Author: Lindsey Downs

Now Is Our Moment: Six Takeaways from the 2025 Badge Summit

By Lindsey Downs

October 9, 2025

At WCET, we’re always inspired by the spaces where innovation in higher education moves from idea to action. From what we understand, the 2025 Badge Summit at the University of Colorado, Boulder, was exactly that kind of moment. What once may have felt like a specialized discussion about badges and digital credentials has grown into a shared movement shaping teaching and learning, and connecting learners with meaningful opportunities.

In this post, Noah Geisel, Microcredentials Program Manager with the Office of the Registrar at the University of Colorado Boulder, captures six takeaways from this year’s Summit that reflect where the field is headed next. These insights show how higher education can lead with clarity, collaboration, and purpose in this exciting new chapter of digital learning.

Enjoy the read,
Lindsey Downs, WCET

This July, nearly 300 people from five continents gathered for the tenth Badge Summit at the University of Colorado, Boulder. The energy felt different this year. It was tangibly less “interesting niche” and more “this is the future of how we’re going to do teaching, learning, and hiring.”

That shift showed up in little ways (more phones out snapping slides) and big ones (the Governor of Colorado speaking on our stage). Below are six takeaways that summarize trends I’m carrying forward – practical things higher ed can use as you design programs, advise learners, and partner with employers.

Badge Summit event graphic. 2025 Badge Summit @ CU Boulder. "it takes an ecosystem." July 21-23, 2025 Boulder, Colorado.

1) A Governor’s “why” matters, and it’s squarely about outcomes

Colorado Governor Jared Polis helped set and validate the tone of the Badge Summit by focusing on the value of credentials, rather than hype. His message is that short-term, trusted, and verifiable credentials should lead to real opportunities, real wage gains, and real upward mobility. The key to these bold aspirations becoming very achievable realities will be employers’ enthusiasm for co-designing credentials and employers’ willingness to meaningfully consume what we issue. As he put it, we don’t need credentials that “don’t mean anything” to hiring managers.

This proactive, collaborative industry role will be a huge shift for many, though hopefully a welcome one. Recent UPCEA research reports that a majority of employers want to be invited to co-create credentials, suggesting there is an existing appetite on the industry side. This is encouraging for campus leaders tasked with establishing these industry relationships.

The shifting expectations suggested by Governor Polis are not limited to industry. For higher ed, the implication is clear: anchor every microcredential in transparent outcomes and employer use, not just course completion. Best practices of credential transparency were a persistent theme throughout the Badge Summit.

2) Speak plainly (or slow your own progress)

A recurring theme across sessions and hallways: we’ve been self-defeating with jargon. If a credential takes three acronyms and a vocabulary lesson to explain, adoption stalls. The fix is not dumbing down, it is translating. What this movement aspires to do is simple: recognize people’s assets in order to better connect them with opportunities. And yet, our explanations tend to complicate things and slow our progress.

When we frame credentials as evidence of specific, verified skills that employers recognize and can act on, people lean in. Multiple conference conversations suggested that we all need one sentence that learners can repeat to a parent, advisor, or supervisor without losing the thread. For example, Keying Chen of Digital Promise shared that a participant in their session described LERs (Learning and Employment Records) as existing “for people’s unseen superpowers to be seen.”

If you don’t have your single sentence yet, that’s the work. Fortunately, practitioners in the Badge Summit, WCET, UPCEA, AACRAO, and other communities are ready to join your support groups and help with that work!

3) LER readiness is accelerating, design like your audience is listening

In past years, some of the most crucial ideas surrounding the LER Ecosystem drew polite curiosity at Badge Summit. This year, the same concepts were being photographed and live translated into campus “to-do” lists. That tells me two things:

Awareness is up. The 2025 Badge Summit was the first in which I didn’t hear a single “We don’t need no stinking badges!” movie quote from Blazing Saddles. People (at least roughly) know what LERs and the things making up the LER Ecosystem are, and they (at least roughly) understand why these things matter. As recently as last year, that was not the case. It demonstrates massive progress and, like the ground vibrations ahead of a stampede, suggests acceleration is coming. Attendees observed that what had been a somewhat sparse and lonely place is now feeling tangible density.
The bar is higher. Stakeholders are moving past “what is it?” to “how do we implement with intention?” If you’ve been waiting for a greener field on which to play, it’s here (Getting Smart’s Mason Pashia posted a great conference recap that covers myriad specific initiatives and technology implementations). The Summit’s sessions reflect an ongoing pivot from theory to practice, including an on-site T3 Innovation Network Mid-Year Meeting to dig into the essential next step after digital credentials are earned and issued: consuming those credentials at scale.

4) Move from learner agency to learner responsibility, and design for pride

We talk a lot about “empowering learners.” This year, I heard (and tried to model) the next step: earner responsibility. That entails:

Earners know what credential signals are and where they fit in their personal story.
They expect (and are expected) to do something with it—share it, explain it, and apply it.
Earners access systems that make it easy, predictable, and rewarding to act on their responsibilities.

Michal Nowakowski, whose team at the Educational Research Institute is leading Poland’s national micro-credentials effort, provided a Badge Summit highlight with a provocative design question for campuses: “Will a learner feel proud to show this to someone who matters?”

If the answer is “maybe,” keep iterating. Pride isn’t vanity; it’s a proxy for clarity and relevance, which can be a top signal that we’re doing things right.

5) The LER ecosystem has begun clicking – because it’s interconnected

A few years ago, the prevailing mental model for many higher ed constituents was “create → issue → (maybe) monetize.” There is an emerging appreciation for a broader model of an ecosystem that recognizes credential earning and issuing as being parts of a larger whole. This awareness is huge, as disparate and isolated acts are unhealthy to an ecosystem.

