5,001 American colleges get 950 hours of paperwork each from an Education Department rule published on Thursday. It measured the burden on one accrediting body and on none of the colleges. The rule is called Accreditation, Innovation, and Modernization. At the Department's own wage that is $95,551 per college, and $478 million across all 5,001 of them. The whole rule is priced at $490 million a year!! Accreditors are the private bodies that decide which colleges can take federal student aid. More than $120 billion a year moves through that gate. The rule rewrites how they operate, so the Department worked out the cost. 470 hours per agency, priced at the median wage for a postsecondary administrator and doubled for overhead, which comes to $47,273. Against a $600,000 budget that is about 8%, and 8% cleared the Department's threshold. The colleges get three separate assignments. 10 hours to read the rule. 470 for teach-out plans, which are the arrangements for students when a college shuts. Another 470 for new transfer credit disclosures. Its reason for not examining any of that is one sentence. Institutions of higher education are not directly regulated by the proposed rule and could only be indirectly impacted. It adds that data on the impact of accreditation regulations on institutions are not available, in a document that already contains tables of institution hours broken out by public, private and for profit. The rule's own text disagrees about who is being regulated. The institution must publicly disclose within ten business days. The institution must inform the student. The institution must provide a written rationale for every course whose credit it refuses. And no, this is not a drafting slip!! Directly regulated is a term of art under the Regulatory Flexibility Act and courts have read it narrowly since 1985, so the Department has a real argument. It would be an easier argument if the same document did not command institutions by name, list them as paperwork respondents, and cost their hours in three separate tables. The threshold is worth your attention too. The Department defines a substantial number of small entities as more than 5% of them, then notes there are fewer than twenty institutional accreditors, so any single one is over 5%. With nineteen entities, one is 5.26%. That prong cannot return no. Note that the count is the Department's own, and its public directory of institutional accreditors lists more than twenty. The mechanism is a definition that decides the answer before the question is asked. One threshold is written so it always triggers. One exclusion is written so the analysis never runs on the group carrying the cost. Watch the comment docket for a single small college filing its own hour count, and watch whether the final rule contains an institution-level analysis that this one says is impossible!!