NBBE Consulting Submits Formal Comment to U.S. Department of Education on Proposed Overhaul of Accreditation Rules

Posted September 21, 2026

Firm's comment on the AIMS proposed rule reflects patterns observed across institutional and agency engagements nationwide, and urges the Department to sharpen several provisions before finalizing the rule

WALDORF, MD., September 21, 2026 — NBBE Consulting, an accreditation, compliance, and quality assurance consultancy serving postsecondary institutions and accrediting agencies nationwide and internationally, today announced that it has submitted a formal public comment to the U.S. Department of Education on the proposed rule “Accreditation, Innovation, and Modernization” (AIMS), the most significant revision to federal accrediting-agency recognition rules in nearly a decade. Today, September 21, marks the close of the public comment period for the rule.

Published August 20, 2026 by the Department's Office of Postsecondary Education (Docket ID ED–2025–OPE–1042; RIN 1840–AD82), the AIMS proposed rule implements Executive Order 14279 and would rewrite nearly all of 34 CFR Part 602 - governing how the Department recognizes accrediting agencies, how institutions may switch accreditors, how transfer-of-credit decisions must be handled, and how institutional closures and teach-outs are managed. The Department has designated the rule “economically significant,” estimating $490.3 million to $494.2 million in annualized compliance costs.

NBBE Consulting's comment draws on patterns the firm observes across its client engagements with institutional and programmatic accreditors, including NECHE, DEAC, MSCHE, ABHES, and ACEN. The firm's submission supports the rule's core goals - reducing unnecessary barriers to accreditor competition, tying accreditation more closely to real student outcomes, and strengthening protections for students during credit transfer and institutional closure - while recommending nine specific changes to sharpen the rule's administrability, including clearer standards for viewpoint-neutrality compliance, a defined sufficiency standard for teach-out financial protection, and an explicit exception to preserving institutions' authority to deny transfer credit for licensure- and clinical-sequence coursework.

“This rule touches nearly every relationship our institutional clients have with their accreditor - how they are evaluated, how their students transfer credit, what happens if they ever have to close their doors. Similarly, having also worked with institutional and programmatic accrediting agencies, seeking initial and continued recognition, we are uniquely positioned to also provide an agency perspective and how the proposed rule supports accountability while also preserving quality.” said Perliter Walters-Gilliam, Founder and Principal Consultant of NBBE Consulting. “We read this rule the way we read every accreditation standard we help a client respond to - line by line, asking what it actually requires and who ends up bearing the cost. We think the Department got the big questions right. We also think a handful of provisions need sharper language before institutions and agencies can comply with confidence — and that's what our comment addresses.”

The firm's full comment letter is available here and via the Federal eRulemaking Portal at regulations.gov under Docket ID ED–2025–OPE–1042.

About NBBE Consulting

NBBE Consulting is a Maryland-based professional consulting firm with deep expertise in international accreditation, quality assurance, institutional effectiveness, and strategic advisory services. The firm serves higher education institutions, private K-12 institutions, and career and technical institutions to achieve and sustain accreditation, improve operational performance, and build strategic capacity. The Firm also supports accrediting bodies, government agencies, and certification organizations with external accreditation and recognition as well as capacity building and public trust.

www.nbbeconsulting.com | [email protected] | 301.818.1323

Media Contact

Perliter Walters-Gilliam

President and Principal Consultant, NBBE Consulting

[email protected] | (703) 919 - 0357