by Michael R. Burgos
A Holy Insurgency
An insurgent movement seeks to invalidate and dethrone an established occupier. Insurgencies are almost always grassroots; a rebellion by everyday visionaries against systemic wrongdoing. From its inception, the biblical counseling movement has been a theological insurgency. It has sought to restore the church’s understanding of counseling as an intrinsically theological task for which the Scripture is sufficient. The biblical counseling movement has simultaneously sought to refute the psychotherapeutic establishment and integrationist counterinsurgency.
Key to the success of any insurgent movement is the establishment of new institutions that serve to herald and pursue the cause. In the case of the biblical counseling movement, many new institutions have been formed. These include accrediting bodies that have set ethical and theological standards for the practice of biblical counseling. Chief among these accrediting institutions is The Association of Certified Biblical Counselors (ACBC). By design, the certification ACBC offers is not recognized by any governmental agency. There is no sanctioning body that has granted validity to ACBC. Rather, ACBC looks to local churches and other Christian ministries to recognize its credibility. In so doing, ACBC has intentionally bucked the bureaucratic expectations of our culture. It has, upon the basis of the Lordship of King Jesus, set up shop on biblical terms. Whereas Licensed Professional Counselors and Licensed Mental Health Counselors depend upon the state to approve their labor, ACBC and the biblical counseling movement has sought the approval of heaven.
The logic of ACBC (or any other biblical counseling certifying body) as an institution is clear. ACBC has effectively repudiated secular counseling accreditation as even relevant.[1] Just as the Lord’s Supper and the public exposition of the Word of God resides within the jurisdiction of the local church, so does the cure of souls. There is neither a need nor a basis for governmental oversight or approval in these matters. Rather, the authority for ministry is bound up in the charter given by Christ to his people.[2]
Honor the Lord Your FAFSA…
Inasmuch as counseling is the prerogative of God’s people, so is theological education and ministerial training. In our day, most who desire to enter into vocational ministry first attend either a Bible college or seminary (or both). This formalized training comes at a price, as the average MDiv costs upwards of $45,000.[3] Fortunately, most conservative seminaries accept federal student loans such that seminarians may become enslaved[4] to the federal government just prior to entering the ministry.
Truly, the vast majority of conservative Protestant seminaries would not exist were it not for federal money. Those seminaries who reject Caesar’s cash derive much of their funding from tax-exempt local churches—as it should be.[5] In order for a Bible college or seminary to lay claim to federal money, that school must become accredited by either a regional or national accreditor that is recognized by either the U. S. Department of Education (DOE) or Council for Higher Education Accreditation (CHEA).[6] So too, there are other reasons institutions seek accreditation. For example, recognized accreditation is a form of statist approval, without which an institution is generally considered illegitimate at best. Jamin Hübner has observed, “Higher-education in the ‘developed’ world, whether religious or not, tends to be arranged to favor education that is validated by a government.”[7] Subsequently, “Accreditors generally function as an arm of the state.”[8]
Accreditation says almost nothing about academic rigor, let alone an institution’s fidelity to Scripture.[9] Consider Union Theological Seminary (UTS) in New York City. UTS has regional accreditation from the Middle States Commission on Higher Education, as well as national accreditation from The Association of Theological Schools. While UTS has the most prestigious accreditation possible, the education it affords is a morass of unbelief.
While most equate “accredited” with “legitimate,” achieving accreditation merely reveals a school’s conformity to the administrative and financial expectations of the accreditor, and by extension, the federal government. Recognized accreditation cannot answer the questions most students might ask of a Bible college or seminary: “Is the faculty faithful unto God?,” “Is the curricula effective and God-honoring?,” “Will I receive the best training here?,” or “Will an education at this school prepare me for the mission field?”
