Oregon school definitions

In response to a question raised in the SCUPS discussion, I thought I would start a thread on the definitions Oregon currently uses. We intend to revise these at the September meeting of the Commission because they do not work well. We would appreciate some input from people with an interest in the issues.

All unaccredited degrees are illegal for use in Oregon unless we evaluate the school. In an attempt to provide someuseful information to the public, we earlier this year set up classifications called "Standard School," "Substandard School" and "Diploma Mill." These are shown on our web site www.osac.state.or.us/oda/ in the definitions under regulation 583-050.

Does it make sense to even have such classifications? Do they serve a public purpose?

We formerly had one list with notes but no classifications. We may move back in that direction and just call them all illegals.

How does a degree supplier currently get classified? Sometimes as a result of formal review (e.g. California Coast), sometimes as a result of informal investigation by ODA (the Harrington clutch), sometimes as part of an investigation of a particular degree user (Berne) and sometimes based on reliable third-party investigations or testimony (e.g. Kennedy-Western).

 

Hi Alan:

Thanks for your post. I believe that the other short thread you were on was removed because of a fraudulent poster. Personally, I think the classifications are a good idea. The distinctions seem valid (no, I have not studied this scientifically) in and of themselves. Also, they add nuance to the list, which might well be a good public relations thing. Keep up the good work. When I was a DL tyro I was "warned off" one particular "school" by its eminently correct inclusion on the ODA list, so I've benefited directly from the existence of the list.
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Also, please check your private messages. I sent you a PM in regard to a particular school. I hope you can give me some information (also via PM, not on open forum, please.)

Janko

 

I have noticed that some other states get around the whole classification issue by just stating what is acceptable for use, and that anything that is not acceptable is not aceptable.

This would require a list of sources where acceptable schools can be found and a shorter list of schools that you have deemed acceptable that are not on another list.

 

What Mike suggests is exactly what we used to do.

We made the change because of public requests for information about which unaccredited suppliers are "real schools" vs. "nonschools." This turned out to be impractical for many institutions that are hard to classify.

State agencies have an obligation to serve the public interest, but sometimes that is not so easy to do.

 

If distinctions are to be made, then descriptions of the classes and criteria for placement are crucial. It would also help if there was a standardized process, instead of a disorganized, ad hoc one.

John Bear has made such distinctions in his books, but with a great deal of "wiggle" room. Businesses and individual selling degrees are included in the Degree Mills section, as are closed operations and those named as degree mills by authoritative sources (such as the U.S. DoE). But as Bear notes, it is easy to construe that many of the entries in the unaccredited schools sections are also degree mills. However, it is difficult to say so without getting sued by these operators. While truth is a defense in such matters, it does not shield one from the expense, trouble, and emotional toll of the process of defending one's self. Perhaps the state of Oregon sees itself less likely to be subjected to that trama.

The other alternative is to have no list at all. Publish your requirements and be done with it. When I saw the original list, it lumped degree mills in with legitimate, unaccredited schools. It was a simple matter to add a school, even a brick-and-mortar school that had no business being on the list. The list was out of date the moment it was updated, was confusing, and didn't add much information (except confusing information). A list of exceptions--unaccredited schools specifically approved by the ODA--would have been much better, and easier to manage.

List or no list? List, if it is done right. If not, no list and just stick to the statement that, unless approved, using degrees in Oregon issued by unaccredited schools is deemed illegal. That oughta cover it.

 

Alan,

The problem with your list (and there have been many discussions here of late) is that it is incomplete in many regards and yet tries to be too prescriptive for schools listed, making it dysfunctional. For instance, you list only a few schools that are State Approved in California indicating those are illegal for some purpose in Oregon and yet there are 254 approved schools in CA alone www.cpec.ca.gov. This situation is replicated when you consider the other 48 States. Using the terms Standard, Substandard, and Diploma Mill seem to be prejudicial. It appears your list has been arbitrarily constructed e.g. changes/additions have been made on the basis of a phonecall (reliable third parties?) rather than the result of any real analysis/evaluation. The list and the ODA website also indicates a government charter to protect Oregonians from other than accredited degree holders and yet your office has very few, if any, prosecutions (successful or otherwise) all of which undermines the purpose and effectiveness of the ODA.

