The AHA has submitted a comment to the Federal Register opposing the Department of Education’s proposed changes to academic accreditation regulations. The proposed changes, the AHA wrote, would “weaken protections for the scholarly standards and practices that sustain the historical discipline, threatening the quality and integrity of both history instruction and scholarship at many different types of institutions.” The AHA identified multiple issues in the proposal, including issues related to academic freedom, the educational value of history, and faculty expertise, among others.
The AHA’s full comment is reproduced below. Learn how you can voice your opposition to these proposed changed here.
September 18, 2026
To: Department of Education
Re: Accreditation, Innovation, and Modernization: Secretary’s Recognition of Accrediting Agencies: Institutional Eligibility under the Higher Education Act, as Amended, Student Assistance General Provisions (ED-2025-OPE-1042-0002)
The American Historical Association (AHA) appreciates the opportunity to provide feedback on the Department of Education’s proposed rule, “Accreditation, Innovation, and Modernization: The Secretary’s Recognition of Accrediting Agencies.” Founded in 1884 and incorporated by Congress in 1889 for the promotion of historical studies, the AHA is the largest membership association of historians in the world with 10,000 members and 135 affiliate organizations representing a vast portion of the history community. Our members work in colleges and universities, K–12 schools, museums, archives, libraries, and many other settings.
The AHA has reviewed this proposed rule with particular attention to its likely implications for the teaching and study of history in higher education. From this perspective, the proposed accreditation system would weaken protections for the scholarly standards and practices that sustain the historical discipline, threatening the quality and integrity of both history instruction and scholarship at many different types of institutions. In particular, the proposed regulations would narrow the definition of educational quality by emphasizing economic returns and short-term employment outcomes; invite accrediting agencies to overrule evidence, disciplinary standards, and scholarly judgment in favor of ideological litmus tests; and encourage cost-based approaches to faculty and program evaluation that do not adequately account for the educational and scholarly functions of departments, including those in history and related fields.
The AHA therefore urges the Department not to finalize the accreditation rule in its current form, and objects specifically to the following issues:
- Academic Freedom, Freedom of Inquiry, and Intellectual Diversity
Proposed §§ 602.17(a)(2)(iii), 602.17(a)(2)(vii), and 602.17(a)(2)(viii)
The proposed regulatory language conflates two distinct concepts: intellectual diversity and ideological diversity. True intellectual diversity is integral to the production of new knowledge. Students benefit from encountering unfamiliar perspectives. Faculty likewise must be free to pursue legitimate scholarly inquiry wherever the evidence and disciplinary standards lead, including inquiry that challenges prevailing interpretations or assumptions. Reflecting core disciplinary commitments, the AHA supports these principles and agrees that institutions should foster environments in which an array of scholarly perspectives can be expressed and examined. Intellectual diversity involves institutions fostering a wide range of academic pursuits, and teaching that range of methods and habits of mind to students. When adequately supported in their intellectual pursuits, academics representing a wide range of disciplines enrich intellectual diversity at their institutions.
Intellectual diversity, however, does not require treating all ideas or interpretations as equally valid. Historians evaluate competing claims according to established standards of evidence, argument, methodology, and disciplinary expertise. The proposed regulations risk conflating openness to diverse ideas with a requirement that institutions demonstrate a particular balance of viewpoints. For history and related disciplines, this distinction is especially important. The range of historical interpretations is determined through scholarly inquiry, the balance of available evidence, and disciplinary standards, not by the political or ideological affiliations of individual faculty members.
The AHA endorses the 1940 Statement of Principles on Academic Freedom and Tenure by the American Association of University Professors: “The common good depends upon the free search for truth and its free exposition. Academic freedom is essential to these purposes and applies to both teaching and research. Freedom in research is fundamental to the advancement of truth. Academic freedom in its teaching aspect is fundamental for the protection of the rights of the teacher in teaching and of the student to freedom in learning.” Principles of academic freedom are central to the American Historical Association’s Statement on Standards of Professional Conduct.
