Cheryl Dowd, Director of the State Authorization Network, and I have been presenting this summer about the status of the federal state authorization regulation. In those presentations we remind people about other federal regulations that remain in place.

The one that has most surprised those in our audiences is the requirement that students be notified at registration if there are any extra fees in course, such as for proctoring. Many of those in the audience said that they notify students about these costs in the syllabus for each course, which is long after the student registers.

Here is the wording from federal regulations, Chapter 34, §602.17(g)(2) regarding institutions of higher education assuring that they know the identity of students in distance education courses:

“Makes clear in writing that institutions must use processes that protect student privacy and notify students of any projected additional student charges associated with the verification of student identity at the time of registration or enrollment.”

Today’s guest blogger is Leeann Fields from the University of Nevada, Las Vegas. She tells us a story about the consequences for one course in not providing the proper notification for extra costs for proctoring services. Thank you, Leeann!

– Russ Poulin, Director, Policy & Analysis, WCET

Our institution recently faced a situation regarding students not being notified of additional fees in a course during the registration process. The situation occurred over proctored exams. Our arrangement for proctoring has students pay a fee to the proctoring service provider for each proctored exam in a course. Students in this course were not made aware of this requirement before they decided to register.

It Was Our Error in Not Notifying Students of Proctoring Charges

UNLV offered an online course in the Spring of 2018 that included four proctored exams. The first three proctored exams at one hour were $15/exam; the final exam was two hours at $19.75, for a total additional fee per student of $64.75, which each student would additionally pay during the course.

Typically, if there are extra charges, the following notification is listed in the registration system for students to see prior to enrolling in the course: “This course has Proctored Exam(s). Additional verification of identity & additional charges required.” A URL is also given to students for students to learn more in FAQs.

For this particular course, this notification was not provided.

A Student Objected and Did Some Research

One student in the course, upon reading the syllabus, was angry about not knowing about these additional fees ahead of time. The student researched the matter and discovered that he should have been told about this at the time of registration.a man sits working independently at a computer

The student went to both the instructor and the department chair who told him proctored exams were a requirement of the course, and he had to abide by that for the integrity of the course. An offer was extended to the student to come to campus and be proctored on location at no charge. The student objected to this as he declared it was a fully online course, and as such, the institution could not require him to come to campus.

When the Institution Did Not Help, an Appeal to the System’s Board Was Made

The student, after feeling he was making no headway within his department, appeared at the system’s Board of Regents meeting and made the issue known there. He arrived armed with citations of the regulations covering the need for such a notification. The student further went on record stating he was not only making the complaint on behalf of himself in the course, but he was “carrying the torch,” if you will, for all the students in the course.

The Regents were quick to realize the student’s complaint had not yet been addressed by the Dean of the College or any level above that rank. With that in mind, the Regents referred the issue back to UNLV, allowing our institution another opportunity to try and resolve this issue to the student’s satisfaction. This would be similar to a SARA complaint first being sent to a state portal entity with the institution never having had an opportunity to resolve the matter.

The Regents left the door open for the student to reappear if an adequate resolution could not be reached. When the Dean was notified of the complaint made at the Board meeting, the Dean turned to our Educational Compliance staff for guidance on a resolution.

The Dean was assured that the student was correct about not having proper notification. However, removing proctored exams from the course was not an option. The instructor and department held fast to the notion that all exams in the course had to be proctored for academic integrity. Also of note, by this time, the students in the course had already paid for and taken two proctored exams. Educational Compliance personnel at UNLV were instrumental in proposing and implementing the solution that UNLV should cover the cost of the proctoring this one time for all students in this course, which addressed the concerns of the student, the instructor, and the department.

Finding in the Students’ Favor; The Institution Had to Pay

The total cost for proctoring in this course was just over $7,000.00 (~110 students x $64.75). The Office of Academic Affairs agreed to pay half the cost and the particular College which offered the course agreed to pay the other half.

Text image says: The total cost for proctoring in this course was just over $7,000.00

The University had to financially figure out how to transfer $30.00 back to each student in the course to reimburse them the $30.00 they had already paid. For the final two exams, the proctoring service changed the billing arrangement for this course only from “student pay” to “institutional pay.” At the end of the course, the proctoring service sent a bill to the institution for the remaining costs associated with exam #3 and the final exam.

About Our Student in the Story

The student shared that both his upbringing and educational experiences in life were heavily underscored with people who taught him about having a duty to serve and that of fighting to protect one’s rights and freedoms in particular fighting for those who are less fortunate. Those influences may help you to understand why, in the student’s own words, he “saw a need to question the policy” and take up the cause for the “students who did not have the time to read through policy.”

Lessons Learned

Certainly, a take-away message here is that it is important to recognize the myriad combinations of education and experiences our students bring to the table. They are, after all, in higher education because they seek to know and/or seek to create new knowledge. With regard to your students at your institution, never take for granted that an issue is not worth someone’s time.

The fortunate part that came about from this costly lesson is that it did show UNLV leadership the value of having a SARA role, such as mine, within our institution to turn to for guidance. It was proof positive that this role is necessary and valuable. Had UNLV not had the internal expertise to guide the Dean on a fair solution, our institution could have landed back in front of the Regents. Instead, we avoided having to have the Regents intervene, making this an even more public and embarrassing situation, and UNLV demonstrated our commitment to both compliance and resolving matters in a fair manner.

image of text reading: The moral of this story: Just in case anyone doubts it…there is a cost for not being compliant!
Finally, the moral of this story: Just in case anyone doubts it, there is a cost for not being compliant!

author headshot
Leeann Fields
Assistant Director of Professional Development & Compliance
Office of Online Education
University of Nevada, Las Vegas (UNLV)


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