For the first time, this year’s Badge Summit witnessed mainstream notions that the LER ecosystem features more stakeholders, and that each has interconnected and interdependent roles in relation to the others. An (overly simplified summary) of the trending understanding of what this ecosystem needs and how it functions:

Opportunity providers (employers) transparently communicate skills needs.
Learning providers (like post-secondary institutions) create programming for people to acquire skills and, importantly, validate when skills are acquired.
Opportunity providers and learning providers issue credentials for skills that are verifiable, trusted, and explicit about what each credential is credentialing.
Learners actively use their credentials after earning them.
Opportunity providers implement technology systems to meaningfully consume credentials, allowing themselves to efficiently, effectively, and equitably match talent and opportunity on a scale.

Versions of this emerging understanding were evident in mainstage plenaries, breakout sessions, tool demonstrations, hallway conversations, and hands-on sessions. For a snapshot, I recommend Lisa Young’s brilliant recap of the first-ever “LER Petting Zoo” activation, in which attendees experienced the process of actually earning and operationalizing digital credentials.

6) What “all learning counts” can mean for higher ed

“All learning counts” was a frequent refrain. For institutions, that’s not a slogan; it’s an operational choice. Four questions to pressure-test your readiness for the provocations that were already percolating at Badge Summit:

Admissions & placement: Can verified prior learning actually move students faster, cheaper, and further?
Advising, Student Success, & Career Services: Do staff members have playbooks for helping students use credentials (transfer, PLA, scholarships, internships, jobs, tutoring, mentorship, gap analysis, etc.) to better understand themselves, identify possible futures, and access opportunities?
Programs & partnerships: Are employer-validated outcomes built in (and refreshed) at the program level?
Recognition of the formative: What are the opportunities to go beyond summative credentialing and also utilize recognition of formative learning and achievement?
Formal recognition beyond the curriculum: In this moment of degrees facing global challenges, how might the institution validate and recognize meaningful college experiences that both tell individuals’ stories and highlight the value of post-secondary attainment?

A closing nudge

Ten years is a long time in the life of a conference. And for a conference rooted in the power of recognition and storytelling, there was a consistent narrative that recognized the practitioners in this space as passionate changemakers who share a profound and audacious belief that they are part of an important movement underway to make the world a better place. While the precise image of our future remains blurred, conference attendees seem confident in a vision of what the impact can be.

More concretely, the message I’m taking forward from the trends at this year’s Badge Summit is simple: clarity beats cleverness, and value beats volume. When credentials are built with employer input, readable by design, and compelling enough that learners are proud to share them, everyone wins. Especially the people our systems haven’t served well enough and long enough.

If this resonates, I invite you to join us next year, from July 13 – 15, in Boulder, Colorado!

Credentials, Digital Learning, Distance Education, Managing Digital Learning

Practice

How Not to “Bowl Alone”

By Lindsey Downs

October 2, 2025

I’ve been thinking a lot about community lately. A few months ago, I was catching up with my Netflix on a flight home, and I watched the documentary “Join or Die.” It’s about political scientist Robert Putnam’s Bowling Alone. This seminal piece argues that in the 1960s and 1970s, Americans began to move away from joining communities and focused more on independent pursuits. One of the things that I hear a lot as I’m out talking to folks is a sense of isolation and loneliness right now. A desire and a need for community as higher education faces unprecedented challenges. I know I feel it. It’s so easy to focus on each crisis and become wrapped up in trying to keep up with each and every technological shift that AI is generating right now.

Thirty-nine years ago, WCET was created as the WICHE Cooperative for Educational Technologies. That word cooperative is a core part of our DNA. Cooperatives are communities that help each other. In fact, there’s a long history of cooperatives in the United States. The first cooperative was founded in 1752 by Benjamin Franklin: the Philadelphia Contributorship for Insurance of Houses from Loss by Fire. This model of mutual aid organizations grew in the 19th and 20th centuries, as Americans sought to find ways to help one another through groups built on democratic principles and mutual assistance. At the heart of these co-ops is the belief that we are stronger together.

When WCET was founded, digital learning was in its infancy. Distance education through correspondence had been around for decades, but technology created new opportunities that expanded access to a greater number of learners. WCET’s parent organization, WICHE, the Western Interstate Commission for Higher Education, recognized that digital learning could only advance through the cooperative efforts of institutions and states. And although WCET was originally meant to be an organization for the Western WICHE states, it soon expanded to states across the United States and Canadian territories.

Today, cooperative and community are two of WCET’s core values. We believe that we are stronger together and are committed to facilitating and developing a community of digital learning leaders and practitioners who can support each other through sharing information, resources, and practices. We embrace many of the historical co-op values, including:

Voluntary and open membership,
Member input and involvement,
The importance of education and information dissemination,
Cooperation and collaboration,
Strength through joint problem-solving,
Concern for our community.

Later this month, we will be celebrating our 37th annual meeting in Denver, taking place on October 21-23. Our annual meeting is an opportunity for folks to come together and learn about the best practices and policies that are impacting digital learning. But more than that, it’s an opportunity for community. Now, more than ever, we need to support one another. We cannot do our work in isolation. We need community. We need cooperation. We invite you to join us as we explore:

the impact of artificial intelligence on digital learning,
accessibility,
best practices in digital learning, and
the regulatory landscape.

We invite you to join with your colleagues to explore opportunities to collaborate and commiserate, yes, but also to create a community of support that will outlast those three days in Denver (have you checked out wcetDISCUSS lately?).

So, join us in Denver as we work together to expand access to high-quality learning opportunities for all students. Join us as we continue to create a community of practitioners and leaders, reminding each other that we don’t have to “bowl alone.” Your work matters as we collectively impact tens of thousands of students. Share your experiences, questions, and concerns with a community that will support you in this critical moment for higher education and digital learning.

