Author: Erin Noelle Walton

ED Negotiated Rulemaking: Thoughts, Updates, and New Position Papers from OLC, UPCEA, & WCET

By Erin Noelle Walton

February 27, 2019

1 Comment

The Department of Education has a long list of higher education regulations under consideration in its negotiated rulemaking process. As the calendar of meetings winds down, the path to agreement on most issues remains rocky, but not impossible. Lost in the reporting about disagreements has been the (at least modest) progress that has been made on some issues.

Please remember with this rulemaking that the results could change what you do every day as a higher education faculty or staff person. There are proposed changes to accreditation, the credit hours, distance education, regular and substantive interaction, getting aid for non-accrediting instruction, and much more.

As you may recall, there is a main committee on “accreditation and innovation” that will have final vote on the proposed issues. WCET’s Russ Poulin is serving on the “distance learning and educational innovations” subcommittee, which provides advice and suggested language on selected items. In this post, Russ will give some insights and observations from someone who is immersed in the process. We will briefly update you on some of the issues that we highlighted in our January 30 post and ask for your feedback on some questions.

Additionally, we are very pleased to announce NEW background and position papers created in a partnership between OLC, UPCEA, and WCET. We are pleased to work closely with our colleagues in these organizations.

It is very difficult to summarize many hours of discussions at the table and behind the scenes. We hope that this post gives you a taste of what is unfolding.

About the Rulemaking So Far…

With two out of the three sets of negotiating sessions now completed, we would be at the second intermission…if this were hockey. The latest news is that we already know we are heading into overtime with a full period of negotiating sessions just added for the first few days of April! We have learned from what has happened thus far. Reviewing those experiences will help guide us to the final buzzer.

The Department Staff Is Negotiating in Good Faith

There was much worry that the Department knew exactly how it wanted to proceed with the issues under consideration and that there would be little true negotiating. From his subcommittee experience, Russ believes:

The Department staff have been attentive in listening, have been extremely helpful, and have changed their minds on several issues from what they originally proposed.

In the main negotiating committee, the Department staff have commented several times on their commitment for this process to reach consensus, which means agreement by all negotiators.

There Are Too Many Issues

These issues are complex. It will be hard to get through them before the clock runs out. The subcommittees have provided suggestions to the main committee. However, not all issues have been addressed, yet, due to lack of time. The main negotiating committee, who has been plagued with snow closures and delayed start days due to weather, has acknowledged the shortness of time to cover issues adequately and asked for an additional session. At the close of the February session, the Department approved an additional session for the main committee who will meet again on April 1-3, 2019.

We Must Protect Students and Federal Financial Aid Expenditures

Yes, we understand this fact. However, there are improved educational activities from legitimate providers that do not fit with current regulations. We have to open the door to those activities and we can do it while combatting fraud and serving students well. It takes a focus on outputs over inputs to accomplish that goal. Unfortunately, we can’t make that change in negotiated rulemaking and that will need to be a focus of the Higher Education Act reauthorization. Russ wrote about a broad plan for a multi-level, evidence-based approach to addressing innovations in a post for Higher Learning Advocates. It’s an example of allowing for experimentation while protecting students.

Thank You for the Feedback

Russ has heard from many people and had many conversations about these issues. He apologizes if he has not been able to get to everyone. This post is another chance for providing your input.

An Update on the Issues

We highlighted six issues in our January post. Here’s an update on four of them. Please provide any ideas or feedback that you may have…

Accreditation

The Department wanted to create more competition among accrediting agencies, make all accrediting agencies national accrediting agencies, and create expediated pathways for the creation of new accrediting agencies. The proposals were met with great skepticism by both “distance learning” subcommittee and the main committee.

Definitions of Correspondence Education, Distance Education, and Regular & Substantive Interaction

If 50% of an institution’s courses or 50% of an institution’s students are labeled as “correspondence students,” then the institution is ineligible to disburse federal financial aid. The concept of “regular and substantive interaction” is key to this determination, but remains a fuzzy concept to many in the postsecondary world.

The subcommittee sought to:

Define the concepts of “regular” and “substantive” to be applied in distance education courses, but still has work to do on those concepts.
Define an “instructional team” that would allow for modalities or institutions that use an unbundled faculty model. As an example, some institutions use different people to provide the main instruction, answer questions, and perform assessments. Since “interaction” is currently counted only if it is initiated by the instructor, these educational models are disadvantaged even if they actually provide more interaction and better results than traditional courses. Protections are needed so that unscrupulous institutions do not lessen interaction with subject matter experts.
A “waiver” process was proposed to allow accrediting agencies and the Department to allow for educational models that technically do not meet requirements. In these negotiations, there has been much work behind-the-scenes work to try to develop methods to recognize proven educational modalities, such as competency-based education. Trying to fit “regular” into a process such as CBE that is by its nature irregular does not work. Again, there is irony in that some of these models actually provide more interaction than traditional ones. The “waiver” would allow a path to aid eligibility until this issue could be fixed by Congressional action.

“A ‘waiver’ process is being proposed for educational models that have extensive interaction, such as competency-based education.”

Contracting with a Non-accredited Provider to Offer 100% of an Institution’s Program

The Department proposed to allow an institution to contract with a non-accredited provider to offer up to 100% of an academic program. Almost all of the subcommittee and the main committee negotiators expressed extremely grave doubts about this proposal. It appears that the Department personnel are still seeking a way for institutions to create deeper partnerships with non-accredited providers or find new pathways to allow those providers to become eligible for aid.

State Authorization for Distance Education

There was much work on this issue with more to come. While there is not perfect agreement, the subcommittee was leaning toward the following for which the main committee acknowledges that they will address in March:

Institutions will need to show that they meet the requirements of each state in which they enroll students, either by direct approval by a state or through reciprocity.
A reciprocity agreement is defined, but there are those who would like to put additional limitations on such agreements.
The institution must document a complaint process for students either where the student is located or where the institution’s main campus is located. Students must also be notified of that process.
A major change is being proposed regarding notifications for programs leading to professional licensure. ALL programs leading to professional licensure (whether offered at a distance or face-to-face) would have to notify students as to which states that the program meets educational requirements, does not meet educational requirements, or for which the institution has not made a determination.

The current language leaves out some of the other student notifications that were in the latest version of regulation which was to go into effect in 2018, but were delayed. More conversation on those notifications is anticipated.

ANNOUNCING! New Background and Position Papers from OLC, UPCEA, and WCET

We are pleased to announce a set of four papers available today. Developed in partnerships with OLC and UPCEA, we provide a history of each issue and principles for how they might be resolved through negotiated rulemaking or through reauthorization of the higher education act. The four issues addressed are:

These documents took much work to compile and gain inter-organizational agreement. These papers provide a great history with links to pertinent resources.

Thank you to those who worked so hard on this partnership…Kathleen Ives from OLC; Jordan DiMaggio, Julie Uranis, and Bob Hansen of UPCEA; and Cheryl Dowd and Dan Silverman of WCET. Finally, these documents would not be possible without the input and insights of Van Davis, Foghlam Consulting.

By working together, the organizations are stronger than working on their own.

Cheryl Dowd
Director, State Authorization Network
WCET – the WICHE Cooperative for Educational Technologies
cdowd@wiche.edu

Senior Director – Policy, Analysis, and Strategic Alliances
WCET – the WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu

Accreditation, Assessment, Competency-based Education, Cost of Instruction, Credentials, Distance Education, Financial Aid, Innovation, Legislation, Negotiated Rulemaking, Professional Licensure, Reauthorization, Reciprocity, State Authorization, U.S. Department of Education, WCET

Practice

Expanding access, success, and equitable outcomes through the effective implementation of digital learning

By Erin Noelle Walton

February 21, 2019

A Sense of Urgency

Many public colleges and universities have embraced the mission of increasing access to higher education by recruiting more diverse student populations. Unfortunately, institutions continue to see significant persistence and completion gaps for their low-income students, students of color, and first-generation students. In response to this problem, many two- and four-year institutions have set goals around equity, success, and completion. They are also increasingly looking for ways to meet their targets through the effective use of digital tools.

In 2015, I wrote a Frontiers blog post discussing a project I led at Austin Community College – “Recycling, Revitalizing and Reimagining” – which described the transformation of a former mall into a tech-centered learning space that allows for hands-on, collaborative activities to facilitate learning. The centerpiece of that project featured the use of adaptive learning in developmental math, which boosted student success and eliminated equity gaps. I ended that blog post describing one of our students:

I am reminded of one of my students, Rafina, who is an assistant in a nursing home. Last semester, she pulled me aside with tears in her eyes and thanked us for giving her hope back. “I’m 52 years old and I had given up on my dreams of becoming a nurse. But I can do math now in this program. You have given me my hope back.” This new environment isn’t just transforming their educational experience – it is bolstering students’ confidence and helping them reach their goals.

