According to Steve Levicoff, in his book Name It and Frame It, from Chapter 10, which discusses TRACS historically:

 "Finally, there are two schools listed in this chapter which are accredited by TRACS, the Transnational Association of Christian Colleges and Schools (see discussion in Chapter 3). At this writing, TRACS is recognized by the United States Department of Education but not by the Commission on Recognition of Postsecondary Accreditation (CORPA). Following hearings in May 1995, the Department of Education put the reapproval of TRACS on hold for eighteen months, at which time further hearings will be held on their status (TRACS is still considered an approved accreditor in the meantime). Pending a determination of that status, I have chosen to err on the side of caution and have listed schools holding their only accreditation with TRACS in this chapter. I admit that this is partially an editorial decision based on my skepticism of the past performance of TRACS, and if TRACS receives a full reapproval I will be delighted to move these schools to another chapter in this book. 29 

From Chapter 3:

"....In 1991, the Department of Education recognized the Transnational Association of Christian Schools (TRACS), an evangelical association which accredits Bible colleges and seminaries, but TRACS is not recognized by CORPA at this writing. (Without fanfare, in 1992 TRACS changed its name to the Transnational Association of Christian Colleges and Schools.) TRACS was founded in 1979 to act as an accreditor of private Christian colleges, universities, and seminaries.[2] Unlike the Accrediting Association of Bible Colleges and the Association of Theological Schools, TRACS deals with Christian liberal arts and vocational colleges as well as schools which focus on a biblical curriculum. Their institutional requirements include a belief in "Biblical inerrancy, Biblical authority, the historicity of the first eleven chapters of Genesis including special creation as opposed to evolution, and other doctrines of the gospel."[3]
        Despite the government's approval of TRACS as an accrediting agency, I do not consider TRACS a legitimate accreditor. There are several factors through which I arrive at my rationale:

• The Transnational Association was granted its initial two-year approval from the Department of Education by Lamar Alexander, Secretary of Education in the Bush administration, over the objections of his own Eligibility and Evaluation Staff. Alexander had been friendly toward evangelical Christian schools in the past and his support was instrumental in thwarting the efforts of the Middle States Association to discriminate against Westminster Theological Seminary. However, the sword of politics can cut both ways. Since the approval of TRACS, Richard Riley, former governor of South Carolina, has become Secretary of Education for the Clinton administration. Based on traditional Democratic positions on educational, social, and religious issues, it is reasonable to assume that the government may not be as sympathetic toward religious education and a conservative Christian accrediting agency, and TRACS' approval could fall by the wayside.  

  There are some mitigating circumstances that work both against and in favor of TRACS when it comes to their reapproval by the Department of Education. Based on such factors as the previous recommendations of the Department of Education's Eligibility and Evaluation Staff against the approval of TRACS, the resistance of many people to the intersection of religion and education via tuition tax credits and school choice, and the liberal nature of the Democratic party platform,... From a political perspective, ... note that TRACS was, at the time of its approval, headquartered in Tennessee and that Lamar Alexander, Secretary of Education during the Bush administration, is a former governor of Tennessee (which may have worked in TRACS' favor in terms of their initial approval). ... current Vice-President Al Gore, Jr., is a former United States senator from Tennessee and Dick Riley, Secretary of Education in the Clinton administration, was the governor of South Carolina, which has a large evangelical Christian population. ... the political climate that appears to be against TRACS' reapproval could take second place to the principle of precedent - since TRACS has been approved already, the Department of Education may reapprove them despite the political climate. ...

• TRACS has a category called "associate status." Unlike candidacy or full accreditation, associate status is not a membership category, but is a way for Christian schools who agree with the doctrinal standards of TRACS to identify with the agency. ... some degree mills have subscribed to TRACS as "associates," implying legitimacy through an agency that has been recognized by the Department of Education.

• TRACS itself has granted candidacy status to some questionable schools (including a few listed in Chapter 12 of this book) that would likely never qualify for accreditation by a regional accrediting agency.

