Insights & Research

The Quality Enhancement Plan, Hold Harmless, and Institutional Trust

As we move forward with the commitments outlined in my 100-Day Plan, one issue continues to surface in conversations with presidents, provosts, and accreditation liaisons: the decision to place the Quality Enhancement Plan (QEP) in a temporary “hold harmless” status during the development of the revised Principles of Accreditation. While this has come with great acclaim from most member institutions, it has also come with its own questions, especially those who will go into the reaffirmation Class of 2028 and beyond.

At the heart of these questions is something far more important than policy mechanics, it’s trust. It’s understandable and will always be a part of the fabric of the relationship between the accountability agency and the institution being held accountable. But trust and integrity are personally critical issues to me. So, let’s dig into the QEP shall we?

What the Law Actually Says

The Principles of Accreditation have always required institutions to engage in intentional, ongoing efforts to improve student learning and success. The QEP has historically been one way to demonstrate that commitment through Standard 7.2, but it is not the purpose itself. It began as a method to show continuous improvement of institutions rather than requiring bright line indicators. But for many, over time this seems to have lost that intent and became an exercise more than an improvement plan. And for many institutions, it became a financial burden. I heard that loud and clear in my first two months at SACSCOC.

The hold harmless posture does not remove an institution’s responsibility for continuous improvement, nor does it diminish expectations for evidence-based improvement. Institutions remain accountable for doing the work of improvement and for being able to explain that work when asked.

What the hold harmless approach does recognize is fairness.

It would be unreasonable and inconsistent with sound accreditation practice to expect institutions to design, resource, or implement a long-term quality initiative after a hold harmless period. Holding institutions harmless during the transition of the revision of the Principles ensures that no institution is penalized for uncertainty created by the reform process itself.

Where the Lore Comes From

The lore emerges from a very understandable concern: “What if we’re caught in the middle?”

Institutions worry that they might pause work now, only to be judged later against expectations that were unclear, or worse, retroactively applied. Others fear that once the new Principles are complete, the QEP will simply be reinstated without regard for timing, capacity, or institutional planning cycles.

Those fears may be rooted in experience or hearsay, not imagination, and they deserve to be addressed directly. I understand those fears, but I want to assure you this will not happen here.

Law vs. Lore

✅ Law: Institutions will not be disadvantaged or penalized for decisions made in good faith during the hold harmless period.

❌ Lore: Institutions will later be judged against standards that did not yet exist.

✅ Law: Any new or revised expectations related to quality enhancement will come with a clear implementation timeline, a runway that allows institutions to plan, align resources, and act intentionally.

❌ Lore: New requirements will take effect immediately, regardless of where an institution is in its cycle.

✅ Law: Continuous improvement expectations are being re-examined to ensure relevance, coherence, and impact.

❌ Lore: The QEP will simply be put back into place exactly as it existed before.

✅ An institution may request to still have their QEP included as part of the reaffirmation review. It will not impact reaffirmation, but it will give quality feedback on an important initiative of the institution. Areas for strengthening will be provided as consultation without any potential penalty or compliance determination…and at an affordable cost.

❌ With the QEP on hold, we did all this work for nothing and can receive no feedback on our initiative.

The Pruitt Perspective

Trust matters in accreditation and it matters to me. As I said in my State of the Commission at the annual conference and to paraphrase a Kentucky state poet laureate, if the SACSCOC membership is to be a body, surely collaboration must be its heart. For that to happen, trust and integrity must be evident.

Institutions should never feel as though they are navigating reform while standing on shifting ground. My commitment is simple and firm: we will not place institutions in the middle, and we will not finalize new standards without a transparent, reasonable runway for implementation.

Equally important, we will not simply turn the QEP back on once the new Principles of Accreditation are complete. If a future quality enhancement expectation exists, it will be because it adds real value, reflects how institutions actually improve student outcomes, and can be implemented fairly and intentionally.

Accreditation should promote clarity, not caution; confidence, not compliance anxiety; innovation, not simply compliance.

So when you hear questions about hold harmless, timing, or trust, the right response remains the same:  Is that law or is it lore?

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