In November 2018, representatives of four organizations–Clare McCann of New America, Antoinette Flores of the Center for American Progress, Emily Bouck West of Higher Learning Advocates, and Michael Itzkowitz of Third Way, submitted joint comments. 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.