This post was written by Van Davis

Collaboration/Community, Online Learning, WCET, WCET Annual Conference

Policy

SAN Releases a New “How To” Handbook to Build an Institution’s State-to-State Authorization Plan

By Lindsey Downs

September 18, 2025

The State Authorization Network (SAN) is excited to share SAN’s newest comprehensive resource, the State-to-State Institutional Approval for Distance Education Handbook, developed in partnership with Shari Miller, Institutional Compliance MATTERS. This handbook is the third major SAN report designed to demystify complex compliance requirements when institutions offer interstate opportunities, whether through online courses or experiential learning. All three major reports align with SAN’s concise one-pagers and charts available in the Getting Started with Compliance Management Gateway on the SAN website, so institution teams can develop practical action

The other important SAN reports include:

The Evolution of Compliance for State Authorization of Distance Education, By Sharyl Thompson (2023).
Professional Licensure Requirements Handbook 2nd edition (2024).

The newest report, State to State Institutional Approval for Distance Education Handbook, walks institutional teams through building a practical compliance plan to obtain any required state approvals to serve students located in other states.

Cover of the State-to-State Institutional approval in the DE handbook.

Who it’s for: Institutions operating outside of reciprocity policy provided through the State Authorization Reciprocity Agreements (SARA).
Why now? The project was prioritized to support SAN’s ~200 California member institutions, since California is not a SARA member state.
Helpful even if the institution participates in SARA: SARA-participating institutions will gain a deeper understanding of state-to-state nuances and the sometimes-dense nature of authorization, even when much of their out-of-state activities are authorized through the policies of the reciprocity agreement.

Today on Frontiers, we are pleased to welcome back Shari Miller to share a concise summary of the handbook and the compliance road it maps.

Shari is a long-time colleague and friend of SAN. She led state authorization work before and after the development of reciprocity through SARA at the institutional level. Shari now consults with a wide range of institutions, including those not participating in SARA, on authorization strategy, operations, and documentation. Shari also authored SAN’s Professional Licensure Requirements Handbook (1st and 2nd editions), mentored cohorts in SAN’s Basics Workshop for many years, and is a frequent SAN presenter and contributor. You’ll find her full bio at the end of this post.

Get the Handbook and Put it to Work

Download it: State-to-State Institutional Approval for Distance Education Handbook
Pair it with: Getting Started with Compliance Management Gateway one-pagers & charts
Share it with: Compliance leads, legal counsel, academic affairs, licensure coordinators, online learning leaders

A big thank you to Shari for developing this thorough handbook to support institutions in managing state authorization of distance education and for sharing the following overview today on Frontiers.

Overview of the New State-to-State Institutional Approval for Distance Education Handbook

From my experience in regulatory work, such as state authorization, I have found that practical information and guidance are the most helpful. When I started working in state authorization and higher education regulatory compliance (before SAN and SARA), I had a wonderful mentor who shared very valuable information in a concise manner. This handbook is intended to

encapsulate the knowledge that I have gained from working and collaborating with so many in this area, and,
to provide step-by-step processes for “doing” state authorization outside of SARA.

The handbook addresses the practical aspects of seeking and applying for approval to offer educational activities and operate as an institution of higher education in another state outside of the institution’s home or domiciliary state. To be successful in this complicated area of regulatory compliance, it takes an institutional “village.”

Using the Handbook

The handbook is segmented into Part I. Foundational Elements, which covers the why part of compliance (both on the part of the regulatory agencies and the institutions), who (as in the triad), what if we don’t (consequences for noncompliance), and the distinction between program approval and state institutional approval. Part one also includes a discussion on required student location/relocation policies for institutional compliance.

Part II, the Development of Institutional Processes to Research, Analyze, Communicate, and Maintain Information, includes two sections. The first section covers institutional research, which provides a roadmap of how to start, who to involve, and how to manage the process. It also has suggestions on types of data to compile for easy access (and where to store it). The second section of Part II. covers state regulatory agency research and strategies for conducting it, recording the data, analyzing the institutional data versus the regulatory agency requirements, plus communication guidance.

Due to the density of the content, we have added graphics and text boxes to highlight critical information throughout the document. The handbook is designed to be a resource that you can print and refer to as needed or use the digital version. After the conclusion are five appendices of useful resources, including possible documentation requirements, draft templates, checklists, tips, and general state authorization resources.

As a general reminder to all institutions, in addition to having obtained authorization to provide educational services in states in which institutions are not legally domiciled, as detailed in the handbook, institutions must also be in compliance with the applicable federal rules and state requirements. These include Title IV certification via the Program Participation Agreement required under the Higher Education Act, reciprocity (where applicable), state professional licensure requirements, such as those covering program and curriculum approval to satisfy state educational requirements (where required), and other applicable general laws. Also, remember that the threshold for compliance with state authorization requirements is ONE student. SAN is a great resource for these issues.

Thank you to Cheryl and the rest of the SAN team for the opportunity to collaborate on another SAN resource!

Conclusion from Cheryl Dowd

As Shari explains in the handbook, the steps for compliance and determining the location of students are complicated and require a coordinated and cross-institutional effort. Compliance isn’t just a legal or administrative function; it involves contributions from faculty, financial aid, registrars, admissions, instructional designers, and more. This handbook provides a roadmap to help each of these stakeholders understand their role in building a comprehensive state authorization plan.

SAN Major Reports:

State-to-State Institutional Approval for Distance Education Handbook(2025)

The Evolution of Compliance for State Authorization of Distance Education(2023)

Professional Licensure Requirements Handbook 2nd edition (2024)

Alongside this new report, you’ll find a wide range of resources on the SAN website, including charts, papers, and examples of best practices, to support compliance for interstate distance education. We also encourage you to explore our professional licensure resources, as well as newer materials that address interstate employment law responsibilities and global compliance.