Here are some recommendations:

1. Re-evaluate the purpose and structure of this list.
2. Expand your list to make it more complete or discontinue it. Showing a tiny subset of schools misleads the reader to the conclusion that these deserve special attention due to some egregious behavior.
3. Publish the process by which schools are evaluated before being listed and be consistent in applying those rules.
4. Keep it simple, to avoid misunderstandings.
5. Publish the due process that occurred to distinguish a school as a Diploma Mill
6. Remove the Standard, Substandard, and Diploma Mill designations and perhaps use Acceptable/Not Acceptable.
7. Don't list known or prosecuted diploma mills next to legitimate state approved universities (continuing to do this demonstrates prejudice and lack of logic)
8. Recognize that all legitimate universities are approved or licensed before they are accredited. The ODA's list and the manner unaccredited schools are considered is pejorative which seems to be an underlying theme in the presentation of your list.
9. Be very clear what you mean when you describe and list a diploma mill. Your definition says that a diploma mill is a school operating without government supervision, which to me means it would be illegal (no license, no inspection/approval).
10. Prosecute illegal diploma mills operating in Oregon.

 

Given that the Oregon ODA has a staff of just 2.5 people (per recent article posted elsewhere) and that they have other important responsibilities, I think that the list has to be kept simple.

I would classify universities without accreditation (or GAAP equivalent) into the following categories:

U.S. State-licensed schools
Unrecognized schools

It should be fairly easy to maintain this classification.

The list will necessarily be incomplete, and so there should be a disclaimer stating this -- and suggesting that people submit the names of individual schools whose status they question. These schools could then be added to the list in the appropriate categories at the ODA's discretion.

 

I think that they make you vulnerable.

There are people out there that would like nothing better than to discredit you and your office. The more creative you get, the more opportunity you give them.

If your critics can argue convincingly that you misclassified even a single school, then you will never hear the end of it.

You could accomplish pretty much the same things by posting a single list of schools whose degrees are currently illegal in Oregon, and then adding annotations if you have additional useful information to add in particular cases.

 

Don't let people try to turn your office into some weird kind of alternative quasi-accreditor of non-accredited schools.

It's an obvious misuse of your office if people outside Oregon want you to tell them which non-accredited schools are "real". Don't get sucked into that stuff.

 

As Bill mentioned and to para pharse Lincoln:

"You may please all the people some of the time; you can even please some of the people all the time; but you can’t please all of the people all the time."

And as also mentioned you have a small staff. Trying to list and identify the bad apples (as more rot occurs everyday) is difficult. Creating a list of all "mills" is imposible, as a new one springs up almost every day it seems.

By going back to the old way, it then becomes the other sides job to prove that they are acceptable and not your job to prove they are not.

 

All of these ideas and points of view are extremely helpful We cannot make any changes until September but I lean strongly toward a simplification.

One of the difficult issues is how to handle "state-approved" as a category. The main problems are these.

1. Oregon statute treats all unaccredited schools the same. Degrees from state-approved schools are illegal for use in exactly the same sense as degrees from Harrington. That is, they all have the same requirement that our office evaluate them before use. So why separate them?

2. State approval in Hawaii, Wyoming, Pennsylvania and South Carolina are four wildly different kinds of animal. There is hardly a point in common. We have no idea what meaning the phrase "state-approved" would have. The only meaning I can think of is "legal within the state issuing the approval," which does not really provide much new information.


On a slightly related matter, Oregon has a long-standing policy of ceasing enforcement once a school reaches formal candidate status with an accreditor. Technically these degrees are not valid, but they go to the bottom of the heap for any action, a form of triage, if you will.

I just heard that the big feature on diploma mills in the Chronicle of Higher Ed came out today.

 

I think the list is very valuable as examples of intitutions whose degrees are illegal for use within Oregon. Make sure that it is clear that it is a list of examples and is not intended to be a complete list. (Which would be impossible to make a complete list anyway.)

As for the complaints that it lumps together apparent attempts at real schools and outright roaring degree mills, that's the way it seems to work in the general population anyway. Most people do not differentiate between different sub-classes of unaccredited. You already have enough distinction between the different sub-classes of unaccredited with what is required by law, legal to use in Oregon and illegal to use in Oregon. IMHO

 

Too much zeal might not be a good thing.