When we began the work of integrating adaptive learning for the developmental math sequence, there was a steep and lengthy learning curve. The dedicated faculty and staff had to work at an exhausting pace to put changes in place, and it was difficult to get the program in place fast enough to reach all our students. Since that time, numerous institutions have begun to incorporate adaptive courseware across a range of courses. Institutions like ASU, GSU, and UCF have seen positive results with the use of adaptive courseware, which are often accompanied by a restructuring of classroom time to emphasize active-learning techniques. While there are numerous discrete examples of excellent work, the field as a whole is still primarily integrating adaptive learning at the individual faculty level. There is a growing urgency to move faster and more efficiently so that we can reach every learner.

Bar graph of Extent of Courseware Use. — Survey of Adaptive Courseware Use at Institutions
*While adaptive courseware holds promise for increasing student success, at many institutions it has not yet been integrated into strategic plans or priorities at the institutional level.*

This same “impatient optimism” around adaptive courseware is shared by the Bill & Melinda Gates Foundation. In his recent GatesNotes, Bill Gates identified the use of technology in education as one of two resolutions for 2019 that he was committed to learning and thinking about:

How much can software improve students’ learning? For years we have been hearing overheated claims about the huge impact that technology would have on education. People have been right to be skeptical. But I think things are finally coming together in a way that will deliver on the promises.

Maximizing collaboration and communities of practice through a network approach

After recognizing the mounting potential for adaptive courseware and digital learning to support institutions as they drive to increase student retention and success, the Bill & Melinda Gates Foundation invested in a new network that will draw on the field’s combined knowledge and expertise to help institutions maximize the potential of adaptive courseware through effective implementation. WCET was selected to serve as the “backbone” of the new network, Every Learner Everywhere. Adopting a “network approach” means that, instead of each individual institution starting from ground zero and working in isolation, those institutions will be supported by a network that allows institutions to crowdsource and share best practices and lessons learned. This information can help drive the field forward by allowing institutions to strategically integrate technology and use it at scale to improve student success.

Every Learner Everywhere began the work of network weaving in 2017 by bringing together 12 organizations that have been working to reduce inequities through the effective use of educational technology. This new network is focusing its initial work on supporting two- and four-year institutions as they use adaptive courseware to help close persistent achievement gaps. The 12 partner organizations will work collaboratively to support institutions as they transform their teaching and learning practices, align the new technology initiatives to their strategic plans, and use adaptive courseware to achieve their institutional goals.

By working collaboratively as a network, partner organizations will be able to learn from each other and present a unified voice to help move the field forward. Our founding network partners include: Achieving the Dream (ATD), the Association of Chief Academic Officers (ACAO), the Association of Public and Land-grant Universities (APLU), the Digital Learning Research Network, Digital Promise, EdSurge, EDUCAUSE, Intentional Futures, Online Learning Consortium, SXSW EDU Conference & Festival, Tyton Partners, and WCET.

The Every Learner Everywhere network is well positioned to leverage the existing relationships and expertise of its partners. ATD and APLU, which will serve as liaisons to the institutions during the initial phase of work, collectively represent nearly 8 million students at 459 colleges and universities. ATD’s longstanding coaching model helps colleges use data, as well as information from peers in the field, to make strategic decisions and transform their teaching and learning. APLU, through its Personalized Learning Consortium, has significant experience helping institutions use adaptive courseware at scale to improve the student experience. Institutions working with ATD and APLU have already reported promising results of using adaptive courseware, including increased course passing rates, higher retention rates, lower costs for students, and increased student satisfaction.

All network partners are committed to common goals—continuously learning from the field and developing solutions that will reduce inequities across a variety of institutional environments.

Why Adaptive Courseware?

Adaptive courseware has the powerful potential to create a more personalized learning environment in college courses. This technology makes learning more student-centric by allowing students to move through an individually customized path of course material based on their skills and knowledge. However, adaptive technology is not just reshaping the student experience; it is also creating new possibilities for instructors. Adaptive technology gives instructors access to new kinds of data beyond traditional end-of-term assessment scores so they can better understand what students are learning and how they are learning it. Many adaptive platforms allow instructors to see a more complete picture of their students, including real-time study habits, engagement with course material, and patterns of errors. This information empowers college instructors to design more targeted instruction and remediation. Additionally, if students are using adaptive courseware to learn more of the course material independently, instructors can redesign their in-class activities to incorporate more engaging, interactive, and high-impact instructional practices.

Triangle graph with three circles in it. One circle contains the word "quality," one circle contains the word "cost," and the third circle contains the word "access." — Evidence highlights that adaptive courseware has the potential to positively impact the “Iron Triangle” of cost, quality, and access that institutions consider when evaluating their offerings.

What’s next?

During 2019, Every Learner Everywhere will work with a limited cohort of public colleges and universities to develop best practices for:

Selecting adaptive courseware products that meet stakeholders’ needs.
Aligning adaptive courseware initiatives with larger institutional goals.
Collecting and analyzing data to track the success of initiatives.
Redesigning courses to incorporate high-impact instructional practices.
Moving strategically from smaller pilots to scaled initiatives.
Sharing outcomes and enabling peer-to-peer learning.

Every Learner Everywhere will start by working with institutions in three states—Texas, Ohio, and Florida—and then expand nationwide with plans to reach at least 200 institutions by 2022. The initial coaching will use the best practices identified in A Guide for Implementing Adaptive Courseware: From Planning Through Scaling, which details the successes of eight universities that are now using adaptive courseware with more than 100,000 students. Using this as a starting point, network partners will work together to improve and expand their bank of high-quality, field-tested resources and training.

In the coming years, the network will likely expand its focus to begin exploring other types of educational technology and opportunities for institutional transformation. Learn more about the network at www.everylearnereverywhere.org.

Stacey VanderHeiden Güney
Director, Every Learner Everywhere
sguney@wiche.edu

Access, Adaptive/Personalized Learning, Collaboration/Community, Courseware, Every Learner Everywhere, Personalized Learning, Student Success, Technology

Policy

Don’t Wait Out the Federal Rulemaking: These State Authorization Related Federal Regulations are Currently Enforceable!

By Erin Noelle Walton

February 15, 2019

1 Comment

Dan Silverman, WCET/State Authorization Network Assistant Director, and I are taking a brief break from the coverage of Negotiated Rulemaking as it affects State Authorization. We remembered that we needed to make good on a promise we made last summer to more fully explain several other currently effective Federal Regulations that relate to the work of compliance when the institution offers online courses and out-of-state activities to students. Please review and share the parameters of these regulations with your colleagues to ensure current compliance.

As always, we are here for your questions, and we will continue to cover the progress of Negotiated Rulemaking!

—-Cheryl Dowd, WCET/SAN

The 2019 Department of Education Federal Negotiated Rulemaking process is underway. As you may be aware, the 2016 Federal Regulations for State Authorization have been delayed. State Authorization is one of the issues being reviewed in this rulemaking process.

Is your institution attempting to wait for the outcome of the rulemaking before taking steps to manage compliance for out-of-state activities?

Our advice: Don’t wait!

In previous Frontiers posts, we have been emphatic that, regardless of the status of the State Authorization Federal regulations, there are other compliance requirements that remain in place for which institutions must observe. These include:

State regulations;
SARA requirements (for SARA participating institutions);
Federal regulations currently in effect:

34 CFR 668.43 (b): Institutional Information.
34 CFR 668.71 and 34 CFR 668.72(c) (2): Misrepresentation – with specific language about professional licensure; *note: eCFR has not been updated, as of this date, the currently enforceable language defining misrepresentation is found in the Federal Register offered here.
34 CFR 602.17 (g) (2): Notification of costs for student identity verification.
32 CFR 68.6 (c)(6)(ii), Department of Defense (DoD) Memorandum of Understanding (MOU) requires participating institutions to comply with all state authorization requirements for providing distance education to participate in the Tuition Assistance Program for active duty military students.

Additional Information to Know About Federal Regulations

We previously promised to write more about Federal regulations that are currently effective and related to out-of-state activity compliance.

34 CFR 668.43(b) Institutional Information

Existing Federal regulations require institutions to provide information about how students can file complaints with relevant agencies of oversight. In 34 CFR 668.43(b), the Department obligates institutions to, “provide its students or prospective students with contact information for filing complaints with its accreditor and with its State approval or licensing entity and any other relevant State official or agency that would appropriately handle a student’s complaint.”

This regulation was part of the 2010 program integrity regulations for improving the integrity in the programs authorized to participate in title IV HEA programs. Note that this regulation pertains to all students, not just those enrolled in distance education programs. The regulation requires an institution to have a process for the student after he or she has exhausted all possible avenues for complaints at the institution related to consumer protection AND the issue has not been resolved to the student’s satisfaction. There are also rare circumstances in which a student may take a complaint to a state entity if the institution has been non-responsive, has been abusive to the student, or otherwise responded in a way that compromised the confidence of the student. The issues that could be reviewed outside of the institution do not typically include issues related to grade disputes or student conduct.