Any doubt about government control through recognized accreditors should have evaporated when the New England Association of Schools and Colleges (NEASC) implied that Gordon College’s policy on homosexual practice was out of step with its accreditation standards.[10] Another example can be seen in the treatment of the Master’s University by one of its accreditors, the Western Association of Schools and Colleges (WASC). WASC has sought to enforce ethical standards and practices upon Master’s,[11] just as with NEASC and Gordon College. One would expect a Christian institution to form its ethical practices upon the basis of a biblically informed Christian worldview rather than the transient mores of a regional accreditor.
Similar observations can be made in view of the treatment of two other Christian institutions by recognized accreditors, namely, Patrick Henry College and Westminster Theological Seminary (Philadelphia). Patrick Henry College sought accreditation with the American Academy for Liberal Education and was denied because of its commitment to creationism.[12] The Middle States Association of Colleges and Schools (MSACS) threatened to revoke Westminster’s accreditation in the 1990s because of a lack of women on its oversight board.[13] Westminster’s charter requires its board to be comprised of ordained elders. MSACS rescinded its threat a year later when Westminster agreed to “to give women a voice in its educational decision-making process.”[14]
R-E-S-P-E-C-T
In the same way that the biblical counseling movement usurped the status quo for its certification, rejecting state approval, Bible colleges and seminaries ought to do the same when it comes to the issue of accreditation. To jettison accreditation is, admittedly, to destroy an institution’s credibility in the sight of the secular world.[15] But, our loyalties were never with this world. Not only would renouncing recognized accreditation vastly reduce the costs of operation for most schools, but it would also emphasize evaluation upon a different criteria: The education itself. Shouldn’t our desire be for local churches to validate an institution?
There are signs within conservative Protestantism that the stigma associated with an education from an unaccredited seminary or Bible college is fading, especially among Reformed evangelicals. This is due in part to a number of highly regarded teachers and authors who have emerged with training from unaccredited institutions. For example, the late R. C. Sproul, while possessing a variety of degrees from accredited schools, also possessed a Ph.D. from Whitefield Theological Seminary.[16] The late George Scipione, one of the founding fathers of the biblical counseling movement, also possesses a Ph.D. from Whitefield.[17] James R. White possesses several degrees from conventionally accredited institutions, as well as several advanced degrees from Columbia Evangelical Seminary.[18] Elyse Fitzpatrick, known for her work within the biblical counseling movement, has an M.A. in biblical counseling from Trinity Theological Seminary.[19] Mark Shaw, an authority on addiction and biblical counseling, possesses a D.Min. from Birmingham Theological Seminary.[20] Aside from the institutions mentioned above, there are a variety of other credible and faithful unaccredited seminaries that have already been well established. These include Reformation Bible College, Covenant Baptist Theological Seminary, Greenville Presbyterian Theological Seminary, Forge Theological Seminary, Master’s International School of Divinity, Reformed Baptist Seminary, Reformation International Theological Seminary, and The North American Reformed Seminary.[21]
Both Greenville Presbyterian Theological Seminary and Birmingham Theological Seminary claim accreditation from an unrecognized accreditor, namely, the Association of Reformed Theological Seminaries (ARTS). While there are many unrecognized accreditors and accreditation mills which have engaged in some obviously spurious practices,[22] ARTS is not an accreditation mill. It is a genuine and thought through attempt at a distinctly Christian non-governmental accreditation.
Some have argued that all unrecognized accreditors are necessarily illegitimate, or even “worthless,” as in the case of Rick Walston.[23] Walston has argued that if accreditation isn’t recognized, it isn’t real. Such a view gives away the store—subjugating theological institutions to the approval of the state by implication. If through recognized accreditation, the government is the only entity that can genuinely vouch for the credibility and legitimacy of an institution, then the government serves as the gatekeeper of higher education.[24] Walston’s view is the statist view: unaccredited seminaries and Bible colleges must be satisfied with no external validation of their education and any attempt to form a Christian accreditor which de-legitimizes the role of the state is immoral. By contrast, if we recognize the division of labor between state and church, there exists no good reason to trust the government to validate theological education and any accreditation should come from the body of Christ. This is the logic of ACBC, the Evangelical Council for Financial Accountability, and it is the logic behind ARTS.