Dear Mr. Contreras,

Since I already know that at least some of what I'm about to write here will seem critical of both you and Oregon's law regarding the use of degrees within its borders, I want to begin by saying that I applaud -- to the point of standing ovation, even - the good intentions of your office... and of you. The world is right to point to your efforts and to hail them as groundbreaking and as a correct first step toward the elimination of degree mills (or at least exposing them and forewarning those who might otherwise have been hurt by them). Congress is right to ask you to testify before its committees in an effort to understand the problem and to learn about what one state is doing about it. There is absolutely no question that what Oregon is trying to achieve, generally, is the right thing. But I am very concerned about the methodology. As is often the case when a huge national problem comes to the forefront of the public's attention, a rush to do something -- even if it's the inherently wrong thing -- is the way Americans tend to react.

Whenever we set out to do something like what Oregon is doing, we must never lose sight of what is required of us under the law. I have been troubled from the moment I first learned about Oregon's program and it's willingness to criminalize the use of certain types of degrees on resumes and in other places. Since this thread began, I've thought long and hard about this issue. Don't get me wrong, it's plain to see, Mr. Contreras, that you want to do the right thing. I am so impressed with your reaching out in places like this to get ideas. And I, for one, am looking forward to the online chat in the Chronicle on the 24th. Bravo! Keep up the good work.

While I agree that accreditation (preferably regional accreditation) by a CHEA-approved agency is and should be the gold standard, Oregon's lumping into a single illegal category all other institutions just goes too far -- especially since possible criminal sanctions attach. Yes, I realize Oregon has a procedure for investigating unaccredited schools and, if all goes well, subsequently making their degrees legal for use in your state, but with your other responsibilities and the tiny size of your staff, I fear that abuse and unfairness are inescapable.

All this talk about what would and what would not be the best way to get done what you're trying to do is interesting, but in my opinion it misses a much bigger mark. The problem, in my estimation, began when your state criminalized the use of degrees which your office does not first approve. Whenever the government punishes with criminal sanctions -- the most hard-hitting and potentially harmfully consequential thing any government can do to its citizens -- it must bother to invest far more than it appears Oregon has invested to date in a construct that will adequately permit the citizenry to be able to tell in clear and unambiguous way when it is breaking the law and when it is not. Everyone here is cavalierly tossing about ideas for how things should be done, and there appears to be no appreciation for the fact that the criminalization factor demands that the entire process be taken more seriously, and that it be more adequately funded and staffed, than is currently the case.

The very problems cited by Rich Douglas, oxpecker, Kirkland and others earlier in this thread more-than-adequately illustrate the fundamental ambiguity of the standard. But when a person's very liberty is at stake (as is the case when a state introduces criminality into the mix), there can be no ambiguity. The constitutional requirement of "notice" is essential in any law which makes any behavior criminal. Sometimes I wish I were licensed to practice law in Oregon so that I could represent the first person that your state goes after under this law. Because the standard to which the citizen is being asked to conform in order to avoid being criminally charged is such a moving target -- for that reason alone (not to mention another that I'm about to introduce in a moment) -- I believe I could not only get my client acquitted, but I believe I could make a sufficient constitutional argument such that the Superior Court judge hearing the case would have no choice but to declare Oregon's law unconstitutional.

But there is another problem -- also a constitutional one. Oregon's willingness to summarily dismiss (whether or not pending investigation) all out-of-state degrees that are not accredited by a CHEA-approved agency -- especially, those that are issued by institutions licensed in their respective states to grant degrees -- cannot be seen as anything short of a gross violation of the "Full Faith and Credit" provision of Article IV, Section 1 of the United States Consitution. In short, no state is permitted, at least not without some serious due cause, to summarily and cavalierly disregard -- and, worse, to make illegal -- that which another state explicitly declares legal through its lawful process of licensure and/or official approval. It isn't that Oregon can't ultimately declare illegal the use of some degree issued by an unaccredited but otherwise state licensed out-of-state institution, but the spirit of the Full Faith and Credit clause demands that before doing so, Oregon must perform adequate due diligence to determine that the licensing or approval process of the state in question is so substandard that its imprimatur is essentially and objectively worthless.

Oregon, therefore, is doing it backwards. Instead of declaring, arbitrarily and categorically that all unaccredited but otherwise state licensed and/or approved degree-granting institutions in other states are illegal, Oregon should do the following:

1) First, obtain a list of all state licensed and/or approved degree-granting institutions from every state. Those that are not only licensed/approved in their respective states but which are also accredited by a CHEA-approved agency should automatically go straight onto Oregon's "approved for use in Oregon" list.

