Summary: Executive Order on Reforming Accreditation to Strengthen Higher Education

This analysis was prepared by Venable, LLP on behalf of AACOM.

April 24, 2025

On April 23, 2025, President Trump signed an executive order (EO) titled Reforming Accreditation to Strengthen Higher Education that directs the U.S. Secretary of Education to implement numerous changes to the U.S. higher education accreditation system and investigate accreditors to determine whether they compel institutions of higher education (institutions) that they accredit to adopt illegal, discriminatory practices. Under title IV of the Higher Education Act of 1965, to participate in the federal student aid and loan programs, institutions must be accredited by an agency that is recognized by the U.S. Department of Education. Thus, federally recognized accreditors are charged with quality assurance and therefore act as so-called “title IV gatekeepers.”

The EO asserts that accreditors have failed to ensure this statutory duty to ensure quality education and have prioritized ideological requirements—particularly around “diversity, equity, and inclusion” (DEI)—instead of academic (e.g., improved graduation rates) and financial outcomes (e.g., graduates’ performance in the labor market). The EO states its purpose is to refocus accreditation standards on whether institutions offer quality academic programs, reasonable tuition, and compliance with the law. 

Of particular relevance to AACOM, the EO specifically identifies the Liaison Committee on Medical Education (Committee), which is the only federally recognized accreditor that accredits Doctor of Medicine degree programs, and the Accreditation Council for Graduate Medical Education (Accreditation Council), which is the sole accreditor for both allopathic and osteopathic medical residency and fellowship programs, as two examples of federally recognized accreditors that mandate “unlawful discrimination.” The EO instructs the Education Secretary to investigate these two accreditors and determine whether continued federal recognition is appropriate. The revocation of the Committee’s or the Accreditation Council’s recognition may have significant effects on the ability of students to use federal student aid to pay for the programs currently accredited by these agencies. 

The text of the EO is available here. A section-by-section summary follows.

Sec. 1: Purposes

The EO asserts that:

• Accreditors have approved “low-quality” institutions despite poor six-year undergraduate graduation rates and negative return on investment for many undergraduate and graduate program degrees.
• DEI-based standards are unlawful discriminatory practices.
• Some accrediting bodies, such as the Committee and the Accreditation Council, impose DEI mandates that allegedly violate a Supreme Court decision (citing Students for Fair Admissions, Inc. v. President and Fellows of Harvard College, 600 U.S. 181 (2023)) and are grounded in unlawful discrimination.

Sec. 2: Holding Accreditors Accountable for Unlawful Actions

• The EO directs the Attorney General and the Secretary of Education, in consultation with the Secretary of Health and Human Services, to “investigate and take appropriate action to terminate unlawful discrimination by American medical schools or graduate medical education entities that is advanced by the Liaison Committee on Medical Education and the Accreditation Council for Graduate Medical Education,” including “unlawful DEI requirements under the guise of accreditation standards.”
• The Secretary of Education is also directed to assess whether to suspend or terminate the federal recognition of the Committee or the Accreditation Council or “take other appropriate action to ensure lawful conduct by medical schools, graduate medical education programs, and other entities that receive federal funding for medical education.”

Sec. 3: New Principles of Student-Oriented Accreditation

The Secretary of Education is directed to take appropriate steps to ensure that:

• Accreditation requires institutions to provide high-quality, high-value academic programs, free from “unlawful discrimination” or other violations of federal law.
• Barriers limiting institutions from adopting practices that improve credential and degree completion and support new education models are reduced.
• Accreditation requires institutions to promote academic freedom and diverse ideological viewpoints among faculty.
• Accreditors do not use their federal role to pressure institutions to violate state laws, unless those laws conflict with the Constitution or federal law.
• Accreditors avoid credential inflation and unnecessary cost burdens on students.

The Secretary of Education is also directed to:

• Resume recognizing new accreditors to foster competition.
• Require accreditors to use program-level student outcome data to drive improvements (without reference to race, ethnicity, or sex).
• Provide accreditors with findings from civil rights investigations.
• Establish an experimental site that will test alternative quality assurance pathways for institutions.
• Increase the consistency, efficiency, and effectiveness of accreditor reviews.
• Streamline the process for institutions to more easily switch accreditors misaligned with their values and mission.
• Update the Accreditation Handbook to ensure that accreditor processes are transparent, efficient, and not unduly burdensome.