In August of 2017, the WCET Frontiers blog explained the context for these regulations and provided more detailed information on how to comply. In addition, you may wish to review resources available on the SAN Website Student Complaints page. In short, please note that these are public disclosures, meaning that they must be readily available for anyone with a web browser. SARA participating institutions should also pay particular attention to the NC-SARA resources on student complaint process.

34 CFR 668.71 & 34 CFR 668.72 Misrepresentation

Federal regulations also prohibit institutions from misleading students about multiple issues, including whether programs meet relevant standards from state educational agencies and professional licensing boards. The currently enforceable definition of misrepresentation comes from the 2016 batch of Borrowers Defense to Repayment regulations, which are designed to protect students. 81 FR 75926. If a student defaults on a Title IV loan, and the student’s institution sues for repayment, then the student can argue that the institution’s misrepresentation is grounds to relieve the student from repaying the loan. Hogan Lovells has written a helpful introduction to these regulations, entailing a thorough background; this is a great place to start.

Misrepresentation is, “any false, erroneous or misleading statement an eligible institution, one of its representatives, … makes directly or indirectly to a student, prospective student.” A misleading statement includes, “any statement that has the likelihood or tendency to deceive. A statement is any communication made in writing, visually, orally, or through other means.”^[1] Beyond misrepresentation, the Department also defines “substantial misrepresentation”as any misrepresentation on which a person could reasonably be expected to rely, or has reasonably relied, to the person’s determent.

The effective amendments to the regulation include that omission of information to students is also misrepresentation: “misrepresentation includes any statement that omits information in such a way as to make the statement false, erroneous, or misleading.” 81 CFR 76072 .

An additional regulation, 34 CFR 668.72, explains that misleading statements concerning whether the academic, professional, or occupational degree that the institution will confer upon completion of the course of study has been authorized by the appropriate State educational agency and/or professional boards. Federal regulation 34 CFR 668.72(c)(2) directly addresses professional licensing by explaining that misrepresentation includes misleading statements concerning whether successful completion of a program qualifies a student to “receive, to apply to take, or to take the examination required to receive, a local, State, or Federal license, or a nongovernmental certification required as a precondition for employment…” This regulation is another reason that institutions should be creating a protocol for disclosures related to professional licensure.

34 CFR 602.17 (g) (2) Application of Standards in Reaching an Accrediting Decision

Processes to ensure the registered student is the one participating in the course.
Provide written notice at time of registration or enrollment of any projected additional student charges to verify student identity (ex. Proctoring fees).

The Department of Education has tasked accreditors with providing oversight of institutions to evaluate the institution’s compliance with certain standards before an accrediting agency determines whether to accredit or pre-accredit an institution or program. The accrediting agency meets the Department’s requirement if the agency shows that they evaluated the institution to meet a list of specified standards, as found in 34 CFR 602.17.

Among the list of standards an accreditor will review is a specific requirement that impacts institutions that offer distance education or correspondence education. Institutions that qualify must have processes in place to ensure that the student registering for a course or program is in fact the student participating and completing the course or program. The regulation offers suggested methods for student verification such as: secure login, proctored examinations, or new or other technologies and practices that are effective.

An important aspect for institutions to note is that the regulation imposes an additional responsibility for institutions charging students to use verification processes. As indicated in the regulation’s subsection (g) (2), an institution is required to make clear to the student, in writing, at the time of registration or enrollment, any projected student costs for the process chosen by the institution to verify student identity. This means that it is too late for an institution to inform the student of proctoring costs in the syllabus on the first day of the class. Failing to notify the student of the projected proctoring costs could result in consequences.

If the institution fails to meet one or more of the standards, the accrediting agency is required, per 34 CFR 602.20, to:

Immediately initiate an adverse action against the institution or program; or
Require the institution to take action to meet compliance standards.

A Relevant Tale

In a recent post, UNLV Pays a Cost for Not Notifying Students about Charges for Proctoring Services, one of our colleagues shared a story from her institution. At the institution, the student brought forward the complaint that he had not been made aware, until he received the syllabus, that his online course would include three proctored exams, nor that the proctored final exam would create additional costs for completing the online course. When the student did not receive satisfaction from the faculty and the academic department, he sought relief from the system’s Board of Regents. The Board of Regents, recognizing the requirements and consequences of the regulation, found in favor of the student and his classmates. In the end, the institution was held responsible for $7,000 in proctoring fees. Covering these proctoring fees prevented necessary action by the accrediting agency.

Institutions must interact with the academic departments to determine proctoring needs or other projected costs to verify student identification to notify the student of the costs in writing at the time or enrollment or registration.

32 CFR 68.6 (c)(6)(ii) National Defense; Voluntary Education Programs

Memorandum of Understanding (MOU) for Tuition Assistance for Activity Duty Military Students.
Institutional compliance with state laws where students are served.

The Department of Defense (DoD) requires that all educational institutions providing education programs using DoD Tuition Assistance (TA) are required to sign the DoD Voluntary Education Partnership Memorandum of Understanding (MOU) to participate in the Tuition Assistance Program (TA Program) for active duty military students. Federal regulation Part 68 requires that the institution agree –through the MOU– to provide specific information to students regarding the financial cost and attendance at an institution to protect military students from unfair, deceptive, and abusive recruiting practices as well as provide academic and student support services to Service members and their families.

Specifically, 32 CFR 68.6 (c)(6)(ii), requires that institutions meet the requirements of the states where services are rendered to the students including compliance with all state laws relating to distance education. Therefore, the Department of Defense is tying ability to offer TA for active duty military students to institutional compliance with State laws in the states where course and programs are offered to the students.

Conclusion

While it is important to be following the negotiated rulemaking taking place in Washington over the next couple of months, it may be helpful to understand and remind your colleagues on campus that other relevant federal regulations are in place and enforceable. Hopefully this post–and the linked resources –can help inform your conversations on campus with decision makers. You can also count on WCET to continue to keep you informed of the progress of the 2019 Federal rulemaking process.

^[1] Please note that although this link to the eCFR indicates that an amendment to 34 668.71(c) is delayed until July 1, 2019, this is inaccurate as the eCFR has not been updated. In fact, the delay was deemed illegal by the U.S. District Court in a Fall 2018 law suit and the Department has stated that it will not appeal.

Cheryl Dowd
Director
WCET State Authorization Network

Daniel Silverman
Assistant Director
WCET State Authorization Network

Military and Veterans, Negotiated Rulemaking, SAN, State Authorization

Practice

Adventures at the Consumer Electronics Show: the world’s largest “Digital Disney World,” the higher ed perspective

By Erin Noelle Walton

February 8, 2019

Executive director of WCET, Mike Abbiatti, recently attended the massive Consumer Electronics Show in Las Vegas. New and soon-to-be introduced electronic products are unveiled each year at the Show. The following blog contains the details and reflections of his adventure through the latest technological innovations. He also wonders what the impact of these new tools will be on education. Enjoy!

–Erin Walton

The yearly Consumer Electronics Show (CES) is the Holy Grail destination for anyone interested in the evolution of technology. Just imagine spending a week with over 200,000 of your best friends from all over the world, wandering around several million square feet of the latest and greatest technology innovations from all over the globe.

There are as many reasons to make the pilgrimage to Las Vegas as there are attendees. For example, if you are the creator of new tech, you are looking for a venue to show your wares. If you are tasked with purchasing new technology for any organization, then you must be there to be sure you can make the appropriate purchasing decision. Similarly, if you are a new company, or an accomplished one looking to move to the next level or retire, then you are at CES in an attempt to sell your company to Google, Amazon, or one of the titans of the industry. And, if you are a CIO/CTO/CSO, then you are there to try to stay current in your profession.

But, what in the world would a technocrat such as myself be doing at this revered event? Given the transformational impact of consumer technology on the strategic transformation, operational diversity, and tactical reality on the entire educational community of interest, the importance of CES cannot be overstated. I embarked upon quite an adventure for a few days that was based in two perspectives: benefits (perceived and real) and risks (also perceived and real) when it comes to the impact of evolving technology and the quest for success for all learners.

Motivations for Attending the Consumer Electronics Show

One of my basic philosophical motivations for attending CES was to underscore my belief that a major shift in technology-enhanced education is the fact that tech no longer moves from the institution to the home, but rather moves from the home to the institution. The impact of this shift cannot be overestimated when it comes to planning for the future of K-20 education. When one adds the evolving cyber-threat landscape, one discovers a new set of opportunities and challenges.

My focus was not infrastructure, but learning more about the impact of new technology on planning, legislation, policy, finance, and the unintended consequences of becoming universally dependent upon technology in teaching people how to do what they don’t know how to do. Currently we call this process ” education.” CES should be a ” must attend” for senior, non-technical higher ed leaders, not just the staff engaged in the daily deep dive into the digital transformation of academic institutions.

