by Michael R. Burgos
(Updated on 05/14/2020)
A Holy Insurgency
(Updated on 05/14/2020)
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.
[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.
[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.
[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/.
[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.
[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.