2) All other state licensed/approved institutions should go onto a second list called "unaccredited, but otherwise licensed and/or approved in its state and, therefore, initially presumed lawful for use in Oregon pending a bona fide show of good cause why it should not be so."

3) A third list of "unaccredited schools that are expressly exempt from licensure and/or approval by their respective state laws" should also be created, and schools thereon should probably also be initially presumed legal for use in Oregon pending a bona fide show of good cause why it should not be so.

4) Virtually all other institutions could go onto a fourth list of schools neither accredited or licensed/approved (or exempt from licensure/approval) by their respective states and, therefore, initially presumed illegal for use in Oregon pending a bona fide show of good cause why it should not be so. This would include schools in states which have no registration, licensure or approval procedures at all.

5) A fifth list of "institutions whose degrees have been shown through due diligence to be illegal for use in Oregon" should also be created -- a list that will grow over time, of course as insitutions fall off the first three lists after due diligence.

The presumption of legality and acceptability of the institutions on the first three lists would certainly satisfy Oregon's responsibilities under the Full Faith and Credit clause. And there is virtually no one who could make an argument -- legal or otherwise -- that Oregon was being capricious in its categorization of those on the fourth list.

I realize that many diploma mills are licensed/approved in their respective states. Fine, then that's where the "show of good cause" comes in. Approve states, not degres. You're micro-managing. Oregon already knows which states have licensing/approval standards that aren't worth the paper they're written on. Start by picking two or three states that have respectable licensure/approval standards. Agreed, they may not be up to par with CHEA-approved accreditation standards, but it should not be difficult to determine the two or three states that have licensure/approval standards that everyone would agree are worthy of giving full faith and credit to for use in Oregon. From that, figure out some kind of minimum licensure/approval standard (short of CHEA-approved accreditation) that Oregon would accept from other states and write it down. Be sure it contains rational, reasonable standards that are legally defensible. Then compare every other state's licensing/approval standards against it. Those states that meet or exceed the standard should be given full faith and credit in Oregon for degrees issued by its licensed/approved institutions. All others should not. Period.

Oregon should not be wasting its time rejecting most and accepting, only as it finds time to investigate, some. I realize my suggestions, above, would be a lot of work -- might even take a year or more, and a staff of a dozen people, to finally get it right. But in the end it will be less work and less costly than what Oregon's trying to do now. And, more importantly, it will withstand constitutional scrutiny.

If Oregon continues down its current path, I fear it's just begging for someone whom it prosecutes under its law to hire a bulldog attorney with a knack for arguing constitutional issues convincingly to not merely get him/her acquitted, but to also get the courts to overturn the law prima facie and to, thereby, force the state to start all over again. Mark my word.

 

In response to Gregg DesElms, there are many good issues well presented here. This is the kind of very useful discussion that helps those of us charged with enforcing the law, and I thank you.

Many of the legal issues have already been discussed with our agency counsel and they are satisfied with our position. I'll mention a couple of details.

Degree use is generally considered to fall under a state's free-standing police power and thus outside the full faith and credit clause. The same is true of, say, bar membership, which also does not cross state lines. We know of no court case anywhere mandating recognition of unaccredited degrees across state lines. Anyone who has such a case, let us know.

In the only case involving ODA since my arrival five years ago (Benton v. Svejcar et al.), the federal judge hearing the case stated during trial that Oregon could rely on accreditation as the standard for legal degree use, despite spirited arguments to the contrary from opposing counsel.

There has been serious discussion around the country of establishing what amounts to a uniform code for state-approved schools, to which "member" states could subscribe and then recognize each other's degrees. This is a practical idea and it may yet happen. It is common practice in some professions, notably nursing. I support this idea and will be discussing it with colleagues in other states. My guess is that religious training schools would be left out but that otherwise at least a dozen states would sign on to such a compact and others would move toward such a standard.

We agree that if Oregon automatically disallowed all use of unaccredited U.S. degrees with no pressure release valve, we'd have some constitutional scrambling to do (foreign degrees are another species). This is the trap into which Florida fell. We are not in that trap because anyone who hears from us about their degree has an opportunity to show that their school meets the basic standards (ORS 348.609(d). The Commission's rules on our web site expressly require a window of opportunity for any degree user before enforcement occurs. Indeed, that is the major process through which we move unaccredited school onto the acceptable list.

Oregon has never instituted criminal charges against a degree user under the current law because civil and administrative approaches are also available. By the way, in North Dakota, using an unaccredited degree is a felony. In Oregon it is a low-level misdemeanor.