The excitement surrounding attending the world’s largest Consumer Electronics Show (CES) is palpable from the moment one boards the airplane destined for Las Vegas. The aircraft is populated by technologists and commercial reps from all over the world. During this trip, I sat next to a young lady whose only job is to circulate around select venues and collect “leads” for her client companies. The discussions I had throughout the trip with other passengers centered on the anticipation of seeing the latest and greatest tech systems and devices that will drive their worlds — from the home to the office — in the near term.

The Adventure Begins

At the show, most of my adventure was spent walking many miles throughout four large exhibit halls and several hotels filled with amazing video, audio, and data manipulation devices. The intent was to gain a general understanding of the physical layout and thematic areas of each venue. It was quite clear that the major topic of focus was “Artificial Intelligence (AI)” and Virtual Reality (VR). Highly touted was the combination of AI, content selection, and audio manipulation. It was clearly demonstrable that technology could create pictures and animation that were almost indistinguishable from live humans. This could certainly have an impact upon future faculty selection. The question could be, do I hire a new faculty expert, or just order one? Not so clear was the fact that true Artificial Intelligence has yet to be achieved and that which was being touted was actually Machine Learning enabled by ultra-fast computer chips and fiber optic transport systems. The significance of this fact, in my context, is that anyone interested in leveraging the latest technology in education should be aware of the realities versus the marketing hype.

In one area, I interacted with an “AI-based” whole body scanner that took a minute or two to scan me and promptly announced that I was a 37-year-old male. Since I am actually a 69-year-old male, I was less than impressed. The night before the exhibits opened, a Russian robot was run over and destroyed by a fully automated Tesla sedan. Barring an international incident, it appears that we have a few glitches to iron out before we entrust our lives to the latest and greatest digital marvels.

The Search for Educational Exhibits

That said, an intriguing aspect of CES was not digital, but rather human. A large proportion of the 200,000 attendees were from Southeast Asia, and this fact was pronounced in the video venues, except in the gaming areas. When it came to gaming and Virtual Reality technology, most of the attendees were from the western nations. In a similar context, the Asian participants were noticeably younger than their western counterparts. I thought this was an interesting observation that demonstrated the investment some countries are making in the education and workforce preparation of their youth.

To cap off my search for educational exhibits, I only found one company with the word “education” on its title and exhibit space. I am sure that there were educational enclaves, but I was only successful in finding one Innovation Space dedicated to higher ed. It appears that the academic community is expected to repurpose technology for the teaching, learning, and research missions. Perhaps readers who attended CES were more successful in finding education-specific venues.

My continuing adventure launched into searching the wonders of state-of-the- art robotics and drone tech. Throughout the week, I kept out a watchful eye for wandering Russian robots and autonomous Teslas. I am sure that there are colleagues at CES who did actually find the education-focused venues and I hope they will follow this blog with their experiences. It is literally impossible to see everything at CES by yourself.

Having gotten a pretty good idea that it is impossible to see all the exhibits at the Consumer Electronics Show, I took a more comprehensive approach. Clearly, Healthcare is at the top of the CES list of foci. My tech-trek revealed quite a variety of technologies relative to generalized integration of AI (Machine Learning) and all types of Mixed Reality (VR and AR). The sheer number and complexity of Healthcare exhibits and products was most impressive.

Discovering Immersive Reality

As stated earlier, the overall CES theme of AI integration into the process of data collection, manipulation, and outcomes was evident. Medical devices designed for both home and clinic use were in abundance. A common theme was Immersive Reality use in training of professionals, dental and medical procedures, and treatment of mental health problems. Home scanners and testing devices not only claimed more effective and affordable than healthcare services, but also a move toward encouraging patients to take control of their healthcare.

Mike wearing bronze and gold steampunk glasses with gears, wires, and gold lenses. — WCET Executive Director, Mike Abbiatti, is always on the lookout for the latest in educational innovations.

The evolution of Telemedicine systems that provide high quality data collection and visualization via an electronic connection between the patient and healthcare provider community continue to promise lower costs by reducing/eliminating travel expenses, and making more efficient use of caregiver time and resources. Add in the plethora of wearable devices designed to monitor health status of the wearers and connect directly to caregivers and you have a highly mobile system.

The trend toward more large retailers investing in healthcare clinics in their stores was also quite evident, thus providing more access to caregivers and to a wide variety of people as part of the shopping process. CES was an amazing journey through Digital Health. Given the shortage of healthcare professionals and the differentiation of healthcare needs on a global scale, the role of technology will continue to increase. In exploring these exhibits, I heard a good bit of discussion about the challenges inherent in relying upon computer-based systems, like robotic surgery, and AI-enabled diagnostic tools when it comes to something as personal and prone to legal liability as one’s health.

CES is the best of all worlds and the worst of all worlds. Currently there is a rush to integrate AI, and the new tech is always is more expensive. These trends are deployed so fast that the actual success in the academic environment is more faith than fact. Historically, legislation and policy lag behind innovation; thus, funding also lags in the higher education community. Today, the reality of increasing cyber-vulnerability adds a new dimension of risk. When higher ed decides to purchase the latest and greatest data collecting, analysis, and decision-making tools, the tendency can be to follow the ready-fire-aim model based upon clever marketing and the perception of public/private urgency.

How to Ensure Student Success

CES is a wonderful experience that I highly recommend to higher ed non-technical leaders to create strategic awareness relative to the acquisition of new technologies required to maximize technology-enhanced education for the growing student populations we serve. Our profession is ensuring student success; our tools are constantly evolving. The Consumer Electronics Show (CES) is an effective source of data from which we make decisions about how we will deliver responsive excellence. From the perspective described in the first paragraph of this blog, I am not only excited about the potentials that new tech brings, but cautious about the inherent risks. It is not rational to think that one person can see and interact with all the devices/systems on display at CES. However, it’s important to remain focused on the fact that the technology is not the most important aspect of the academic experience; rather it’s what we, as educators, actually do with the tech. The way we utilize tech is the most important filter through which to pass all of the magic that CES provides.

[youtube https://www.youtube.com/watch?v=mHreov2zl1U]

Educational technology is currently experiencing a significant upswing in investment. This availability of funds will spawn legions of new devices and systems designed to collect data more efficiently, transport data faster, process data more rapidly, and generate potential decision support. We must also be aware that all new technologies have inherent risks associated with vulnerability, primarily data theft from external and internal (intentional and unintentional).

What About Data Protection?

I was disappointed to see that the FBI had only a small booth with three attendants in one of the venues. I will admit that most venues and product displays at least mentioned, even if in passing, the importance of data protection. When one considers the steep learning curve that those associated with funding, managing, protecting, and delivering curated academic content to an ever-increasing diverse and distributed population of learners, one can understand the necessity of having an effective cyber-defense strategy. Adding one or more of the amazing devices or systems to your home, your institution, or your classroom can be a risky scenario.

Final Thoughts and Call to Action

I will end this blog by stating that the Consumer and Electronics Show was an excellent example of the marketable trends. As educators, we must be mindful of the fact that technology is valuable only when the devices and associated software enable quantifiable student success outcomes. My assertion that technology moves from the home to the institution was validated at CES. My concern that we could easily allow technology to become the driving force in education was also confirmed, at least in my case.

In closing, I had a unique opportunity to view the wonders of a burgeoning global technology marketplace through the lens of an educator and technocrat. The basic outcome for me is that we must be careful to ensure that the focus of our collective efforts, and investments in our home and institutional in technology must not be influenced by the technology, but rather by what we DO with the technology to improve our lives and the lives of the students we serve.

A Practical Note

Please think about attending the Consumer Electronics Show in the future. The actual cost was only $100 for a pass to the exhibit halls, with the added cost for the travel to Las Vegas. The lost opportunity cost would be significantly more than $100. I will add that there are certainly much more expensive passes one can purchase that allow entry into the keynote and breakout sessions. My rationale for avoiding the extra cost was that I didn’t see a need to attend sessions that would provide information that would probably be outdated the next day. Our colleagues at SXSW.edu, etc., do a great job of providing a tradeshow with more of an academic focus. However, seeing the whole picture at the Consumer Electronics Show is certainly an excellent pathway to stand on top of the mountain and survey the horizon.

Mike Abbiatti
Executive Director
WCET

Artificial Intelligence, Cybersecurity, Digital Learning, Innovation, Technology, Virtual/Augmented Reality

Practice

A Recipe for a Successful Institutional Open Education Initiative

By Erin Noelle Walton

February 6, 2019

1 Comment

Rajiv never ceases to amaze me; the first time was at Nicole Allen’s (SPARC) annual OERroke party at Open Ed. Rajiv can really sing and dance. Although it is hard to top a duet performance of “I Had the Time of my Life” from Dirty Dancing with Amanda Coolidge (BC Campus), Rajiv has gone on to even greater accomplishments. On Jan. 23, 2019, BCcampus announced Dr. Rajiv Jhangiani was the winner of the Award for Excellence in Open Education. He has worked tirelessly to advance open education and open pedagogy in Canada, the US, and around the world. While I believe Rajiv would’ve been successful at any career he chose, he has dedicated his life to making education accessible, equitable, and inclusive for others. Take a few minutes to read his insightful blog, and then follow Rajiv on Twitter, read his book, and watch his talks on Youtube.

