types of guidance and clarity for recognition which is currently limited to the Handbook.   

Are there any inaccuracies, inconsistencies or inclusions within the Handbook that are counter to the regulations contained in 34 CFR 602? Additionally, are there any items within the law or regulations that need further explanation? 

Page 3 of the Handbook, under “standard of review,” provides definitions for the terms “fully compliant,” “substantially compliant” and “not compliant.” Although these are terms referenced under 34 CFR 602, only “substantially compliant” is defined in regulations. The Handbook should be about clarity. Terms, such as these, should instead be defined as part of regulatory or sub-regulatory guidance.

We appreciate your efforts to ensure the process for the Department’s recognition of an accrediting agency is transparent, efficient, and not unduly burdensome. C-RAC remains ready to work with you and others at the Department as you update the Accreditation Handbook. 

Again, thank you for the opportunity to submit these comments. Please contact the Chair of C-RAC, Dr. Heather F. Perfetti, by phone at (267) 284-5026 or by email at hperfetti@msche.org if we can provide additional information or lend our expertise.    
 
Sincerely, 

Dr. Heather F. Perfetti C-RAC Chair President, Middle States Commission on Higher Education (MSCHE)	Dr. Selena M. Grace, President Northwest Commission on Colleges and Universities (NWCCU)
Dr. Mac Powell C-RAC Vice-Chair President, Accrediting Commission for Community and Junior Colleges (ACCJC)	Dr. Stephen Pruitt, President Southern Association of Colleges and Schools Commission on Colleges (SACSCOC)
Dr. Barbara Gellman-Danley, President Higher Learning Commission (HLC)	Dr. Maria Toyoda, President WASC Senior College and University Commission (WSCUC)
Dr. Lawrence M. Schall, President New England Commission of Higher Education (NECHE)