The proposed § 602.17(a)(2)(vii)(B) would require agencies to evaluate institutional policies protecting faculty in teaching, scholarship, and research within their academic disciplines, including “including conditions under which a range of academic perspectives may be expressed and examined without adverse action based on lawful viewpoints unrelated to professional or academic competence.” Proposed § 602.17(a)(2)(viii) would additionally require institutions to maintain policies designed to “support, promote, and appropriately prioritize intellectual diversity and the free exchange of ideas amongst faculty,” including explicit measures of student and faculty perceptions of the range of viewpoints offered by an institution or program. Although the Department states that its intent is not to prescribe specific policies or override institutional autonomy, these provisions could invite accrediting agencies to make judgments about whether particular faculty, curricula, or programs exhibit an appropriate degree or distribution of intellectual or ideological diversity. For history and related disciplines, such judgments risk displacing the disciplinary standards and informed, scholarly appraisals that appropriately guide teaching, research, and scholarship.
Accreditation must not become a mechanism for determining whether the faculty or curriculum of a history department contains a particular distribution of political or ideological viewpoints. Nor should institutions be required to present competing interpretations as equally supported when the weight of historical evidence does not bear such equivalence. Evaluating faculty or academic programs according to ideological commitments would provide no reliable measure of intellectual diversity and could instead encourage accrediting agencies to treat political or ideological balance as a proxy for scholarly quality.
The AHA further urges caution regarding the use of student and faculty perceptions under § 602.17(a)(2)(viii) as evidence of an institution’s achievement of intellectual diversity. Surveys can provide useful information about whether students and faculty perceive opportunities for intellectual engagement and the expression of differing perspectives. They cannot, however, independently establish whether a department’s scholarship or curriculum merits accreditation. Survey responses therefore should not serve as an independent basis for determining whether a department’s scholarship or curriculum reflects an appropriate range of disciplinary perspectives.
Accordingly, the AHA recommends that the final rule make clear that accrediting agencies may evaluate whether institutions protect academic freedom and foster an environment conducive to the free exchange of ideas, but may not evaluate faculty, curricula, scholarship, or teaching according to political or ideological balance. This clarification would preserve the legitimate goal of encouraging intellectual diversity while protecting the disciplinary standards and scholarly judgment essential to the quality and integrity of higher education.
- Measuring the Educational Value of History
Proposed § 602.17(a)(1)(ii)(A)–(E)
The AHA is further concerned about the proposed requirement for accrediting agencies to measure student success using “educational and economic returns aligned to the program’s credential level, length, and occupational context relative to the total cost of attendance.” The proposed regulation specifies that such returns may be assessed using earnings data calculated under 34 CFR part 668, enhanced Unemployment Insurance wage records, or other reliable earnings data available to the agency.
Students deserve transparent information about the costs and outcomes associated with higher education. However, employment and earnings data are not interchangeable with measures of educational quality. History is a disciplinary field with graduates who enter a wide range of occupations rather than a single identifiable labor market. Students trained in history work in education, government, museums, archives, libraries, law, journalism, communications, nonprofit organizations, business, technology, public policy, and many other fields. The skills developed through historical study—such as conducting research, interpreting complex sources, communicating arguments, and assessing competing claims—are transferable to a wide range of careers.
The Department’s proposed language recognizes that educational and economic returns are aligned to the “occupational context” of a credential. For history, however, this context is unusually broad. A measure that associates a history degree primarily with the earnings of graduates in a narrow set of occupations would fail to capture the actual educational and occupational uses of historical training.
Moreover, some of the most important outcomes of historical education are not readily measurable through earnings data. Historical education prepares students for further education, professional training, public service, civic participation, and forms of work in which research, writing, interpretation, and evidence-based reasoning are central but difficult to isolate statistically as the product of a particular degree.
The AHA therefore calls for a significant revision of the Department’s proposed rule change, to specify that economic returns are one category of evidence concerning student outcomes, rather than a proxy for the intrinsic educational quality or value of a disciplinary program. The AHA requests the revision of § 602.17(a)(1)(ii)(E) to make clear that educational and economic returns are complementary measures and that no accrediting agency may treat earnings, employment, or other economic indicators as a standalone measure of the quality of a program.
III. Faculty Expertise, Staffing, and Educational Quality
Proposed §§ 602.17(a)(2)(i) and 602.17(a)(2)(iv)
The AHA supports appropriate institutional flexibility. But flexibility in staffing is not a hallmark of educational quality.
The proposed rule asks accrediting agencies to evaluate whether institutions maintain a sufficient number of appropriately qualified faculty and other subject-matter instructors and whether institutions maintain “sufficient flexibility in instructional staffing policies and procedures to respond to persistent material changes in student demand, program viability, or financial conditions.”