Looking ahead, before the close of 2025, SAN will publish more important resources:

A fourth major SAN report, which will summarize an intensive study on how institutions are implementing professional licensure requirements.
The third edition of State Authorization of Colleges and Universities: A Handbook for Institutions and Agencies will be available on Amazon.

For those unfamiliar with the State Authorization Network, SAN was created in 2011 as an additional membership group by WCET (the WICHE Cooperative for Educational Technologies) in response to emerging federal regulations requiring institutions to meet state authorization requirements for distance education.

SAN was designed to provide institutions with resources, training, and a collaborative community to navigate the complex landscape of state and federal compliance. SAN operates within WCET’s broader mission of advancing digital learning in higher education, focusing specifically on the regulatory and authorization challenges that impact institutions and the students they serve.

Institutions or organizations interested in joining SAN can visit the SAN Membership webpage for details or connect directly with SAN staff at san-info@wiche.edu to see how membership can support your compliance journey. SAN is here to help with your compliance needs!

This post was written by Shari Miller and Cheryl Dowd

Distance Education, Reciprocity, Regulation, SAN, State Authorization, State Authorization Network, Student Success

Practice

Cutting through the Framework Fog

By Lindsey Downs

September 11, 2025

It comes as no surprise that Artificial intelligence (AI) is reshaping higher education. Much of what is emerging from the field relates to AI, whether it is news about technological advancements or questions about how we should use it.

Alongside these, a wave of AI literacy frameworks has emerged, each offering its own definitions, competencies, perspectives, and guidance on the use of AI in higher ed.

In today’s post, our guest authors, Angela Gunder and Claire Renaud, unpack what this fog means for institutions and how to cut through the haze to move past confusion and build strategies that best serve their communities. Thank you both for this post.

Enjoy the read,
Lindsey Downs, Editor, WCET Frontiers

Since artificial intelligence (AI) burst onto the scene a couple of years ago, higher education institutions, along with many other organizations, have been grappling with which generative AI tools to adopt and what guidance to provide for their use. In particular, there has been a rapid proliferation of AI literacy frameworks seeking to elucidate which practices are needed for faculty, staff, administrators, and learners to use AI within educational contexts. Each framework brings its own set of definitions, competencies, and guiding perspectives. On the one hand, this multitude of frameworks indicates that organizations recognize the importance of understanding how Generative AI, and AI more broadly, impacts their work. On the other hand, for anyone looking for a starting point, the sheer number of frameworks has created a state where countless individuals and institutions are feeling overwhelmed by choice, what WCET’s AI Working Group calls a “framework fog.”

What is the framework fog?

Why a fog? With framework after framework appearing on the horizon, yet no one clearly stands out to guide the way, it can feel as if a heavy fog has settled in. Just as fog obscures surroundings and makes it hard to see barriers or landmarks, the framework fog overwhelms with too many perspectives and choices. For those who want to build on what already exists rather than start from scratch, this creates confusion and discouragement, leaving them unsure of which direction to take. In other words, they may feel stranded on the side of the road, uncertain where to take the first step.

The problem deepens when frameworks define literacy differently. Too often, literacy is treated as a simple on/off switch: either “literate” or “illiterate,” “ready” or “not ready.” While easy to grasp, this framing ignores the social and organizational contexts in which tools are used. It oversimplifies the complexity of how people in specific roles, within unique institutional cultures, actually engage with AI. And sadly, this binary has been used historically to marginalize populations of learners, dictating who has the ability to become literate and who does not.

A grounded approach is to think in terms of AI literacies-plural. AI literacies are not a final destination but an evolving set of practices that shift with role, context, and culture. What works in one environment may be a poor fit, or even counterproductive, in another. And as AI continues to evolve, along with our perspectives on it and our actions related to it, a pluralistic approach to AI literacies allows us to keep pace with the rapid changes in AI and how it is impactfully and ethically used in educational contexts. As AI adapts, our literacies also adapt, allowing us to move forward rather than remaining fixed in place, and ultimately left behind.

Cutting through the fog

When you’re standing in a dense fog, you don’t wait for it to lift completely before moving forward. You find your bearings, lean on what you know, and take intentional and deliberate steps forward into the unknown.

The same applies here: you don’t need to find the perfect framework before acting. In fact, finding one framework to rule over all others is an impossible task. Instead, you must use your organization’s values, culture, and needs as your guide.

Here are some practical ways to cut through the framework fog:

Turn on your headlights: Just as headlights reveal the road immediately ahead, begin by clarifying your immediate context. Examine your institution’s mission, values, culture, and most pressing needs around AI, as well as where you have strengths that can be applied. These act as your headlights, illuminating which aspects of any framework will actually serve your community and which you can safely ignore.
Use a compass, not a map: In thick fog, even the best map is hard to follow; you can’t see the landmarks it references. A compass, however, always points true north. Let your institutional values serve as that compass, guiding you to select and adapt elements from multiple frameworks rather than following any single one completely. Review what’s available, remix the elements that align with your direction, and leave behind anything that leads off course.
Travel in convoy: Navigating fog alone is risky, other drivers may spot obstacles you miss. Form a diverse group including faculty, staff, administrators, and students. Their perspectives will help you see through different patches of fog at once.

By approaching existing frameworks this way, you can begin to construct an AI literacies framework that genuinely supports your community over time, rather than trying to shoehorn your context into a one-size-fits-all model that won’t grow towards the vision and mission of your institution.

