BIFI secretary Chris Hoofnagle filed comments with the Department of Education on Updates to
the Accreditation Handbook, an effort to “update the Handbook to ensure that the accrediting agency recognition process is transparent, efficient, and not unduly burdensome.” Hoofnagle using UC Berkeley’s accreditor as an example, explained three problems arising from the incentives created by the Handbook:
Academic quality and rigor. Current accreditation standards, as implemented by bodies like WSCUC, emphasize procedural compliance and proxy metrics (retention rates, graduation rates, institutional policies) rather than direct evidence of subject-matter mastery. The UC System’s 90% graduation goal exemplifies the problem: it is easier to meet by lowering standards than by investing in instruction. The comment proposes more meaningful alternatives, such as faculty surveys on student preparedness, honest student-to-faculty ratios, and tracking of professional licensure passage rates.
The “success of all students” frame. Well-intentioned equity frameworks have produced a range of standard-lowering practices, including completion-based grading, proliferating accommodation mechanisms, and administrative pressure for ever-greater deadline flexibility. These practices model labor-management norms rather than professional ones, and poorly prepare students for independent responsibility.
Intellectual diversity. Accreditation standards embed contested political values (framing institutional missions around “social justice” rather than knowledge-based inquiry) while doing nothing to assess whether students encounter competing viewpoints or reasoned disagreement. The comment proposes viewpoint-neutral criteria for review (CFR) language and survey-based measures of intellectual climate.
Finally, the comment argues that high-performing flagship institutions like Berkeley have long since demonstrated their quality through labor-market outcomes and research productivity, and should be subject to proportionally lighter accreditation oversight.
This comment was not filed on behalf of BIFI, but rather in Hoofnagle’s individual capacity.