Historical education depends upon faculty expertise. History departments across the country are composed of instructors with specialized knowledge of particular historical periods, regions, languages, methodologies and sources. The range of expertise necessary to provide a meaningful historical education may not correspond neatly to student demand in any single semester or academic year. For example, a department may need faculty expertise in a language or geographical area even when enrollment in courses using that expertise is relatively small. Such expertise is essential to the department’s overall curriculum, research capacity, and ability to train students in specialized fields and prepare them for a variety of careers.
Regardless of specialty, faculty members are qualified to and may teach introductory courses, advise students, supervise undergraduate and graduate research, maintain institutional relationships with archives and other institutions, and contribute to interdisciplinary programs. Their value to an institution cannot be assessed solely by enrollment in individual courses.
A university that retains only the fields with the highest immediate enrollment would substantially narrow the range of historical questions its students could study. The AHA urges the Department to eliminate the provision in § 602.17(a)(2)(iv) that establishes staffing flexibility as a preferred alternative to stable and appropriately qualified faculty. Accrediting agencies should evaluate staffing in relation to an institution’s educational mission, the range of programs it offers, and the disciplinary expertise necessary to fulfill those programs.
The Department should also clarify that “student demand” must not be interpreted solely through short-term course enrollment. Persistent educational needs, degree requirements, research programs, advising responsibilities, interdisciplinary teaching, language instruction, and other contributions to institutional and student learning should be included in assessments of staffing needs.
- Cost-Benefit Analysis and the Institutional Role of History
Proposed § 602.17(a)(3)(i)
Finally, the AHA opposes the proposed rule requiring accrediting agencies to conduct a cost/benefit analysis that includes review of an institution’s budget, resource utilization and allocation, strategic plans, and whether the expected benefits of institutional activities justify their associated financial, administrative, and opportunity costs. The Department estimates that accrediting agencies would conduct approximately 5,000 such analyses annually, requiring approximately 750,000 hours of work—a massive undertaking in terms of time and resources. The proposed provision would benefit from greater detail regarding how educational and scholarly benefits are to be evaluated in order to justify the massive increase in annual workload for accreditors.
A university is composed of academic departments that collectively provide the educational, scholarly, and institutional resources through which the university fulfills its mission. Beyond rigorous undergraduate education in historical methods, history departments contribute to general education, teacher preparation, interdisciplinary study, graduate education, public programming, archival and library use, and the preparation of students for a broad range of careers.
These benefits extend well beyond the students formally enrolled as history majors. A historian teaching a course in a general education curriculum may educate hundreds of students from across their institution. A faculty member’s research may contribute to museum exhibitions, documentary projects, community partnerships, policy discussions, and many other outlets beyond the university. These activities are highly beneficial to the institution, even though they may not produce readily attributable financial returns.
The Department’s proposed framework should therefore distinguish between cost efficiency and educational value. A program should not be judged inefficient merely because some of its benefits cannot be reduced to direct revenue, enrollment, or earnings measures. The AHA recommends that § 602.17(a)(3)(i) be revised to require accrediting agencies to consider educational, scholarly, institutional, and public benefits when evaluating the costs of institutional activities. The Department should further clarify that cost-benefit analysis must not be used as a standalone basis for determining whether an academic discipline or program provides sufficient educational value.
Conclusion
The American Historical Association supports the Department’s interest in a higher education accreditation system that is rigorous, transparent, accountable, and responsive to the needs of modern students. The AHA is concerned, however, that several sections of the proposed rule will narrow the meaning of educational quality and will result in graduating students who are unprepared to enter the workforce. Accreditation should protect academic freedom without requiring political or ideological balancing; it should measure intellectual diversity without substituting political categories for disciplinary judgment; consider employment and earnings without treating economic outcomes as proxies for educational value; promote responsible staffing that values faculty expertise; and encourage cost-conscious decision-making without reducing the value of academic programs to their direct financial returns.
The quality of historical education depends upon the freedom to investigate the past, the expertise required to interpret evidence, and the institutional structures that allow scholars and students to pursue sustained inquiry. A strong accreditation system should protect and strengthen those conditions rather than undermine them, which is why the proposed rule must not be adopted in its current form.
Respectfully submitted,
Sarah Weicksel
Executive Director