Conclusion

The framework fog isn’t going away overnight. But that doesn’t mean we have to be lost in it. WCET will soon share a report that evaluates existing AI literacies frameworks, offering practical guidance for remixing to your distinct institutional contexts. The report highlights how each framework, each one openly licensed and available for adaptation and re-contextualization, aligns to the three dimensions of the WCET AI Policy and Practice framework (Governance, Operations, and Pedagogy), and recognizes that a holistic approach to institutional strategy for AI is necessary to maintain impact over time, and to ensure that AI benefits rather than disadvantages those it seeks to serve. In addition to the WCET Report on AI literacies frameworks, a more detailed toolkit will follow for WCET members, offering insights into how to apply the findings of the report across different contexts and roles. Together, these resources will provide guideposts to help institutions navigate through the framework fog and chart a course that fits their unique landscape, leading them to their intended destinations with confidence and clarity.

This post was written by Angela Gunder and Claire Renaud

Artificial Intelligence, Distance Education, Managing Digital Learning, Online Learning, Student Success, WCET

Practice

WCET Featured Member: Arizona State University

By Lindsey Downs

September 9, 2025

Introducing WCET’s New Featured Member Series

At WCET, our focus is on our community. Every day, our members lead the way in digital learning: innovating, problem-solving, and sharing strategies that shape the future of higher education. To celebrate and spotlight this work, we’re excited to launch a new monthly Featured Member series on WCET Frontiers.

Each month, we’ll highlight one of our member institutions or organizations, giving you a chance to learn more about their mission, current digital learning initiatives, the challenges they’ve faced, and what lies ahead. Each article will include an introduction to the institution or organization and the institution’s responses to a short interview. We hope this series not only shines a light on the incredible work being done out there in the field, but also sparks ideas, connections, and collaborations.

For our first feature, we’re thrilled to spotlight Arizona State University, a long-standing WCET member recognized nationally for its innovation, scale, and impact. We are grateful to ASU for sharing their story with us and kicking off this new series.

Lindsey Downs,
Editor, WCET Frontiers

Institution Snapshot
Institution: Arizona State University
Location: Tempe, Arizona
Student Population: 180,000+ learners (campus + online)
Fun Fact: ASU researchers designed the cameras for NASA’s Mars rovers, so the Sun Devils have literally helped us see the Red Planet.

About ASU

Arizona State University (ASU) is a leading public research university recognized for its innovation, access, and impact. With more than 180,000 students enrolled across campuses in the Phoenix metropolitan area and through ASU Online, it is one of the largest and most diverse universities in the United States. ASU is known for pioneering new models of teaching, learning, and discovery.

ASU’s Charter is to measure itself not by whom it excludes, but by whom it includes and how they succeed. The university is:

dedicated to advancing student success,
fostering research that addresses the world’s most pressing challenges, and,
engaging with communities to drive positive societal impact.

Why is digital learning important to your institution?

Digital learning is central to Arizona State University’s mission of access, excellence, and innovation. As one of the largest public universities in the nation, ASU is committed to serving learners at every stage of life — from traditional undergraduates to working professionals and lifelong learners. Through digital learning, ASU is able to remove barriers of geography, cost, and time. It enables us to meet learners where they are, offering flexible pathways that align with their personal and professional goals. Digital platforms are also integrating adaptive technologies, data-driven insights, and personalized experiences that enhance student success. By embracing digital learning, ASU not only expands its reach but also fulfills its charter commitment: to serve all learners and to advance the economic, social, cultural, and overall health of the communities it impacts.

What challenges have you faced in digital learning, and how did you address them?

One of the key challenges ASU has faced in digital learning is ensuring that access translates into success. Expanding opportunity through online and hybrid education requires more than simply scaling courses — it demands maintaining academic quality, supporting diverse learners, and addressing issues of equity in technology access.

ASU has addressed this by investing in robust student support systems tailored for digital learners, including 24/7 tutoring, success coaches, and accessible course design. We’ve also prioritized inclusive technology practices to make sure all students, regardless of background or circumstance, have the tools they need to succeed.

Another challenge has been preparing faculty to teach effectively in digital environments. To meet this, ASU created professional development programs, collaborative design teams, and faculty innovation centers that provide ongoing training and support for digital pedagogy.

By approaching these challenges with innovation and intentionality, ASU has built a model of digital learning that not only increases access but also fosters meaningful student success outcomes at scale.

Looking ahead, what trends or initiatives are shaping your digital learning plans?

At Arizona State University, the future of digital learning is shaped by our commitment to scale, innovation, and student success. We are expanding access to high-quality education globally, using technology to serve learners not just in Arizona, but around the world. Key initiatives include scaling personalized learning through adaptive technologies, integrating generative AI to enhance teaching and support, and expanding stackable, flexible credentials that meet workforce needs. We are also investing in immersive learning environments, such as virtual reality and simulations, to create more engaging and applied learning experiences.

By operating at scale, ASU is not only increasing the number of learners served but also reimagining how digital learning can drive equitable access, career readiness, and lifelong learning pathways on a global level.

Why WCET?

Arizona State University is a proud WCET member and values the opportunity to connect with peers across higher education to share strategies, explore innovations, and collectively advance digital learning.

Thank You!

Thank you to Arizona State University for sharing your story with WCET Frontiers! Stay tuned for next month’s Featured Member, and if you’d like your institution to be highlighted, reach out to the WCET team.

WCET, WCET Member Feature

Practice

WCET’s Accessibility Project: Progress, but Not yet Perfection

By Lindsey Downs

September 4, 2025

Illustration of an accessibility checklist, with accessibility icons

WCET has always taken accessibility seriously. When we updated our website in 2021, we worked diligently to ensure that all content, including PDFs, adhered to the Web Content Accessibility Guidelines (WCAG) 2.0, AA standards. We worked with WebAIM a few years after the website’s launch to ensure that our web-based content still complied with those standards.