—Tanya Spilovoy, WCET

I believe in the power of open education to help widen equitable access to education. I believe in using open resources, not only for the financial benefits for students, but also for the impact on teaching and learning.

As an early adopter of open textbooks, I have for years witnessed first-hand the tangible impact of the cost savings on my students’ lives. As an open textbook author, editor, and OER project manager, I have heard from numerous faculty who have taken advantage of the open licensing and built upon my efforts. They have updated, augmented, and adapted the resources available to better serve their students. As an open education researcher, I have investigated the perceptions and impact of OER adoption on students, faculty, and institutions. As an open education scholar, I have published articles, chapters, as well as a book on the subject. As an open education advocate, I have had the privilege of working with over 100 institutions across five continents to help build local capacity and guide their efforts to support this important work.

In the course of this work and especially in the context of my role as the institutional lead for open educational practices at Kwantlen Polytechnic University (KPU), there is one question to which I have given a lot of thought in recent years: What enables an open education movement to gain traction within an institution?

My University is a Proud Leader in the Open Education Movement

But first, let’s provide some context: KPU is the leading institutional adopter of open textbooks and other OER in Canada. We launched the country’s first two Zed Cred programs (known as Z Degrees in the U.S.) over the past two years, established an OER grant program (overseen by a dedicated and cross-functional Open Education Working Group), integrated Zed Cred markings into our course timetables, established a print-on-demand service for open textbooks, provided faculty development opportunities for open pedagogy, and recently launched OPUS, an open publishing suite to support faculty and staff who wish to create or adapt OER. I mention these achievements because my reflections on successful open education initiatives are inevitably guided by the growth of our own initiative efforts at KPU.

Lessons from Our Success

In reflecting on my experiences, I realize that, although open education champions are critical (be they faculty, librarians, instructional designers, or students), there are at least eight other necessary ingredients that must be present for their message to gain traction. They are as follows:

Most importantly, there needs to be at least some grassroots interest upon which to build. This is not terribly difficult to locate, and you will likely find several faculty members at your institution who have been adopting open textbooks, even though they may not have informed others of their practice. Perhaps some faculty have been embracing open pedagogy without specifically using that term. This is the base which the champions can leverage to grow the movement on your campus, including by recognizing and celebrating these early adopters.
To serve a growing grassroots interest, champions must have the ability to raise awareness and provide adequate training and support to their colleagues. This can take the form of:
- Campus events that bring in articulate speakers who are well-versed in open educational practices. This is key because of the phenomenon of internal experts usually being discounted,
- Regular professional development opportunities (e.g., offered by the library or teaching & learning centre), or
- An OER grant program to support the creation or adaptation or OER and related ancillary resources.
While efforts to raise awareness and provide support must include a focus on the potential cost savings to students from adopting OER, these efforts should also highlight the potential of open pedagogy to spur innovation in teaching and learning. In many ways this is almost a more important message; although many educators initially come to open education for the cost savings, they often stay for the pedagogy.
Training and support should be paired with regular communications (including during Open Education Week) that raise awareness of the problem of high textbook costs and the availability of high-quality OER. But the framing of these communications is key and should foreground academic freedom. After all, agency and choice are core values of the open education movement just as much as is access, something that manifests in a variety of ways — from the control over the content provided to faculty through open licensing, to the central role given to students in their learning journey via open pedagogy. So, it should be clear to faculty that OER are a new, additional option that is available to them and that they are the only ones who can determine which resources are appropriate for their students and their specific courses. The role of the champion is therefore only to make them aware of available high-quality OER and to provide them with the necessary support should they choose to adopt these resources.
Of course, none of this happens magically. Although champions are usually driven by their passion for the movement and its implications for social justice, permitting their critical work to occur “off the side of their desk” is a surefire way to ensure burnout. The movement will then likely die an early death. So, just as champions can support their colleagues, the champions (the most irreplaceable of all ingredients) themselves need support, whether in the form of time releases or secondments, role re-designations or the creation of a designated position, or even necessary funding (e.g., for campus events and OER grants). Note that each of these assistances stems from the visible and tangible support of senior administrators.
A helpful strategy to grow grassroots support and earn the support of senior administrators is to conduct research. At KPU, we have conducted and published research to better understand the negative impact of high textbooks costs on educational outcomes and on the efficacy of OER adoption. Although plenty of this research already exists, it is helpful to demonstrate these same effects in your local context. Efficacy research — which might be done in collaboration with some of those early adopting faculty — also complements the social justice and pedagogical innovation arguments for OER with an evidence-based practice argument. At KPU, since the launch of our Zed Cred programs, our research efforts have grown to include investigations of the impact of the initiative on course waitlists, withdrawal rates, and grade distributions, all useful metrics through which I can demonstrate the institutional impact of this initiative.
To give the research data context and strengthen the case for supporting open education to the institution’s board, it is valuable to make explicit connections between the open education initiative and the institution’s strategic goals. This is vital whether these include student access, student success, pedagogical innovation, or leadership. The same is true for strategic goals at the program level. For example, at several institutions I have seen programs that are struggling with declining enrollment invest time and resources into OER development and adaptation so that they can market these programs as Z Degrees (to good effect, I might add).
Finally, although it is possible for an open education initiative to succeed on the back of local expertise and sweat, it is far more common for progress to take place when the institution seeks opportunities to collaborate with external organizations and institutions. This might take the form of applying for external grant funds (as we do from BCcampus), joining the Open Textbook Network, connecting faculty at one’s institution with like-minded colleagues at other institutions via the Rebus Community, or even looking for opportunities for collaborative OER development across institutions in the same region.

Adapt These Steps for Your Institution

While this is not mean to be an exhaustive list, nor a universal formula applicable to all contexts, I have tried to capture the elements I have found to be essential in the context in which I work.

Without doubt, the recipe that has worked for KPU is a function of our identity as an open access institution that is focused on teaching excellence. Regardless of your institutional lens and goals, I can assure you that, once this momentum begins to build, you will see signs that include faculty proudly sharing their innovations, external recognition, and gratitude from students. And if you are lucky, the initiative will reach the point of where it is now at KPU — where open education is an integral part of our institutional DNA and a core part of our identity.

If you are passionate about widening equitable access to higher education, about improving student persistence and performance, and catalyzing pedagogical innovation, I urge you to follow our lead.

Rajiv Jhangiani
Special Advisor to the Provost on Open Education
Kwantlen Polytechnic University

Faculty, Open Educational Resources, Professional Development

Practice

Past the Point of No Return: The Not-So-Shadow Education Sector

By Erin Noelle Walton

February 1, 2019

3 Comments

Welcome to Sasha Thackaberry (Vice Provost, Digital and Continuing Education at Louisiana State University and member of WCET’s Executive Council) who authored today’s guest blog post. At a couple meetings of our Executive Council, we’ve had brief discussions about the growing sector of non-accredited providers. One of our worries is that traditional education institutions might not be paying quite enough attention to the emerging challenges or possible benefits of working with these new providers. Thank you to Sasha for your insights.

— Russ Poulin, WCET

The point-of-no-return has been reached in higher education; most institutions just don’t know it.

In higher ed, particularly in the online and innovation space, we know all too well the drivers that are pushing new learning models. Student loan debt now exceeds $1.5 trillion, employers are minimizing or eliminating their degree requirements, and many students and employers question the value of a college degree. Still, there are other employers and fields wherein advanced degrees are increasingly required – otherwise known as “degree inflation.” The mix of economic pressures from without and within, combined with the coming demographic changes in higher education’s traditional-aged population and the decade of state disinvestment in public education, has forced many institutions to transform or die. Arizona State University, under the leadership of Michael Crowe, innovated into the online space, as did Southern New Hampshire University, a private not-for-profit. Western Governors University is continually expanding their footprint nationally with their competency-based education model that is flexible and cost-effective.

Into this landscape comes the “Shadow Education Sector,” which is increasingly less shadowy. This category encompasses Boot Camps and a variety of micro-credentials from the providers formerly known as MOOCs. Education is getting more condensed, shorter-formed and more workforce relevant with flexible start dates. Companies themselves, eager to train the next generation of tech workers, have made their content available for free – examples include Salesforce’s Trailhead, Microsoft Learn, and AWS Training and Certification. Combined with verified assessments, these “competency-first” alternative credentials are an effective way to upskill at little cost to learners. Dominating this space are technology credentials, followed by analytics and business-related credentials.

The Questions That Arise

With the availability of cheap alternatives to gain skills that enable family-sustaining wages and social and economic mobility, there are two central questions that arise:

What happens if fewer students elect a full college or university degree in favor of alternative credentials?
What does this mean about who we in the higher education space, and what our purpose is?