• The recognition of TRACS presents church-state difficulties. Their approval by the Department of Education could, hypothetically, be declared unconstitutional if their status is challenged in court. In 1971, the United States Supreme Court articulated what became known as the Lemon test, which holds that any statute on the part of the federal government or a state government must meet all of the following conditions:
  
  First, the statute must have a secular legislative purpose; second, its principal or primary effect must be one that neither advances nor inhibits religion; finally, the statute must not foster an excessive government entanglement with religion.[4]

  In addition to statutes, the Lemon test has been held applicable to local laws, policies, procedures, and other government actions dealing with religion. If challenged, the Department of Education's recognition of TRACS could be declared a violation of all three prongs of the test:
   

  • The act of recognizing TRACS may appear to have a secular purpose, that is, maintaining quality standards in programs of higher education. However, the Department's recognition is specifically geared toward the recognition of a religious accrediting agency whose sole purpose is the accreditation of Christian programs.
  • The Department of Education's approval of TRACS advances religion in general, and evangelical Christianity in particular. While you or I may not have a problem with such an endorsement, the courts have consistently construed that the advancement of religion over non-religion, or of one particular faith over another, violates the Establishment Clause of the First Amendment of the United States Constitution.
  • The courts are likely to construe the monitoring of TRACS by the Department of Education as an excessive entanglement of government with a pervasively Christian agency.

  (As a side note, the same issues could theoretically be raised about the Accrediting Association of Bible Colleges, which is also an evangelical Christian accrediting agency. The Association of Theological Schools, on the other hand, accredits both Christian and non-Christian schools.)

• The doctrinal statement of TRACS contains several points with which many Bible-believing Christians would disagree...

  ... TRACS appears to be expressing a preference for charismatic doctrine. In addition to the general factors which could be interpreted as a violation of the Lemon test discussed previously, the doctrinal statement could be construed as a further violation of the test since it advances a particular form of Christianity (not to mention the effect it will have in terms of alienating many evangelical Christians). One reason for the doctrinaire nature of TRACS' position appears to be that their former board chairman is Henry Morris, president of the Institute for Creation Research, an otherwise unaccredited graduate school in California, and a well-known apologist and creation science scholar who has written extensively about the "young earth" view of history. Morris' influence is so strong that TRACS attaches a two-page defense of the young earth position (written by Morris) to their doctrinal statement.
   

• Finally, many educators I have spoken to at regionally accredited Christian schools, as well as several state education commissioners, have expressed significant reservations about TRACS' credibility. If there are doubts about TRACS within the professional academic community, that raises further questions in my own mind about the extent to which their accreditation will be viewed as credible by colleges, universities, and seminaries that are accredited by an agency recognized by the Department of Education and CORPA.

        For a school to seek accreditation by TRACS does not necessarily indicate that the school is a degree mill; in fact, a few credible schools are seeking or have received TRACS accreditation. Despite the reputation TRACS has among many academic professionals of not being a solid accrediting agency, there are several reasons that a few legitimate schools have decided to affiliated with TRACS. For example:

• Notwithstanding that they are overly doctrinaire and have recognized several schools which I have classified as degree mills, the fact remains that, at this writing, they are recognized by the United States Department of Education (though not by CORPA). This limited recognition ensures that students applying to TRACS-accredited schools will be able to receive federal financial assistance for their education, thus improving the enrollment statistics at such schools.

• Because of their recognition by the Department of Education, some educators see TRACS as a stepping stone to accreditation by a regional agency. "If TRACS will accredit us," the rationale goes, "we may stand a better chance of ultimately being recognized by a regional accreditor."

• In four cases, TRACS has accredited schools that also hold other recognized accreditations. Liberty University, which is accredited by the Southern Association of Colleges and Schools (SACS), is also a fully accredited member of TRACS. However, Liberty was recently placed on probation by SACS and, while the probation was ultimately lifted, the university continues to have financial problems and is under investigation by the Department of Education. ...

• In addition to Liberty, other TRACS-accredited schools that are accredited by agencies recognized by both the United States Department of Education and CORPA are The Criswell College in Dallas, Texas (also accredited by SACS), Christian Heritage College (which was co-founded by TRACS' Chairman of the Board, Henry Morris, and is also accredited by the Western Association), and Florida Bible College (also accredited by the Accrediting Association of Bible Colleges). These schools may feel that TRACS accreditation is a further credible expression of their legitimacy or a hedge against future negative action toward one of the other accreditors, or may simply support TRACS' mission and/or doctrinal statement.

• Schools that might have a moral objection to becoming accredited by a regional agency, AABC, or ATS may have less of a problem with TRACS, which has a more pervasively biblical doctrinal statement with which schools holding to the "young earth" creation doctrine can agree.

• Legitimate schools that have been recognized by TRACS never applied for regional or professional accreditation in the first place, have nothing with which to compare TRACS, have never considered the arguments I raise in this chapter, and may be unaware that TRACS has also recognized several questionable schools.

