After the pandemic prompted a move to online instruction, accreditation—usually not an issue for established institutions like Carleton—has come to the foreground. 

Accreditation is a process by which the Department of Education (DoE) ensures that institutions of higher learning, like Carleton, maintain certain standards of educational quality. Accreditation agencies are private educational associations that conduct oversight on behalf of the DoE.

Carleton’s accreditation body is the Higher Learning Commision (HLC), an independent nonprofit agency which oversees accreditation for colleges and universities in 19 states throughout the central US. The HLC conducts reviews every 10 years, with Carleton’s last review in May 2019. 

Accreditation reviews are analogous to health inspections at  restaurants, but instead of checking whether employees wash their hands and cook the chicken all the way through, accreditation bodies like the HLC check whether institutions like Carleton conform to standards regarding credits in a degree, faculty qualifications and, importantly in 2021, how much online instruction can be provided at an in-person college like Carleton. 

A US Department of Education policy enacted in 2006 established that “distance education programs were not required to be evaluated or approved by an accrediting agency if the institution did not offer more than 50% of its courses via distance education, have more than 50% of its students enrolled in distance education, or offer more than 50% of an educational program via distance education,” according to the HLC website. 

Before the pandemic, this was no issue for Carleton, which offered few online courses. When the pandemic began and Carleton switched to remote learning in spring of 2020, the college received an Emergency Distance Education Waiver from the HLC that May. 

The waiver “allows institutions to initiate or expand distance education beyond the extent of their current approvals, solely to accommodate interruptions in study related to COVID-19,” according to a document titled  Temporary Emergency Policy Related to COVID-19 and published by the HLC. Carleton was given permission to offer expanded distance education until “the public health emergency is no longer present.” 

“Carleton has been approved for distance education courses during the pandemic, so long as the federal [government] declared emergency related to COVID-19 is in place,” said Dean of the College Gretchen Hofmeister. “We don’t know when the federal government will lift this declaration, but we assume that it still applies through Summer 2022.”

Despite some confusion, it would seem that Carleton is out of the woods when it comes to accreditation. The college easily clears the DoE benchmarks that would require further accreditation for distance learning. As of Winter 2022, Carleton 1) offers less than 50% of its courses via distance education, 2) has less than 50% of its students enrolled in distance education and 3) has no program which offers more than 50% of an educational program via distance education.

However, on the very last day of the Trump Administration, the Department of Education issued an announcement titled Guidance on Accreditation and Eligibility Requirements for Distance Education. This announcement overruled the previous guidelines. Under these new rules, “before an institution offers any distance education programs(…) the institution must be evaluated and accredited for its effective delivery of distance education.” 

This would mean Carleton would have to undergo a rigorous evaluation and accreditation process by the HLC to be eligible to give any online instruction. It is unclear what this process would look like, whether Carleton would pass and what the consequences would be if it did not pass. 

However, the Secretary of Education has waived the requirement for Carleton until “the end of the payment period that begins after the date on which the federally declared national emergency related to COVID-19 is rescinded,” according to the Guidance on Accreditation and Eligibility Requirements for Distance Education. In other words, Carleton is not in any danger, given the Emergency Distance Education Waiver it received in May of 2020 — at least until the national emergency is lifted. 

Yet one requirement of the new regulations remains, despite the federally declared COVID-19 emergency. Colleges like Carleton still must submit a “substantive change request” to the HLC if they “increase distance education to exceed more than 50 percent of a program or of the institution’s overall delivery of education.” 

In this context, “program” is defined as a certain degree, such as a Bachelor of Arts in History or Biology. A “substantive change request” is a request for a change in an institution’s educational offerings to an accreditation body like the HLC, which then approves or denies the request. Examples include “expanding its academic offerings, opening a new location, changing its mission, etc.” As long as Carleton stays under the 50% threshold, they will not have to submit a substantive change request. 

Administrators like Hofmeister are working to keep Carleton in line with these new rules. 

“Our programs will be compliant with our current accreditation status so long as we do ‘not offer more than 50% of an educational program via distance education’ in the words of the HLC,” said Hofmeister. “To ensure this is the case, we are tracking students’ degree audits to confirm that none have more than 50% of their 210 credits in online courses.” 

So for now, Carleton remains in the good graces of the HLC–as long as no student reaches the magic number of 105 credits of online instruction. Even so, myriad questions and problems will emerge the second the national emergency due to COVID-19 is lifted. If Carleton continues to give any online instruction, the college will have to go through the laborious and uncertain process of being evaluated and accredited as a provider of distance education.