“Accreditation” is not a word often bandied about at the breakfast table, except by higher ed wonks like me. But it’s a crucially important word for everyone committed to what the late Supreme Court Justice Felix Frankfurter defined as the rights of a university to determine for itself on academic grounds: “who may teach, what may be taught, how it shall be taught, and who may be admitted to study.”
Accreditation is a non-governmental, peer-review process for evaluating educational institutions and programs to ensure quality, safety, and ethical practice. For decades the government has granted approval for federal financial aid distribution to accrediting bodies like the Middle States Commission on Higher Education (Middle States), which evaluates all Philadelphia-area schools, along with others in our larger geographic region. Since 1952, Middle States has protected local institutions from government interference.
Now the Trump administration wants to remove or deeply compromise the link between accreditation and approval of the right for Penn, Temple, Drexel, Arcadia — all Philadelphia institutions — to distribute financial aid. This would be a castration.
On life support but still venomously alive, the Trump Department of Education (DOE) is more dangerous than ever. After transferring responsibility for defaulted student loans to the Treasury Department, the DOE is now taking actions that are seemingly small and certainly less recognized by the general public. They are weaponizing accreditation and something called the System for Award Management (SAM). Their ultimate goal is to threaten colleges and universities with the loss of student financial aid — something that not even the wealthiest institutions could easily manage. Federal financial aid includes grants, work study funds, and loans that help about 13 million students finance their education.
Although the Trump administration’s efforts targeting financial aid are pretty clearly unconstitutional, even a one-year delay in a university’s ability to assign financial aid, as cases move through the courts, would be devastating.
Disrupting a system not in need of disruption
Until 2026, U.S. higher education has functioned under laws and traditions that have kept the federal government at arm’s length. For decades the federal government has delegated the dispersing of financial aid and other federal funds to accreditation agencies like Middle States, which describes its accreditation process as ensuring “institutional accountability, self appraisal, improvement, and innovation through peer review and the rigorous application of standards within the context of institutional mission.” Philadelphia-area colleges and universities must follow established practices to test themselves against agreed-upon standards of quality and financial stability.
Although the system is not perfect — What system is? — Middle States has served this region well for 74 years. On March 16, 20206 the DOE particularly targeted Middle States in a six-and-a-half-page letter from Under Secretary Nicholas Kent, to Heather F. Perfetti, President of Middle States. The message is highly technical, almost unreadable — Read it here — a clear indication that the DOE assumes accreditation is too wonky, too inside baseball, to seize public attention until it’s too late. Their big-time assault on something “little” definitely means a lot to every college student, including all those in the Philadelphia area.
The essential message is that the Trump DOE requires what Mike Gavin, President and CEO of the Alliance for Higher Education, calls “a perverse definition of civil rights,” questioning any reference to diversity, “neglecting the fact that work to support veteran students, or those from rural areas, is also essential to supporting diverse groups of students.”
The letter as a whole is designed to create innumerable technical, vague, hidden potholes to trip up the agency that now approves Philadelphia-area colleges and universities for financial aid. And that would be a disaster. If the Trump administration takes over approving institutions for financial aid distribution, they would gain incomparable methods of blackmail, forcing institutions to do whatever they ask, including providing lists of Jewish students and staff — one of the demands currently made to Penn.
In addition to my respect for Middle States, I have worked with accrediting agencies in other geographic regions: the Higher Learning Commission (HLC) and the Northwest Commission on Colleges and Universities (NWCCU). Sometimes I was annoyed by the extensive paperwork and by an occasional rogue assessor who didn’t fully recognize the wonderfulness of my university programs. But deep down, I knew that our U.S. accreditation system protects academic freedom.
Until 2026, U.S. higher education has functioned under laws and traditions that have kept the federal government at arm’s length.
Weaponizing the system for award management
When I was a university president, each year I would sign a routine participation agreement, the System of Award Management (SAM), ensuring that my institution would be eligible for federal dollars, including federal financial aid under Title IV. I never imagined that this agreement would be weaponized. The Trump administration intends to use SAM to accomplish the goals of the DOE’s now-unlawful Dear Colleague letter (February 2025), which tried to eliminate all policies and programs addressing racial equity. And again, holding back student financial aid is the stated weapon of choice.
We should never forget that these enemies of higher education just keep plugging away. Smaller print is harder for the public to detect, and there’s plenty of small print in the SAM documents. To achieve the goals of “Dear Colleague,” the Trump administration, through The General Services Administration (GSE), has filed a proposed information-collection change (sounds small and harmless). But it’s just another route to adopt requirements to make it difficult for colleges and universities to award federal financial aid and to receive other federal dollars.
How to fight these cunning ploys
The wily enemies of higher education depend on the public’s eyes glazing over. Pathways for public comment on these outrages are hidden in obscure corners of the Federal Register and other small-print documents. Here are my attempts to shine a flashlight:
On SAM:
Send public comment to regulations.gov. They say by March 30, but if you’ve missed the date, send it anyway — and copy your Congressional representatives.
On accreditation:
Open this link for the wonky description of review panels, which really don’t mean much since DOE gets to select them:
Intent to Establish Negotiated Rulemaking Committee – Accreditation, Innovation, and Modernization (AIM) Committee** (Published 1/27/2026). The first session of this committee takes place April 13 to 17 and the second session, May 18 to 22. There’s a small print option for general public comment.
I give you the fast approaching dates for action on these matters to motivate quick response. I suggest not depending only on the links provided. Please write to both PA senators and every PA member of U.S. Congress to let them know of the dangers inherent in these administration proposals: threats to students, to higher education, to the First Amendment, to democracy. Little things — when they are the products of little minds but not little at all in their consequences — mean a lot.
Correction: The Citizen regrets misspelling the surname of Mike Gavin, President and CEO of the Alliance for Higher Education, in a previous version of this post.
Elaine Maimon, Ph.D., is the author of Leading Academic Change: Vision, Strategy, Transformation. Her long career in higher education has encompassed top executive positions at Governors State University (IL), University of Alaska Anchorage, and Arizona State University West Campus, as well as distinction as a scholar in rhetoric/composition. Her co-authored book, Writing in the Arts and Sciences, has been designated as a landmark text. She is a Distinguished Fellow of the Association for Writing Across the Curriculum.
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