Thanks again for raising these issues. You obviously have a good sense of what might work.

 

And thank you, Mr. Contreras, for such a thoughful (and quick) response. I appreciate learning more about how Oregon views these issues. And I am relieved to learn that you are so well versed in them... as it should be.

You wrote:

While I realize that free-standing police power generally trumps full faith and credit, I have always believed that to categorize degree use as such was flawed thinking. Just my opinion, mind you. Bar membership clearly qualifies because creation of the standard and its narrowness, one's ability to conform to said standard with precision using resources entirely within the state's borders, and the state's ability to enforce said standard in a completely fair and equitable way -- again, completely within its borders -- is a sophisticated and self-sufficient system upon which no neighboring state or its standards could reasonably improve... thereby creating a veritable model for what a state's "free standing police powers" means. Degree granting, on the other hand, enjoys no such necessary and appropriate narrowness, rigidity, self-sufficiency and sophistication of standards. Unless Oregon can provide from within its borders every conceivable kind of degree that any resident thereof could possibly want in order to make a good living in the field of his or her choice, thereby negating the need to go outside its borders to obtain same, then applying the standard of free-standing police power as a means of exemption from full faith and credit starts to get a little shaky. Again, just my opinion.

I haven't read that case, but now I will. Thank you.

On thing I think it's important to consider is that there is a fundamental difference between Oregon's interests in keeping out of its borders (and only its borders) those who seek to qualify themselves with unaccredited (or, at the very least, clearly sub-standard) degrees, and the reliance upon or patterning after Oregon's standards by other states. I confess that I may be making that mistake of logic and reason as I think about this whole thing. Still, though there is certainly no law which requires it, Oregon, in my opinion, should be ever-mindful of its role as a trail blazer and the tendancy of other states with fewer resources to copy what Oregon has done in the hopes that if the court found it to be acceptable there, then it's statistically more likely that the courts here will find similarly. Though Oregon didn't ask to be considered the defacto standard-bearer, I believe it should nevertheless be sensitive to its role as precisely that -- a role which, of course, puts an unintended (and clearly unmandated) heavier burden on the state to do what's right for a larger body of citizenry, including those beyond its borders.

That would be wonderful! I'd love to see that sort of thing. It would go a long way toward establishing the creditbility of institutions and their degrees, as well as the states who license/approve them.

I would consel not to leave out the religious institutions but, rather, to make their inclusion voluntary. It seems there are countless seminaries, for example, that are exempt from licensure/approval in their states (but which, nevertheless, must be registered as "exempt") and which are offering rigorous coursework. Most of them are small, some of them highly sectarian, and nearly all of them unable to afford accreditation. A seminary which is exempt but which nevertheless conforms with minimum standards set by a consortium of states would permit said seminary to demonstrate have some level of standards compliance and, therefore, credibility -- all without having to mortgage the farm. That, it seems to me, would be useful.

Only if that window of opportunity permits the defendant to completely escape prosecution even if unsuccessful in his/her efforts to persuade you as long as said efforts were clearly in good faith and it is abundantly clear that the defendant was misguided (or at least had a wrong but nevertheless good faith belief in the credibility of the institution from which he/she obtained his/her degree) would I be entirely comfortable with going at it in that way. As should be obvious by now, it's the criminality of it that so troubles me. While I appreciate that that may be the only way to get the public's attention, it fundamentally raises the bar to a new level that demands at every step the elimination of ambiguity of the standards to which you expect citizens to conform... which, of course, translates as adequate notice.

Oregon's taking the seemingly easy road of simply making illegal all degrees not accredited by CHEA-approved angencies is a simple statement that by anyone's standards is unambiguous and, therefore, meets the notice requirements before criminality may then attach. But, in my opinion, Oregon muddies the waters by subsequently trying to account for the exeptions -- the micro-management to which I referred in my previous posting. And if Rich Douglas and others are correct in what they wrote here about how confusing it then becomes, then notice is fundamentally lost. At that point, criminal sanction becomes very dangerous from a simple consitutional rights standpoint... and, in my opinion, potentially endangers your entire program at the hands of a judge with a soft spot in his/her heart for strict constitutionality. I realize it's been argued and that the court said you were okay. But another lawyer, another judge, another day... who knows what could happen.