        In summary, TRACS' limited recognition is somewhat tenuous and their reputation is somewhat controversial. Students are better off enrolling in schools that are accredited by a regional association, the Accrediting Association of Bible Colleges, or the Association of Theological Schools, all of which are fully recognized by both accreditor-approving agencies (the Department of Education and/or CORPA) and by other academic institutions.
        Having reported several negative findings about TRACS, let me say a few positive things before we move on.... TRACS is obviously a sincere effort to bring quality to Christian higher education. I think that they've been sloppy in some of their methodology, but I have no doubt about the legitimacy of their motivation. Second, there are several reputable scholars who are on the board of TRACS and who serve on TRACS accreditation teams, more than can be said about the accreditation mills. The mere existence of TRACS underscores a need for reform in the world of accreditation, as evidenced by recent controversies with some regional accrediting agencies that will be discussed in Chapter 5. Finally, TRACS has responded positively to some of the criticisms in this book (which an accreditation mill wouldn't have done), which also underscores the legitimacy of their motivation.
        (Lest I sound too positive, however, TRACS also threatened to sue me for what I've written about them. They haven't done so, which leads me to believe that their threats were merely a form of pressure to get me to change what I have written in previous editions of this book. Well, I haven't. Suffice to say, the evaluation of any organization should be based on the analysis of available facts and shouldn't take into consideration any external pressures, whether positive or negative.)

A Fourth Edition Postscript on TRACS

        In reviewing the above text on TRACS for this edition, I find no substantive changes in the history and evaluation of TRACS as I have relayed it in these pages. There have, however, been a few developments which bear reporting here.
        In May 1995, the United States Department of Education held hearings on the reapproval of TRACS. Even though they were originally granted a two-year approval in 1991, the hearings were not held until 1995 because of changes in federal laws governing accreditation, a change in presidential administration in Washington, and the appointment of a new National Advisory Committee on Institutional Quality and Integrity at the Department of Education.
        In 1993, as a follow up to Name It & Frame It, I wrote a book titled When the TRACS Stop Short: An Evaluation and Critique of the Transnational Association of Christian Colleges and Schools.[7] Unlike this book, which was written primarily for students and other educational consumers, When the TRACS Stop Short was geared primarily toward the professional education community and addressed only schools that were recognized by TRACS through accreditation, candidacy, or associate status.
        If TRACS was displeased with what I wrote about them in Name It & Frame It, they went ballistic when they heard about When the TRACS Stopped Short and engaged Wendell Bird, a prominent Christian attorney who has written some excellent materials on constitutional issues, to take legal action. TRACS threatened litigation, I had a few laughs, and they never sued. (As for whether my book defamed the accreditor, I felt somewhat vindicated to read in the prestigious Chronicle of Higher Education, "TRACS officials have called [When the TRACS Stop Short] inaccurate, but the Education Department found that the group based some improvements on criticisms raised in the book.")[8]
        At the Department of Education hearings in May 1995, the National Advisory Committee found serious problems with TRACS and voted to give them eighteen months to improve before facing another review by the Department. One problem the Committee found was that TRACS had granted candidacy status to Nashville Bible College, a traditional residential school which at the time had only twelve full-time students, seven part-time students, and two part-time faculty members.
        The Committee did not substantively address the church-state concerns expressed about TRACS here, but did note that the language used to describe TRACS in government publications - indicating that TRACS accredited "Christian institutions which believe in Biblical inerrancy, Biblical authority, the historicity of the first 11 chapters of Genesis including special creation as opposed to evolution, and other doctrines of the Gospel" - could be construed as giving the impression that the Department endorsed a particular set of doctrines. The Committee did recommend the use of more neutral language, but TRACS executive director J. Gordon Henry stated that there was nothing wrong with the description, noting, "TRACS has no identity crisis about who we are."[9]
        As of September 1995, ... J. Gordon Henry has retired as the association's executive director, as has Henry Morris, TRACS' founder and chairman. TRACS has moved from Tennessee (where it had been headquartered on the same grounds as J. Gordon Henry's home) to Forest, Virginia. The association has appointed Earl Mills and Russell Fitzgerald, both of whom served at Liberty University, as associate executive directors.
        In a recent interview, Mills indicated some changes at TRACS which may improve the quality of their performance. However, TRACS policies dictate that action cannot be taken against recognized institutions on an immediate basis, and that questionable institutions must be given time to improve their performance before final action is taken....."  30  

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