On the Legality of Operating an Unaccredited Seminary or Bible College
Currently, there are twenty-eight states which offer a religious exemption to higher education licensing, accreditation, and certification. In these states, unaccredited religious institutions operate with general autonomy, although some states require religious modifiers in the degrees issued by these institutions. Twenty-two states afford religious institutions no exemption,[25] effectively precluding any unaccredited Bible college or seminary from issuing degrees.[26] The rationale traditionally put forward by those states who possess no religious exemption is that the lack of such an exemption effectively outlaws degree mills. Such laws, however, are fine examples of gross unconstitutional overreach since states cannot legally preclude religious higher education or the establishment of religious schools of higher education designed for ministerial training. The domain of Christian education for ministry belongs to the church and not the state.
It has become virtually impossible for those states who do not afford a religious exemption to enforce or uphold their prohibitions on unaccredited religious colleges and seminaries since the landmark ruling in HEB Ministries Inc. v. Texas Higher Education Coordinating Board. In 1999, the state of Texas issued a $173,00 fine to Tyndale Theological Seminary for issuing degrees apart from recognized accreditation or state certification and for identifying itself as a “seminary” apart from state consent. Arguing the unconstitutional nature of the Texas Education Code via the Free Speech Clause, Free Exercise Clause, and the Establishment Clause, the Supreme Court of the State of Texas ruled in favor of Tyndale in 2007.[27] Douglas Laycock, Distinguished Professor at the University of Virginia School of Law, concluded in view of this case that “The state has no business licensing seminaries or any other religious institution. It is shocking that the state even attempted such regulation.”[28]
Insurgency: A Way Forward
Just as ACBC blazed a trail and established its own certification using biblical parameters, Christian colleges and universities ought to do the same. Key to the de-stigmatization of legitimate Christian Bible colleges and seminaries which lack recognized accreditation is transparency. Unaccredited Christian schools should always reveal their faculty, method of education, and they should clearly and unapologetically reveal their syllabi from the outset. Schools should also make all theses and dissertations available to the public. Such transparency can serve as a means unto distinguishing a legitimate institution from a degree mill which either sells degrees and(or) issues them upon the basis of inadequate work. Unaccredited institutions should not hide the fact that they reject recognized accreditation. Rather, schools should treat their lack of accreditation as a badge of honor. A great way to divulge an institution’s commitment to biblical fidelity is to say, “We reject approval from governmental accreditors and are seeking the approval of Christ through his church.” Further, reciprocity agreements between institutions that share a theological vision will further serve to grant prospective students a real means of evaluation. ___________ [1] See “Statement on Licensure,” Association of Certified Biblical Counselors, (2019): [2] Matt. 28:19. [3] According to the Association of Theological Schools, the preeminent national accreditor for seminaries, the average tuition cost for MDiv students per year was $15,442 in 2018-19. Conventional MDiv programs are three years of graduate study (i.e., 90 credit hours). Association of Theological Schools Commission on Accrediting, “2018 - 2019 Annual Data Tables,” (2019): 4.1. https://www.ats.edu/uploads/resources/institutional-data/annual-data-tables/2018-2019-annual-data-tables.pdf. [4] Prov. 22:7. [5] E.g., The Southern Baptist Theological Seminary. [6] There are other reasons institutions seek recognized accreditation, including the illegality in some states of operating an unaccredited institution of post-secondary education. For instance, in my home state of CT, there is not a religious exemption clause for a degree-granting