In other words, is the traditional university or college still relevant in the same way? Will it be in 10 years?
To address the first question, the fact remains that fewer students are already electing a full college or university degree. We know this because of the decline of enrollments in higher education overall, combined with the number of players and credentials emerging in the “Shadow Education” space. Though the economic model for former-MOOC programs may not be fully hammered out, they still collectively attract millions of students. Some of these students would have been going into a college or university environment to get additional education or a degree. Free or low-cost combined with flexibility is a compelling competitive advantage compared to a full degree. For example, Trailhead by Salesforce had 600,000 users in 2018, which was three times the number of users the previous year – there is a demand and it is growing.

There are some interesting secondary questions. Who knows about these low-cost, high ROI offerings? The demographic studies for MOOCs at the beginning belied their original purpose with a majority of learners already being educated, most with a college degree, older, and primarily male. The most recent analysis I could find on demographics also indicated that learners in micro-masters and specialization programs, traditionally under $1,000, are still roughly in this demographic, though equal percentages of women and men were reported.

In other words, it may be that most learners who are taking advantage of the alternative, low-cost options are the students who could have gone back to college for an additional certificate or degree. Some similarities in demographics lend credence to this hypothesis – the average age was 35 from this study from Teachers College, nearly identical to the average age of students in fully online programs.

Though enrollment in online courses and programs are still growing nationally while overall enrollment in higher education declines, the percentage growth has slowed. It is no accident that during this slowed growth, a huge marketplace of alternative credentials, largely offered outside of higher education, has emerged with large numbers of enrollments.

Conclusion: The (Not-So) Shadow Education Sector is pulling away students who otherwise would have enrolled in college and university programs.

There are some experiments with institutions merging these alternative credentials into their traditional degrees and certificates, even at the curricular level as is the case with students at UMass in one program. There has not been a landslide of investments in this space since this thorough analysis conducted in 2016 by Deborah Keyek-Franssen who wrote an excellent synopsis of the then-current state in The Mainstreaming of Alternative Credentials in Postsecondary Education. The expanded alternative credentials that are available through partnerships with MOOC companies like edX and Coursera look more like OPM relationships that have significantly less ROI from a financial perspective for the universities that partner on them.
The EQUIP program, an experimental site option from the Department of Education to provide federal funding for programs that used over 50% of their programming through secondary providers, was underutilized. Now the DE is in negotiated rule-making, which could significantly change the rules allowing providers to access federal financial aid for programs that could be essentially academic passthroughs, where colleges and universities can provide credentials for education delivered largely by a third parties.

Once again, when colleges and universities fail to evolve fast enough, the pressure comes from the outside to force us to evolve.

Colleges and universities still have the opportunity to evolve the degree through stackable options to meet the needs of a changing economy and changing needs. Our mission to provide lifelong learning is needed more than ever to support the development of thinking minds along with technical skills. But that window of opportunity is closing if you can hear the signal in the noise.

Personally Passing the Point of No Return

I end with a personal story. My husband was outgrowing his previous job, but didn’t have a coherent career path, and his current skill set is mainly within docketing in patent law, which is pretty much a niche field. He is looking to transition careers.

Because I work in the field of online learning, and my husband is an actor by training and passion, I thought that he might want to experiment with learning experience design and course building. So, I curated for him an increasing complex set of learning experiences to determine if this was the right next step for him. He took a MOOC course from University of Maryland University College, the core Quality Matters training, and is doing an unpaid internship. He’s now in a free IDEO course on Learner Experience Design.

We are currently considering a graduate degree for him, but not a traditional one. Now that he has a decent skill set in this space, he’s considering an M.Ed. in Learning and Technology from Western Governors University. It’s competency-based, low-cost, and highly flexible. With their flexible pacing, he could (with his now solid prerequisite knowledge) graduate with a degree in as little as 6 months.

My husband is among a demographic that previously might have immediately gone back for a graduate degree to obtain those skills and that credential. But welcome to the Shadow Education Sector/next DIYU evolution – in walks in the free online education offerings.

The flip side of that is hiring. I do quite a bit of hiring.

The Flip Side

Recently we wanted to hire a web developer. Of the candidates we interviewed, one rose to the top. He had several credentials, including one from a Boot Camp, and significant experience in the field. What he did not have was an undergraduate degree. He’s still working his way through his undergraduate degree at – you guessed it – Southern New Hampshire University. We hired him, and he has been an amazing addition to the team.

We have passed the point of no return.

Who among us has the open mind and attitude to listen to this (loud) signal in the noise? Who among us has the will to evolve? Because in higher ed, our mission matters. And we can do it better, and we can do it together, but only if we do it now.

Right now.

Sasha Thackaberry
Vice Provost, Digital and Continuing Education
Louisiana State University

Credentials, Distance Education, Online Learning

Policy

ED Negotiated Rulemaking: Issue Summary and Seeking Your Input

By Erin Noelle Walton

January 30, 2019

5 Comments

WCET continues to cover the wide-ranging set of rule changes that are being proposed under the U.S. Department of Education’s negotiated rulemaking process. The Department is seeking input on several major changes on issues with special focus on accreditation and how to handle “innovation” in qualifying students for federal financial aid. Examples of what is being proposed include fundamental changes to the recognition of existing and new accrediting agencies, competency-based education, regular and substantive interaction in distance learning, state authorization of distance learning, and written agreements allowing institutions to contract 100% of a program to a non-accredited entity.

WCET’s Russ Poulin serves on the Distance Learning and Educational Innovation Subcommittee, which has conducted one of its three sessions. Meanwhile, WCET State Authorization Network’s Cheryl Dowd watched a large stretch of the negotiations via live-stream. We collaborated on this post to give you a taste of the complex topics being discussed. We also tried to simplify the feedback process by asking some very direct questions about each issue.

In our analysis below, we focus on issues that are of great interest to the competency-based, distance, and correspondence communities that Russ is representing. We also focus on issues that have been discussed, with the exception of the last one below. That particular one covers the “academic integrity” expectations, which appears to expand beyond distance education to ALL courses. The subcommittee has yet to tackle this issue.

Enjoy our write-up of the following issues. We’d love your feedback…

Accreditation

The proposed changes to accreditation are numerous and could fill an entire post on their own. We cover only one below.

In brief, the Department is proposing more competition for accrediting agencies by making it easier for more agencies to be created. Frankly, the two of us would like to know more about this vision. On the face of it, a competitive model does not seem to be fully compatible with the oversight role expected of accrediting agencies. We can see where they are trying to promote accreditors that are focused on sub-sectors or encourage more innovation, but is this the way to accomplish that goal?

602.3(b) What definitions apply to this part? Scope of Recognition for Accreditors (See pages 1-5)

Among the issues related to accreditation, the subcommittee reviewed the Department’s proposed language describing the Department’s scope of recognition of the geographic territory of accrediting agencies. The Department staff indicated that the proposed language was designed to provide clarification to an existing capability regarding overlapping geographic areas of accrediting agencies. For example, a regional accrediting agency may authorize institutions within the same geographic area as a state accrediting agency. The purpose of the existing regulation was described to encourage competition among accrediting agencies.

Despite the assurance of the Department staff that the new language does not change current available practice, members of the subcommittee expressed the following concerns:

While institutions may currently choose between a national or regional accrediting agency, there may be unintended consequences by increasing competition among accrediting agencies.
Institution choice may cause an institution to select the accrediting agency that is perceived to be the easiest to achieve approval.
While the Department wanted to level the perception of a hierarchy between regional and national accreditation, the result may be an increased accrediting hierarchy by some institutions, creating an agency only for “elite” institutions.

Questions:

Should the Department encourage competition among accrediting agencies?
If there are choices for institutions in selecting an accrediting agency, what protections should be put in place to maintain quality among the agencies and prevent confusion to students?

Definitions of Correspondence & Distance Education, Including Regular & Substantive Interaction

600.2 Definitions: Correspondence courses, distance education, and regular & substantive interaction (See pages 2-4)

In 1992, the definitions of “distance” and “correspondence” education were written in opposition of each other. If 50% of an institution’s courses or 50% of an institution’s students are correspondence students, then the institution is ineligible to disburse federal financial aid. Embedded in the definitions is the concept of “regular and substantive interaction,” which has been the subject of guidance from the Department, but is still a fuzzy concept to many in the postsecondary world. In the Department’s guidance and in audit findings, the focus has been on activities by the instructor, which seems to define “instruction” more than “interaction.” There have also been questions about who qualifies as an instructor.

There are huge implications in the outcomes of this issues for distance education, competency-based education, and consumer protection. Remember that the ultimate goal for the Department is to design a way for them to determine what counts and does not count for aid eligibility. It would be nice to have a more outcomes-based alternative, but it is unlikely that will fly.