Then, in June 2024, the Department of Justice issued their final rule revising the regulation implementing Title II of the Americans with Disabilities Act (ADA). The revised rule specifically focused on web content, social media, and mobile apps. The rule also stated that at a minimum, organizations needed to comply with the WCAG 2.1 Level AA success criteria and conformance requirements (including for captioning). The timeline for compliance seemed reasonable:

Large entities, those institutions serving a total population of 50,000 or more, must comply by April 24, 2026.
Small entities, those institutions serving a total population of less than 50,000, must comply by April 26, 2027.

Read our other accessibility posts for additional background:

WCET is a small organization with a lean but mighty staff. We are also part of a larger organization, WICHE, the Western Interstate Commission for Higher Education. WICHE is a regional compact that serves the 15 western states and the U.S. Pacific Territories and Freely Associated States. This qualified us as a large entity with a deadline of April 2026.

To further complicate matters, WCET has three distinct networks: Membership, the State Authorization Network (SAN), and Every Learner Everywhere (Every Learner). Each network has its own website and social media presence.

It became apparent very quickly that we needed to work collaboratively in order to:

Streamline efforts,
Learn best practices,
Explore solutions,
Ensure that content linked on more than one website was remediated and connected appropriately.

Like many of our members, we were trying to figure out how best to manage this important aspect of accessibility, not just to meet the DOJ deadline, but also to improve our content for everyone.

Our Process

In the fall of 2024, SAN, Every Learner Everywhere, and WCET began meeting monthly to start addressing this challenge. We needed additional time to discuss our process, so we switched to a biweekly meeting schedule in the spring of 2025. Each network has two people participating in the meetings. In addition to these meetings, we created a Slack channel for sending reminders, asking questions, and sharing information.

The first meetings were important because they allowed us to understand the scope of work ahead for each of our units. We could also allocate funding to help with remediation because we were ahead of the budget cycle. The early meetings were also overwhelming because we realized the volume of content that was going to need remediation, including:

PDFs that passed the Adobe PDF checker but did not meet WCAG 2.1 AA standards.
YouTube videos that had captions, but not audio descriptions.
Webpages that needed to be archived.
Links to highly inaccessible websites.

Once we fully understood the volume of work ahead, we rolled up our sleeves and began managing our parallel efforts. Each of the three networks managed its process slightly differently, but there were (are) four critical steps in the overall process.

Step 1: Inventory Content

It was essential to determine the quantity of content we had and how much of it would require review for accessibility.

Digital Materials

Illustration of a checklist with accessibility icons

For our created content, mostly hosted on our websites, we exported a list of media files, including file names, web links to the media, and publication dates. This did not include YouTube videos.

Once we had this information exported to a spreadsheet, we overlaid it with Google Analytics to see the content with the most views. This made it easier to identify which resources could be easily moved to an archive page or deleted. If a resource was older than 10 years and had very few views, it was clear we didn’t need to remediate it.

The most recent and most viewed resources were marked for review and remediation. The content between the two groups needed a staff member to review one-on-one and make recommendations.

Video Content

Almost all of our video content is hosted on our YouTube channels. We used a similar process to the one above to select and prioritize videos for remediation, based on view counts and dates.

In step 1, the biggest lift was reviewing resources, specifically PDFs, that were published within the past ten years and/or had an average number of views.

Step 2: Help! We need help!

Once each of the networks had a handle on the volume of web content that required review and remediation (over 500 pages of PDFs, and 100+ YouTube videos), we realized that we did not have the capacity or expertise to fix all of our PDFs, add audio descriptions to our YouTube videos, and caption plus transcribe all of those videos.

We explored several different companies to help. This was a very time-consuming process, and I would like to acknowledge Patricia O’Sullivan, Associate Director of Strategy Execution at Every Learner Everywhere, who did much of the legwork in researching, interviewing, and selecting our vendor partners. Ultimately, we landed on Be Accessible to help with PDF remediation and 3Play Media for Audio Descriptions.

Step 3: Out with the old, in with the new

This step is ongoing. For the PDFs, we have uploaded the files that need to be reviewed and/or updated to meet WCAG 2.1 AA standards to our vendor, Be Accessible. Their staff is currently working on remediation. As we receive the updated files, we will swap them out with the outdated files across our websites. All networks will need to communicate with each other, as a PDF may be located on one or two different websites. For example, if SAN has an updated resource and WCET points to it on a webpage, we need to double-check that the link still connects correctly.

The networks are finishing up sharing our video content with 3Play Media. The staff will provide audio descriptions, as well as captioning and transcriptions, as needed. Once the videos are complete, we or 3Play Media will make sure our YouTube channel has the finished content. Every Learner, which has embedded videos on its website, will take an additional step of embedding the new code on their webpages.

In the meantime, we will begin to move content that we do not plan to remediate to a new archive page or, in some cases, delete it entirely. We are working with a web designer on a new webpage for archiving older resources that should be retained. If we receive a request to create accessible versions of any of these archived resources, we will remediate the file.

Step 4: Juggling another ball at the same time – making sure that new content is accessible from the beginning

A young woman in a clown outfit juggling

As all of this work is underway, and we find ourselves seven months from the DOJ deadline, we continue to generate a substantial amount of web-based content. Each network posts PDFs of reports, resources, and toolkits, and shares new videos on a weekly basis.

Simultaneously with our remediation efforts, we must ensure that our new content meets or exceeds WCAG 2.1 AA standards. We are using the PAC PDF checker and working with consultants who are knowledgeable about the standards when editing, formatting, and designing our content. Additionally, we will continue to work with 3Play Media to provide audio descriptions, transcripts, and captions for our videos.

Focus on Progress and Work Toward Perfection

The process has been a great experience. It was incredibly daunting at the start, but it has been wonderful to collaborate and learn across the networks. We will continue to keep you posted on our journey and provide a follow-up blog post about what we learned along the way. If I have any advice, it’s to just get started with the content that is most often accessed. It can feel overwhelming to aim for perfection by April 2026, but the key right now is to focus on making consistent progress.