non-accredited Bible institute or seminary. [7] Jamin Hübner, “Obstacles to Change: Overcoming Hurdles of the State Apparatus in Higher Education,” Journal of Religious Leadership, 16.1, (2017): 21. Walston wrote similarly, “Quite simply, accreditation is validation.” Rick Walston, Walston’s Guide to Christian Distance Learning, 5th Ed. (Maitland, FL: Xulon Press, 2007), 64. See also Susan D. Phillips, Kevin Kinser eds., Accreditation on the Edge: Challenging Quality Assurance in Higher Education (Baltimore, MD: [8] Hübner, “Obstacles to Change,” 22. [9] This is true even of what is arguably the most evangelical of recognized accreditors, the Transnational Association of Christian Colleges and Schools. [10] David French, “Gordon College Keeps Its Faith and Its Accreditation,” National Review, (2015): https://www.nationalreview.com/2015/05/gordon-college-keeps-its-faith-and-its-accreditation-david-french/. [11] See WASC’s action letter to Dr. John MacArthur (2018): https://wascsenior.box.com/shared/static/c6ojdrd8tt4w1le7it98nyag0z7d6gzb.pdf. [12] Latonya Taylor, “Christian College Denied Accreditation,” Christianity Today, (07/08/2002), https://www.christianitytoday.com/ct/2002/july8/15.16.html. [13] “Seminary May Lose Accreditation,” Christianity Today, (10/22/1990), https://www.christianitytoday.com/ct/1990/october-22/education-seminary-may-lose-accreditation.html. [14] Samuel Weiss, “Accrediting Agency and Seminary Agree on an Advisory Role for Women,” NY Times, (06/19/1991), https://www.nytimes.com/1991/06/19/education/accrediting-agency-and-seminary-agree-on-an-advisory-role-for-women.html. [15] In the eyes of many in academia, this has already been achieved—accreditation or not. Cf. the comments of Conn who claimed that any school that affirms a confessional position at the institutional level ought to be denied accreditation on that basis. Peter Conn, “The Great Accreditation Farce,” The Chronicle of Higher Education, (06/30/2014), https://www.chronicle.com/article/The-Great-Accreditation-Farce/147425. [16] “Dr. R. C. Sproul,” Ligonier Ministries, https://www.ligonier.org/about/rc-sproul/. [17] “Dr. George Scipione,” Greenville Presbyterian Theological Seminary, https://gpts.edu/about/faculty-staff/scipione/. [18] “James R. White,” Columbia Evangelical Seminary, http://www.columbiaseminary.edu/james-r-white-dminthd-faculty-mentor.html. [19] “About,” Elyse Fitzpatrick, https://www.elysefitzpatrick.com/. [20] “Mark E. Shaw,” Truth in Love Ministries, http://www.histruthinlove.com/marks-bio/. [21] Two of the listed institutions, namely, the North American Reformed Seminary and Forge Theological Seminary do not charge for tuition. [22] E.g., the Accrediting Commission International (ACI), which is the recapitulation of the now defunct International Accrediting Commission, which was shut down for fraud by the Attorney General of Missouri in 1989. See Walson, 87. ACI “accredits” Bible colleges and seminaries even if they teach cultic doctrine. For example, ACI accredits Atlanta Bible College, the undergraduate institution of a non-trinitarian restorationist cult. [23] Walston, 66. [24] See Blumenstyk’s statement, “Accreditors are hugely powerful gatekeepers,” in Hübner, “Obstacles to Change,” 22. [25] This may change as Illinois’ legislature is currently evaluating a deregulation bill (Senate Bill 2822). Cf. Morgan Lee, “Should Unaccredited Bible Colleges Be Allowed to Grant Degrees?,” Christianity Today, (03/26/2015), https://www.christianitytoday.com/ct/2015/april/should-unaccredited-bible-colleges-be-allowed-grant-degrees.html. [26] See for example, Public Act No. 13-118 in my home state of Connecticut: “No person, school, board, association or corporation shall operate a program of higher learning or an institution of higher education unless it has been licensed or accredited by the State Board of Education Office of Higher Education, nor shall it confer any degree unless it has been accredited in accordance with this section.” [27] Reeve Hamilton, “Questions Surround Unregulated Institutions,” NY Times, (12/09/2011), https://www.nytimes.com/2011/12/09/us/questions-surround-unregulated-institutions.html. [28] Douglas Laycock, Religious Liberty, Vol. 2 (Grand Rapids, MI: Eerdmans, 2011), 606.