Questions:

The Department is proposing allowing for an “instructional team” so that institutions using an unbundled faculty model (one course may have different people providing direct instruction, academic feedback, and assessment feedback) are included. How would you improve that definition?
The Department is proposing that an institution’s accrediting agency determine who “qualifies an instructor or a member of an instructional team and what qualifies as regular and substantive interaction” given some guidelines. Does it work to have the accreditor make this determination? How would you improve it?
Should there be an option of interaction initiated by the student instead of the instructor, such as happens in a competency-based education course? How do we guard against the student being left to learn on their own?
One of the guidelines for regular interaction includes the requirement for instructor-initiated interaction at least once per week in a non-term program. One institution said that this would harm their CBE program. How would you improve?
You may want to look at the proposed language and suggest improvements.

What Counts as a Correspondence Student?

600.2 Definitions: Calculating the number of correspondence students (See page 12)

As mentioned above, if an 50% of an institution’s students are declared to be “correspondence students,” then that institution is ineligible to disburse federal financial aid. Previously, there was no guidance on how to calculate which students are distance or correspondence. The Department proposes that a “correspondent student” is one “whose enrollment during an award year was entirely in correspondence courses. This is a small change that could have a big impact on institutional eligibility.

Questions:

Does that definition work?
Does that definition protect against fraud?

Contracting with a Non-accredited Provider to Offer 100% of an Institution’s Program

668.5(c) Written arrangements between an eligible institution and an ineligible institution (See pages 15-17)

One of the proposed changes that received the most discussion the proposal for institutions eligible to disburse financial aid to contract with an ineligible institution or organization. Under current regulations, the ineligible institution is allowed to offer less than 50 percent of the educational program. The proposed change would remove that cap and allow an institution to contract out as much as 100 percent of a program.

Picture from sign posted at the Smithsonian National Air and Space Museum. The signs read "The National Air and Space Museum is Closed today." — No visiting the museums while rulemaking was conducted.

Negotiators expressed considerable worry about the possible ramifications of allowing an institution to contract the entirety of program. What controls would the institution have over the program? Could this lead to more fraud?

Questions:

The Department negotiators said that they were not necessarily wedded to their proposal that would allow institutions to contract out as much as 100% of a program. The limit is currently 50%. At what percentage should the limit be set?
Should an institution be limited in the number of programs it contracts out? If yes, what should that limit be?
What other safeguards are required?

State Authorization for Distance Education

600.2 Definitions: “state authorization reciprocity agreement” (See page 7)
600.9 (c) state authorization for distance education (See pages 13-16)
668.50 Institutional disclosures for distance or correspondence programs. (See pages 41-43)

The Department’s proposed changes included the elimination of the currently delayed 2016 State Authorization Regulations. However, the Department shared that the initial discussion from the subcommittee has caused Department leadership to change their thoughts from eliminating the regulations to now understanding that the concepts are important to keep, but there is the need to determine what must be changed or clarified. The official from the Department leading the subcommittee discussion on this issue reiterated that, prior to 2010, there was no Federal regulation related to state authorization for activities that occur outside of the state of the institution. The purpose of the regulation, he explained, was a hook to require that institutions follow the states’ laws for activities in order to participate in title IV programs.

For the definition of a “state authorization reciprocity agreement” (as included in the 2016 regulation), not all committee members concurred as to the interpretation of the language surrounding enforcement of state laws versus reciprocity agreement standards. The Department provided the letter from former Undersecretary Ted Mitchell describing the intent to support that the state would agree to use the standards of the reciprocity agreement. It was additionally discussed that most states went through a legislative process to participate in SARA, which is a voluntary reciprocity agreement for the states.

Several concepts for state authorization regulations were underscored as important. First, that elimination of the regulations would be bad for consumers. Second, that reciprocity provides a less onerous and less expensive alternative to state by state authorization for activities than was available when the regulation was first introduced in 2010. Third, that students in professional licensure programs should be made aware whether the program will lead to licensure where the student is located when taking the program.

Questions:

How should a state authorization reciprocity agreement definition address reciprocity member states following the standards of the reciprocity agreement versus enforcement of state laws?
What disclosures should be required of institutions and how should the disclosures be provided to students?

Definition of Asynchronous Courses

668.3; Academic year. Definitions (related to asynchronous coursework) (See page 14)

The Department proposed language intends to acknowledge asynchronous courses in a framework that clarifies or identifies an academic week and an academic year for the purposes of Title IV disbursement. The Department indicated that asynchronous coursework has been stated in the regulations for approximately ten years, but that a revised definition is needed to address that asynchronous coursework is not always structured with specific intervals in the same manner as synchronous coursework.

Several members of the committee expressed confusion over the proposed language and the Department’s attempt to create language compatible for all asynchronous modalities: correspondence, distance education, and direct assessment. A few committee members expressed the concern that the proposed language did not sufficiently address assessment.

Questions:

How should asynchronous coursework be defined and sufficiently address the different possible modalities?

Academic Programs Offered on a “Subscription” Basis

668.2 Definitions: Full-time student in a subscription-based program (See pages 7-8)
§668.2 Definitions: Subscription-based program (See page 10)
§668.34 Satisfactory academic progress (in a subscription-based program) (See pages 36-38)
668.34 Disbursing funds (in a subscription-based program) (See pages 45-46)

Subscription-based programs forego the usual quarter, semester, or tri-mester structure and allow a student to take a specified number of credits over a set time period for a fixed price…or some variation on that idea. The student is not confined to a specific time period to complete that coursework within that term. Not surprisingly, that model does not fit well with traditional financial aid disbursement schema. The Department is attempting to define a subscription-based program and the aid processes for students enrolled in one.

Question:

For those that offer subscription-based programs, you should study the proposed rules closely as they will have a significant impact on your operations. How would you improve what is being proposed?

“Clock Hour for Distance Ed” Definition, Plus “Academic Engagement” in All Distance Courses

600.2 Definitions: “clock hour” for distance education settings (see pages 1-2)
§600.2 Definitions: “academic engagement” in a distance education course (currently embedded in the “clock hour” definition)

Most institutions choose between the credit hour or clock hour to measure student learning and progress through a degree or certificate program. The clock hour has typically been used by practical programs, such as cosmetology or truck driving in which all (or most) of the learning is through direct instruction or hands-on experiences. Some clock hour programs are using a hybrid approach and it is possible that some (computer programming?) could be conducted completely at a distance. The clock hour definition previously did not include distance education courses. The proposed definition includes the definition of “academic engagement,” which has been previously used in calculations of financial aid refunds for students who have dropped out of distance courses without notifying the institution. Since the notion of “academic engagement” is used in multiple place, Russ asked the Department to pull it our as a separate definition.

Questions:

Does “fifty to sixty minutes in a 60-minute period of consecutive or non-consecutive academic engagement” work for defining a clock hour in a distance education course?
Are the activities in “academic engagement” still relevant whether in clock hour or credit hour settings: “attending a synchronous class, lecture, or recitation online; interacting with a faculty member or participating in an online discussion about academic matters; participating in interactive tutorials or computer-assisted instruction; or taking exams. Academic engagement does not include logging into an online class or tutorial without active participation or participating in academic counseling or advisement”? How might you improve them?

Academic Integrity for ALL Courses – Should Face-to-Face Courses Also Combat Cheating

602.17 Applications of standards in reaching an accrediting decision (academic integrity in courses requirements) (See page 13-14)

This proposed change focuses on the requirements that institutions assure that, “the same student who participates in and completes the course or program and receives the academic credit.” In other words, assure that students are not cheating on their exams, papers, or other academic work. The proposed change seems to expand this requirement to ALL instruction, not just distance and correspondence courses.

This proposed change has flown under the radar and you may want to pay attention. It was not discussed in the subcommittee, yet.

Questions:

Distance and correspondence education have lived with this wording. How would you improve the requirements? Note: we might not be able to change some of it because it is in statute and Congress would have to make the change.
What’s your thoughts on expanding it to all instruction?
What do they mean by an “electronic badge” as a way to verify student identity?

What’s Next? And Seeking Your Feedback

If you wish to learn more about negotiated rulemaking, we thank Higher Learning Advocates for providing a “101: Negotiated Rulemaking” summary of how the process works. The rulemaking process is slated to end by the end of March. The Department maintains a great web page with background documents, a list of negotiators, and links to recordings of the sessions.

The subcommittee meets again on February 11-12 and its final meeting is March 11-12. This will go by quickly.

We invite input either through responding to this blog post or direct communications with us. Understand that we’re getting lots of feedback and may not respond to you promptly or give you the proper thank you for taking the time to provide input. Thank you for doing so.

Russ Poulin
Senior Director – Policy, Analysis, and Strategic Alliances
WCET – The WICHE Cooperative for Educational Technologies
rpoulin@wiche.edu

Cheryl Dowd
Director – WCET State Authorization Network
WCET – The WICHE Cooperative for Educational Technologies
cdowd@wiche.edu

Accreditation, Competency-based Education, Distance Education, Negotiated Rulemaking, Reciprocity, U.S. Department of Education

Practice

Announcing the Report Reader Checklist: Your newest research resource

By Erin Noelle Walton

January 18, 2019

1 Comment

Today we’re excited to welcome Mary Ellen Dello Stritto and Kathryn Linder from the Oregon State University Ecampus Research Unit to introduce an excellent new resource: the Report Reader Checklist. This checklist is a set of criteria that can help guide report readers and evaluate online education.