That's why I proposed going at it in precisely the opposite way. Assume anything a state licenses and/or approves is -- at least initially -- legal in Oregon. Then create a standard -- either one of your own, or one of a consortium of states as you mentioned. Compare the standard against anything and everything that isn't accredited. Move to my fifth list, above, anything that doesn't meet the standard. And then just be done with it. Otherwise, you end-up trying to figure out who's a diploma mill and who isn't, along with all its concomitant and seemingly endless definition creation and review. Under my proposal, diploma mills will automatically fall into the fifth list. They don't even need to be declared diploma mills in order to get there. If someone in your office wants to take the time, as an advisory warning sort of thing, to separate out from the fifth list or to tag thereon those which are bona fide diploma mills by any reasonable standard, that's fine... but unnecessary in order to protect the citizenry under my proposal.

That's refreshing to know. Thank you for telling me that. And don't interpret my saying so as suggesting my belief that no crimininality should ever attach under any circumstances. Being the pinko-punko (as my father used to call those such as me) lefty liberal that I am, I'm not against throwing people in jail for breaking the law, but I do want it to be just; and I want the rules by which people must abide to be painfully clear and obvious. Sadly, under its current conditions, I fear Oregon's approach doesn't quite meet that standard... yet. But then again, that's partly why you started this thread, I presume: So that it can be improved to the point that it does... which I applaud.

Holy cow! I'm obviously worrying about the wrong state, aren't I? [grin] Maybe I'll go harass them for a while and leave you and your obviously well-intentioned efforts here alone!

Naaaaah! (Just kidding.)

Thanks, again, for the excellent discourse. You're clearly the right guy for your job. Don't let anyone tell you otherwise. I'm terribly interested in how this all comes out, and I humbly request that you take my view of things (and my proposal) into consideration as you refine and perfect. Thanks for listening!

 

Under Oregon law, religious institutions have a choice as to whether or not to be exempt from state oversight. If they choose exemption, their degrees are valid for any religious use. If they choose to be state-approved, their degrees are also legal for use for secular purposes.

This approach was recommended by the seminaries themselves when the law was written some years ago and it has worked very well. We have six unaccredited state-approved religious schools and about 15 unaccredited exempt schools. A school can change status at any time by its own choice, provided it goes through the appropriate process.

 

I've heard that about the North Dakota law a number of times now. I'm definitely not a lawyer but my own personal reading of the North Dakota law lead me to believe that it was generally a misdemeanor to use an unaccredited degree. The felony was an exception and applied if the person printed up their own diploma. (But hey I'd be fine with being wrong on that, I'd like to know though so I could laugh at myself.)

This threw a wrinkle into my favorite advice to people determined to buy a degree mill diploma. That was instead of them putting their hard earned money into the pocket of a con-man, they should instead print up their own diploma. Now it needs to be qualified with "unless you live in North Dakota where it's a felony".

 

A little note about Religious institutions, accreditation, and exemptions: Some religious schools, while having rigorous programs, choose to NOT pursue accreditation due to concerns about conflicts between doctrinal and secular requirements. One oft-cited example is the Baptist college that applied for accreditation, and was told they would have to offer classes in DANCING. They declined to further pursue accreditation.

 

Well, since John Ashcroft is opposed to dancing, the feds are unlikely to impose such a requirement right now. That family has an interesting approach to what is proper and what is not: dancing is forbidden, but Lady Ashcroft once called the Missouri state librarian and asked her to personally come in and open the state library on a weekend so her child could study. I happened to be working for the Missouri agency that oversees the library at the time.

Here is a question for the group, which resulted from an inquiry I received today.

One of the problems we have run into with a couple of degree suppliers is that although the *name* of the supplier remains the same over time, its owners and also its policies regarding the award of credit change radically. This places us as a government agency in the awkward position of being obligated to treat the named institution as having the *lowest* standards that it ever had in order to screen out bogus degrees, or of trying to list the standards that it had at each point in its existence and figure out how to classify that set of standards, which is hopeless for hundreds of entities.

This is obviously a clunky way to screen credentials, yet we have found no better way (so far). It is possible that we could go to a system in which an individual degree-holder could submit actual academic work for evaluation, but we could not evaluate it in-house since the breadth of fields would be too wide, so we'd have to hire it out, which means we'd have to charge the applicant a fee, probably in the multiple hundreds of dollars.

I realize that some of you will think that this is an example of why the state should just stop screening, but that's not an option - I have to enforce the law and am looking for better ways to do that.