WCET members join us in MIX, our online community platform, where we now host the WCET Accessibility Exchange (WAE). In this group, we provide tips and resources every month, and you are welcome to ask questions and engage in conversations with other members. Join us! This month, we will be sharing an accessibility focused, member-only fact sheet, and I will be leading this month’s Closer Conversation on September 26, WCET’s Accessibility Project: Progress, but Not Perfection.

This post was written by Megan Raymond

Accessibility, Department of Education, Digital Learning, Distance Education, Managing Digital Learning, Online Learning, Regulation, Student Success, WCET

Practice

Breaking Down Walls

By Lindsey Downs

August 28, 2025

President George Bush sitting at a table on a lawn, surrounded by two individuals in wheelchairs and two others. Bush is signing something on the table.

Imagine a student who relies on a screen reader to navigate their course or descriptive audio to better understand and follow video recordings. For that student, accessibility is a necessity. Thirty-five years ago, America made a commitment to that student when President George H.W. Bush signed the Americans with Disabilities Act (ADA) on a hot July 26, 1990, summer day.

That July day changed the lives of millions of Americans and continues to do so today for the 46.8 million Americans with disabilities. What started as a struggle for access to physical spaces continues to play out in the digital realm, but the goal remains the same: making sure that all people can fully participate in the richness of life.

In June 2024, the Department of Justice released new Title II regulations meant to update the regulations associated with the ADA to address digital media. Those regulations require public entities to comply with the WCAG 2.1 AA standards for all digital content, with very limited exceptions. WCET has written extensively about these new regulations, beginning with our August 2, 2024, blog, Accessibility in the Spotlight: Department of Justice Regulations, where Judith Sebesta and I explain the new regulations along with the very limited exceptions to those regulations, and through other posts exploring accessibility. Most public institutions are expected to comply by April 24, 2026. Compliance, though, is about more than making a deadline; it’s about making sure students, faculty, staff, and the general public have equitable access to an institution’s digital resources.

Last year, we also surveyed digital learning and accessibility leaders on how the implementation of the new Title II regulations was going on their campuses. At that time, only 61% reported that their campus had begun to address compliance. Respondents indicated that they faced numerous challenges, chiefly a lack of staff and working with third-party vendors to ascertain their compliance. Only 56% reported that they were only in the initial planning phase.

WCET understands these challenges firsthand. As a part of the Western Interstate Commission for Higher Education (WICHE), we are considered a public entity and must come into compliance by April 24, 2026. This means we are actively in the process of making our digital content accessible, including remediating PDFs, creating accurate webinar transcripts, and ensuring our videos have descriptive audio where necessary. As we progress in our own accessibility journey, we will continue to be transparent and share the lessons we are learning.

This month, we’ll be focusing much of our work on accessibility, providing you with resources you can use to address the new Title II regulations. These resources include:

A long, winding road leading around a mountain

Blog posts, including a blog detailing WCET’s own accessibility journey,
A member-only checklist to help you navigate the WCAG 2.1AA accessibility standards,
A Closer Conversation, where you can share your own experiences and questions with other members,
A pre-conference workshop at WCET 2025, “Cultivating Accessibility: Ensuring Compliance and Fostering Inclusion in Higher Education,” along with many other accessibility-focused keynotes and sessions (check out the program and register here),
WCET’s MIX Accessibility Community, the WCET Accessibility Exchange (WAE), where members can ask questions and learn from their peers,
WCET’s Accessibility Practice page, where you can find a compendium of our public and private accessibility resources.

I want to take us back to that July 1990 summer day. The signing of the Americans with Disabilities Act was a major civil rights victory, but the fight goes on. Now, many of our students, faculty, and staff face digital barriers such as unreadable documents and websites or videos without captions and descriptive audio.

As President George Herbert Walker Bush said on that July 1990 day, “Let the shameful wall of exclusion finally come tumbling down.” We must make sure that digital learning opens doors for all learners and not blocking access for some. It’s incumbent on all of us to make sure that every learner can access the promise of digital learning.

Someone using a braille terminal or braille display, an assistive technology to help individuals who need visual assistance to use a computer — *An individual using an assistive technology device called a braille terminal or display.*

While we invite you to join us in eradicating digital barriers in September, let’s keep this work going each and every month. Whether it’s exploring our resources, joining the MIX community, or attending one of our events, together we can ensure that every learner has the opportunity to succeed. And, as always, WCET is here to help you as we collectively bring down those walls of exclusion. Please reach out and let us know how we can help.

* If you are interested in learning more about the passage of the ADA, check out PBS’s recent American Experience documentary, Change Not Charity: The Americans with Disabilities Act.

At WCET, we believe in being transparent in how we use AI. Perplexity was used to review this blog post and offer suggestions for improvement.

This post was written by Van Davis

Access, Accessibility, Digital Learning, Distance Education, Managing Digital Learning, Online Learning, Student Success, Technology, WCET

Policy

Insights into AI’s Transformative Role in Higher Education: WCET’s 2025 Survey

By Lindsey Downs

August 21, 2025

TLDR Catch our video summary Watch Now. WCET Frontiers

Artificial Intelligence is no longer a distant possibility on the higher education horizon. It’s here. And it is reshaping how institutions operate, teach, and support learners (in fact, I’d say it is changing the way most places operate, whether they’re ready for it or not). Since WCET’s first AI survey in 2023, the pace of experimentation and adoption has accelerated dramatically. It’s two years later, and now we see both growing momentum and innovation in how AI is used, and also pressing challenges: institutions are testing new ways to improve efficiency, personalize learning, and guide policy development, all while grappling with issues of ethics, equity, and sustainability.

