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In November 2018, representatives of four organizations–Clare McCann of ¹ú²úÊÓƵ, Antoinette Flores of the Center for American Progress, Emily Bouck West of Higher Learning Advocates, and Michael Itzkowitz of Third Way, submitted . The comments to Northwest Commission on Colleges and Universities (NWCCU), a regional accreditor, offer suggestions for improving the agency's proposed accreditation standards on student achievement, risk-based accreditation, and transparency.