One of the earliest warning signs that the coronavirus was loose in the US came in late February when researchers studying the prevalence of flu in Seattle tested old samples for coronavirus. They found that some of the samples they had collected earlier in the year were infected with the virus, so they reported this finding to health authorities. They were ordered to immediately cease testing their samples because their research subjects had only agreed to be tested for the flu, not coronavirus, and their lab was a research lab and thus not certified for clinical work.
As the New York Times piece that broke the story put it “the Seattle Flu Study illustrates how existing regulations and red tape — sometimes designed to protect privacy and health — have impeded the rapid rollout of testing nationally… Faced with a public health emergency on a scale potentially not seen in a century, the United States has not responded nimbly.”
One of the lessons of the fight against the coronavirus has been that in a crisis, regulation can be just as harmful as it is helpful. Reason.com recently ran an article with the title “Coronavirus: 10 Public Safety Regulations Set Aside in the Name of Public Safety.” It details restrictions on who can make tests kits and masks and other protective equipment that have been rescinded so that we can get more test kits, masks and protective equipment.
Similarly, some of the regulations governing the meat packing industry are being relaxed so that increased production at plants that remain open can make up for lost capacity at plants that have been closed by coronavirus outbreaks. The increase in the pace of production will make it harder for food safety inspectors to do their work, but the calculus seems to be that keeping the food supply chain functioning is worth the risk to food safety.
Keeping the higher education system functioning during the crisis may not be as immediately essential as supplies of masks and ventilators and food are, but in the long run how we respond now will shape the future of higher education and that in turn will affect how the recovery plays out.
So, has anyone contemplated the possibility that regulations meant to protect students in normal times might now be hindering our ability to educate them? Not really. The Higher Learning Commission, for example, has said that it wants to be flexible, but that intuitions should inform them of any “adjustments.” In other words, be flexible, but don’t think you can stop documenting everything you do.
Likewise, the assessment world, which enforces the biggest portion of the reporting and documentation burden that accreditors place on colleges, shows no signs of backing off.
For my sins, I subscribe to the ASSESS list serve. The other day an ominous email from the list landed in my inbox. It is a good example of how the assessors are trying to position themselves in the current crisis. The email, which had as its subject line “Measure twice, cut what?” offered a link to an article on a business news site that suggested using “robust marketing measurement capability” to ensure that firms “cut in the right places…while preserving the company’s ability to adapt and thrive in the future.” The email’s author suggested that this logic should be applied to universities too. Thus, as we
look at the potential cuts (programmatic and otherwise) that institutions will be making, it is essential that these decisions be made using good assessment data on the things that are most important — student learning, our mission(s), and overall institutional outcomes.
The assessment voice has never been more important than now!!!
It’s certainly the case that universities will be making cuts in the near future. It’s also true that those cuts should, to the extent possible, pare away the unnecessary, the frivolous, and the counterproductive parts of institutions first. We are going to face serious decisions about how we spend our money. How we choose to allocate scarce resources in the next year or two may permanently reshape higher education. So having a clear sense of mission will be essential and having valid data to work with would make that task easier.
Unfortunately, assessment offices won’t be much help here. In fact, assessment offices are the last places you should look to for valid data. I pointed this out years ago and assessment insider Dave Eubanks made a more sophisticated version of the same point a little later. The only effect this has had on the world of assessment is that they have shifted from talking about “valid data” to talking about “actionable data.” But no one ever offers an explanation for why we would want to take action based on data that they tacitly acknowledge are not valid.
In fact I expect most administrators charged with making these difficult decisions have not even considered using assessment data to decide where to make cuts. “Looks like all three philosophy students all score ‘super-di-dooper’ on their critical thinking assessment and the average for business students is ‘meets expectations.’ Oh well, I guess we better cut the marketing program…”
That administrators are unlikely to seek out assessment data to help them make decisions now, reflects their awareness that those data are basically meaningless when it comes to judging the quality of a program or what its effects on students are.
So why have they supported and funded the collection and pseudo-analysis of all those data, followed by the Kabuki theatre of “loop closing” for so many years? You know why, it’s because the accreditors demand it.
Assessment is part of a costly culture of compliance that has grown dramatically in the last decade. Colleges are expected to be able to demonstrate that they are in compliance with an extraordinarily large number of government regulations. However worthy the aims of the rules that drive us to have FERPA trainings, Title IX offices, Diversity offices, IRBs, IBCs, IUCUCs, and so on, each of those regulatory regimes creates costs. If you have ever wondered why there seem to be so many more assistant vice presidents and associate deans now, one of the reasons is that there are now a lot more rules to follow and in most cases the burden of documenting that compliance falls on the university.
The 800-pound gorilla of higher education compliance culture is assessment. Something that was a fringe activity when I got my first teaching job twenty some years ago, has become the all consuming, do-or-die, centerpiece of accreditation. Somehow accreditors will allow universities to fritter away absurd amounts of money on athletics and other vanity projects; permit private, for-profit online program managers to flog their expensive, low-quality graduate programs while hiding behind the names of public, non-profit universities; and turn a blind eye to the mass exploitation of adjuncts. Colleges can even get away with firing people for refusing to participate in the faking of assessment data. But God help you if you can’t produce the requisite tonnage of assessment reports.
Of the many compliance requirements that universities face, none is as all encompassing and pervasive as assessment. IRB affects some, but not all, research. Title IX affects some, but not all, students and faculty. Assessment is in every class, every program, and it demands the time of every wretch on campus who stands in front of a class. The budgeted costs of running assessment offices may be modest at most universities, but the costs of assessment in faculty time and attention exceed any other compliance requirement. And for those of you who don’t teach, I have bad news. The assessors have you in their sights too. The next big thing in mission creep is co-curricular assessment, which extends the non-benefits of assessment to activities like intra-mural soccer and the Quidich team.
Just as the FDA has had to get out of the way of manufacturers of medical supplies in order to get more medical supplies and the ATF has had to look the other way to let distilleries make hand sanitizer, maybe the best thing that accreditors and the assessors could do for higher education right now is to promise to take the next year or two off. Universities are going to have to make some wrenching and unprecedented changes in how they operate. They will have to cut costs and rid themselves of the unproductive parts of their operations. They will need flexibility and they will need to move fast. What better way to reduce costs, increase flexibility, and enhance morale than to take two years off from assessment?
If we are going to risk a little more e. coli in our chicken in order to have chicken at all, surely we can take a chance that the wrong action verbs are going to be deployed in some of our learning outcomes statements. I am willing to risk it if it means we can offer more education to more students. When the zombies eventually shuffle off and we stagger out of our Zoom sessions and into the light, the survivors can decide whether and how to restart assessment.
Maybe that article was right; by cutting “in the right places” now, we might just preserve “our ability to adapt and thrive in the future.”