State Authorization Landscape and Process: An Inventory, Classification, and Analysis

4 min readSep 30, 2021


Written by Erik Ness, Sean Baser, & Matt Dean

The “regulatory triad” serves many functions related to postsecondary educational quality and public accountability. Yet, two actors — regional accreditors and the federal government — have received the lion’s share of attention in the regulation of institutions. Recently, however, higher education leaders and policymakers have called our attention to the role of states in the initial and continuing authorization of postsecondary education institutions. Perhaps most notably, the State Higher Education Executive Officers Association [SHEEO] has highlighted its policy relevance through a white paper (Tandberg, Bruecker, & Weeden, 2019), a series of research projects, and a community learning project with nine state agencies. These efforts arise in large part because states have been seen as “the forgotten stewards of higher education quality” (Bruckner, 2020) and “where accountability goes to die” (McCann & Laitinen, 2019). The irony of states as “forgotten stewards” of quality is that 98% of U.S. degree-granting institutions operate within the legal authority of state governments (Contreras, 2020). As with many elements of state higher education, we know that there is a wide array of approaches to structure, authority, governance, funding, capacity, process, and policy objectives.

With the support of SHEEO and Arnold Ventures, we conducted a 50-state inventory of state authorization efforts that classified states into four distinct categories based on the centralization and stringency of these authorization approaches. We measure centralization by the number of governing entities, authorizing agencies, and application processes in the state. These range from a highly centralized approach of states with a single authorizing agency with its own governing entity to states with three or more governing bodies and authorizing agencies. We measure stringency based on 41 metrics of initial authorization applications related to organization and governance, academics, consumer protection, and student outcomes.

Our findings reveal four distinct approaches to state authorization of postsecondary education. The protective approach, which includes states with high centralization and high stringency, has the highest number of states (19 plus Washington, D.C.). Nearly all states with the most stringent approach are in this quadrant. Moreover, the centralized structure limits the number of governing entities and agencies involved in the authorization process, allowing states to take a consistent approach. The measured approach (low-centralization, high-stringency) includes states with moderate levels of stringency and centralization. This professionalized, measured approach may also be related to the SHEEO agency serving as a governing entity in all but one state. By contrast, the autonomous approach (low-centralization, low-stringency) includes the least number of states (seven) and the most varied approaches to authorization with multiple governing entities and relatively low stringency. In several states within the category (e.g., North Dakota and Utah), there are extreme differences in stringency between agency approaches. Finally, the independent approach (high-centralization, low-stringency) includes states that seem to take an intentionally laissez-faire approach to authorization. All states with the lowest stringency scores appear in this quadrant. This quadrant also has the highest proportion of non-education governing agencies. The SHEEO agency serves as a governing entity in less than half the states in this quadrant.

Our inventory reveals significant variation of state approaches to the stringency and centralization of authorization efforts. This variation warrants further scholarly attention to understand the effects of these approaches on state, campus, and student outcomes. We also offer three recommendations for policy and practice.

First, we join the recommendation of SHEEO and other policy organizations to enhance the state role in the regulatory triad. For example, states could better assure quality by actively engaging with accreditors in the coordination of joint site visits and better protect consumers by implementing stricter state-level requirements for authorization based on existing federal financial responsible scores.

Second, state higher education officials and leaders should craft an intentional approach to postsecondary education authorization within their state. This is not to say that all states should strive for a more centralized, streamlined approach to authorization. Rather, all states should consider how their authorization approach aligns with broader state objectives, regardless of their centralized authorization landscape and process. States with multiple agencies may be at risk for the silo effect. These states should find intentional ways to encourage these agencies to share information and work together as a cohesive unit. In other cases, states might consider reforming processes in order to institutionalize a comprehensive and interconnected approach to authorization.

Third, authorizing agencies should ensure that authorization processes are transparent and user-friendly. Through our inventory, we discovered that the clarity and accessibility of agency websites and application processes varied greatly. We recommend that all agencies make their application available to the public. States should also consider designing robust and well-organized websites with students, institutions, consumer protection advocates, researchers, and others in mind.

This blog post is based upon a report that is one in a series coordinated by the State Higher Education Executive Officers Association (SHEEO) and supported by Arnold Ventures. The series is designed to generate innovative empirical research regarding state authorization processes and policies that can serve as a foundation for future research and policy in this understudied area.

You can find our full report here:


Bruckner, M. A. (2020). The forgotten stewards of higher education quality. UC Irvine Law Review, 11(1), 1–41.

Contreras, A. L. (2020b). What is a degree? In A. L. Contreras (Ed.), State authorization of colleges and universities (2nd ed., pp. 5–40). Oregon Review Books.

McCann, C., & Laitinen, A. (2019, November 19). The Bermuda triad: Where accountability goes to die. New America.

Tandberg, D. A., Bruecker, E. M., & Weeden, D. (2019). Improving state authorization: The state role in ensuring quality and consumer protection in higher education. State Higher Education Executive Officers Association.




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