Thank you to Mary Ellen and Katie for joining us to review this important resource. Congratulations on its release!

Enjoy the read and enjoy your day,

Lindsey Downs, WCET

The Oregon State University Ecampus Research Unit is excited to share a new resource we created to help a range of stakeholders make data-driven decisions. Our new Report Reader Checklist includes a comprehensive set of criteria that offers a guide for those who are reading reports to evaluate the quality and rigor of online education study reports that they may encounter in their work. The checklist features six focus areas:

context,
methodology,
sample,
reporting results,
transparency, and
reader experience.

Purposes of the Report Reader Checklist

The Report Reader Checklist was created to serve three main purposes:

The Report Reader Checklist serves as a guide for administrators and stakeholders in the field of online teaching and learning who need or want assistance with reading and understanding the results of various research reports.
The Report Reader Checklist empowers readers in the field of online teaching and learning to confidently identify the strengths and weaknesses of study reports as they make decisions and/or take specific actions based on study results.
The Report Reader Checklist can be used as a resource for increasing research literacy in the field of online teaching and learning.

The checklist is intended to provide an overview of the foundational elements that should be included when reporting the results of a study. Report readers can then apply each checklist criterion to a report to determine whether that element has been included or not. If readers find one area (e.g., “Context” or “Methodology”) that is missing several criteria within a report, this would indicate that a report is weaker in that particular area.

The Six Areas and the Criterion

The following contains an overview of the six areas of the checklist, along with the criterion in each area:

Context

Does the report describe the larger purpose of the study? Does it explain the history or theoretical framework? Does the report include research goals and suggestions for further research?

Methodology

Does the report have a methodology section? Is it clear how data were collected and analyzed? If the study used statistics, were they named? If coding was used, was the procedure described?

Sample

Are the study participants described in detail? Is it clear how participants were recruited? Does the sample represent an appropriate level of diversity? Are subgroups appropriately identified?

Reporting Results

Are all numbers in the report easy to comprehend? Is the “N” provided? Does the report identify missing data? Is it clear where study findings fit with the study’s purpose? Do data visualizations enhance your understanding of the results?

Transparency

Are raw data included in the report? Are instruments or study protocols provided in the report? Are the authors clear about any conflicts of interest? Is the discussion rooted in data results?

Reader Experience

Does the report use language that is easy to understand? Is the report ADA accessible? Does it include a summary or abstract? Is the study an appropriate length?

Download a one-page PDF of the checklist and access additional details for each criterion and our list of exemplar reports for each criterion.

Mary Ellen Dello Stritto
Assistant Director
Ecampus Research Unit, Oregon State University
maryellen.dellostritto@oregonstate.edu

Kathryn Linder
Director
Ecampus Research Unit, Oregon State University
kathryn.linder@oregonstate.edu

About the Oregon State University Ecampus Research Unit: The OSU Ecampus Research Unit makes research actionable through the creation of evidence-based resources related to effective online teaching, learning, and program administration. The OSU Ecampus Research Unit is part of Oregon State Ecampus, the university’s top-ranked online education provider.

Course Design, Distance Education, Faculty, Managing Digital Learning, Online Learning, Professional Development, Research

Practice

Congratulations! You are a Best Ranked School! But…

By Erin Noelle Walton

January 16, 2019

3 Comments

In the media and in communications to your PR staff, there will be lots of hype this week about ranking online programs. In the past, we have been critical of such rankings on the basis of the quality of their methodology and we let them respond to questions from WCET members. Subsequent discussions produced mixed results.

Thank you to Anna Porcaro, Wichita State University, for her guest post with a different take on sites that provide rankings or “best” designations for an institution or its programs. You may want to consider how your institution promotes these “honors.”

— Russ Poulin, WCET

Congratulations! Your school was just ranked in the top 25 by [best-x-degree.com].

Which Chief Marketing Officer wouldn’t welcome an earned-media opportunity like this? Just think about it: a no-cost option for you to market your specialized program! Especially since the established outlets that provide annual ratings rely on a team at your school to actively submit page after page of data, often in combination with publicly-available IPEDS data.

Earned-media is marketing that you don’t control, but mentions you, like a review, a positive blog or article about you, recommendations, etc.

However, by engaging with these third-party ranking sites that go by names like, “affordable” “best,” “top,” etc., you are actually working against your own interests.

As you have likely heard for years now, Google, Bing, Yahoo, Baidu, and other search sites have an algorithm that determines what pages come up in what order for any given search. What you may not know is that there is a process to get your website listed on top. This is called Search Engine Optimization (SEO).

Make Your Website SEO Friendly

When making your website SEO friendly, there are few items to address. The two most important are:

1) Page Authority: Your page authority is similar to your page’s reputation. Do other ranked sites that have been around for a while link to it and it does it link to other ranked sites?

2) Quality: Quality is indicated by the functionality of your pages. Does your site load quickly, does it have a lot of broken links, and is it filled with usable content that links to keywords in the body of your page that are words that rank high in searches, or do you have just pages of links?

Checking these two boxes will increase your web authority.

Benefits of SEO

The goal of your webpage is most likely to get your message out to your customers. It’s good to be able to get that message out without spending money on paid digital media channels like display or paid search. Making your pages SEO responsive is a way for your owned-media channels (Medium defines these as “web properties owned by the business”) to be connected to the place where many of your potential students’ eyes are: search engines. If you are using a modern Content Management System (CMS) on a good server, much of the speed and link issues can easily be tamed. It is up to your team to produce usable content that will keep eyes on your pages, reduce bounce-rates (or the rate of people leaving your site without engaging), and, therefore improve your quality scores.

Feeding to SEO Machine

If you have a quality site, and unless your university is brand new, your website should already have some authority, because as a university or college you are a known player on the open web. That means that your site is a target for people hoping to establish their authority by connecting with you. It isn’t just enough for them to come up with a click-bait type site (“Best online schools for x; #9 will amaze you!”) and link you to their site, you have to reciprocate. So how do they get you to do that? They not only rank you, but they try to entice you to accept their ranking as meaning enough for you to link back to them and in turn lend your authority to their site.

Remember, these “best schools” sites are not in the game of ranking schools. They exist for one reason: to get you to link to their site; to help them rise in authority. Why? Because once they have dominated the search market, they then can use that same authority to sell “sponsored” rankings. They have made something that on the surface looks like earned media and have turned it into paid media and they have marketed their wares for little to nothing. They aren’t doing so through the channels you are using, paid media, they are doing so through earned media and SEO. They also are using people to reach out to you via email or phone call and to get you to link to them.

Yes, you can be listed on their site, take their certificate and put it on your site, send the story through your PR machine and feed the earned-media machine, but in the meantime, you have pushed your own website out of the running to be seen on organic search rankings.

In other words, students learn about your programs or your school, not from you, but from one of these third-party sites. Then to be seen, you have to pay them so that students actually see you.

Searching for Our Site

One such “best” website that “congratulated” us on our high ranking recently had this type of design on their page for a specific graduate program:

Sponsored programs (called “Featured” with a tiny light blue “sponsored” disclaimer below them),
Description of the field and highlights of careers in that area,
Their ranking methodology (which was done very loosely by assigning points to student/faculty ratio, average price, and concentrations – not actually on the quality of the program or its alumni),
Top 15 programs listed in reverse order with a short blurb on each program.

In this description, you should see that they are playing the SEO game well.

They have created content (it’s not just links) that highlight valuable keywords,
They have fast loading times (no special scripts running to make it slow down, not a lot of large graphics, only logos from the schools), and,
The site has working links to credible sites.

What they don’t have is authority – that is what they want from us when we put their site through our PR processes or link to their site directly from ours.

The problem with these pages is evident when you go search for your school or program. What you may see is that your program is nowhere to be seen in a search. The first two pages of my own search for our “ranked” program was filled with “best this” and “affordable that.” Only one legitimate school came up organically.

By winning the SEO game, they have pushed you out, and in turn, your “highly ranked” program is so far down on their page that you aren’t likely to be really seen.

In the last two years, we have seen these sites dominate the organic search market for university programs. They are proliferating almost daily. We get several emails a month from these sites. Often, they’ll go to the non-PR/non-marketing team and then because they aren’t vetted properly, a program links to their website or put out a story, and soon they have fed the SEO machine.

The solution to take back organic search is to make sure your team is versed on the proper techniques for making your sites optimized for search. More importantly, we need to stop giving our authority and legitimacy to these sites. Save your earned-media opportunities for higher quality media outlets. If we stop linking to these sites, and schools stop paying to be sponsored, and we can own the organic search world again.

Anna Porcaro
Executive Director of Online Learning
Wichita State University
WCET Steering Committee member

Digital Learning, Distance Education, Managing Digital Learning, Marketing, Online Learning, Quality, Rankings, Technology