To capture these shifts, WCET turned to trusted colleague and friend Judith Sebesta, to lead in updating the survey and report. This year’s survey and accompanying report offer a timely look at where colleges and universities stand with AI in 2025. With insights from over 200 institutions plus expert interviews, the findings reveal how campuses are moving from curiosity and concern to strategy and from experimentation to large-scale planning. Whether you’re already piloting AI initiatives or just beginning to ask the big questions, we hope this research provides valuable guidance and sparks meaningful conversation across the higher education digital learning community.

Enjoy the read,
– Lindsey Downs, WCET

Artificial Intelligence (AI) is reshaping the landscape of higher education, offering profound opportunities alongside complex challenges institutions must address. Since the widespread adoption of generative AI tools in late 2022, higher education institutions have entered a period of rapid experimentation and transformation. Initially, concerns about academic integrity dominated discussions, but institutions quickly recognized AI’s broader potential. From streamlining student services to enhancing personalized learning and improving operational efficiency, AI is now widely seen as a catalyst for campus innovation, though skeptics remain.

To provide insight into those opportunities and challenges, a new WCET report offers a detailed look at how colleges and universities are approaching artificial intelligence (AI) in governance, operations, and teaching and learning. Supporting Governance, Operations, and Instruction and Learning through Artificial Intelligence: A Survey of Institutional Practices and Policies 2025 provides a comprehensive snapshot of how colleges and universities are integrating AI across campus. With insights from 224 survey responses and interviews with seven higher education professionals, the report highlights the current state of AI adoption; support, incentives, and training; policies and guidelines; AI’s benefits and challenges; and predictions and recommendations for the future.

Key Findings

AI Use: A Focus on Instruction and Learning

The 2025 WCET survey, its second after the first in 2023, reveals that most institutions are still in the early stages of AI integration. The majority have deployed AI within the last two years, most commonly for instruction and learning. However, survey data suggest that its use to support operations and governance is growing. AI is primarily used to enhance efficiency and productivity for academic tasks, such as content creation, editing, and curriculum development. For institutions not using AI, a primary reason is the lack of knowledge among administrators, staff, and especially faculty.

Support, Training, and Incentives: Building AI Literacy

Key support strategies for responsible and effective AI use focus on:

ethical guidelines,
general policy development, and,
faculty training.

Workshops and webinars are the most common forms of professional development for faculty, administrators, and staff. student training remains limited, with nearly one-third of institutions offering no AI-related education to their learners. This gap is concerning, given the growing importance of AI skills in the workforce.

Faculty champions and dedicated AI task forces and committees are driving AI integration across campuses. These support structures are essential for fostering a culture of experimentation and collaboration. Incentives, such as public recognition, certification, and stipends, are also being used to encourage AI adoption. However, while a majority of institutions do not offer incentives to encourage AI use, there has been an increase since the previous survey in institutions that do, particularly at larger, well-resourced institutions.

The Role of Policies and Guidelines

A large majority of surveyed institutions either have existing AI policies or are developing them, a significant increase since WCET’s 2023 AI survey. Academic integrity and plagiarism policies are the most common, reflecting ongoing concerns about student misuse of AI tools. However, some institutions are opting for more flexible guidelines and frameworks to address the rapidly evolving nature of AI technologies.

Institutions are also beginning to explore policies related to ethical and responsible AI use, data security, and instructional applications. The report emphasizes the importance of aligning these policies with institutional goals and involving diverse stakeholders, including students, in their development.

Challenges and Benefits

The report identifies several obstacles to AI adoption, with the most significant being insufficient knowledge among faculty and staff. Distrust and skepticism toward AI technologies also persist, alongside ethical concerns, resistance to change, and worries about academic integrity. These challenges highlight the importance of robust training programs and clear guidelines to address knowledge gaps and build trust.

Environmental concerns are emerging as a new challenge, reflecting growing awareness of AI’s resource-intensive nature. Institutions are beginning to grapple with the ethical implications of AI’s environmental footprint, including its impact on water and energy consumption.

Despite these challenges, AI offers numerous benefits. While “teaching critical digital skills” was the top benefit of AI in 2023, “efficiency” is now the most frequent benefit, reflecting a focus on practical AI applications. AI is also being used to improve student outcomes and provide personalized learning experiences.

Innovative applications of AI are emerging across campuses. For example, Northern Virginia Community College is using AI to evaluate transcripts, reducing processing times from weeks to days. Similarly, Metropolitan State University of Denver is deploying AI as a collaborative tool for teams, enhancing productivity and creativity.

Predictions for the Future

A road leading forward, taken to show high speed

The report includes intriguing predictions from interviewees about AI’s future in higher education. One envisions AI-powered personal assistants that follow students throughout their educational journey, providing tailored advice, tutoring, and support. These assistants/agents could revolutionize student services, making education more personalized and accessible.

AI is also expected to transform assessment practices, shifting the focus from final products to the learning process itself. By analyzing students’ interactions with AI tools, educators can gain deeper insights into their learning experiences and critical thinking skills. We may see a premium on the spoken word over the written, and a shift from valuing degrees to valuing skills.

However, concerns about the digital divide and the potential obsolescence of traditional degree programs remain. As AI reshapes the job market, institutions must ensure equitable access to AI technologies and prepare students for a future where skill sets may outweigh formal credentials.

Recommendations for Institutions

Based on the survey findings, the report offers ten actionable recommendations for higher education institutions (with more information on each in the report itself):

Develop Comprehensive Policies and/or Guidelines.
Invest in AI Literacy and Fluency Training.
Establish Support Structures.
Offer Incentives.
Coordinate AI Use Across Curricula.
Address Challenges Proactively.
Promote Ethical and Equitable Use.
Expand Student Training.
Leverage AI for Operational Efficiency.
Encourage Experimentation.

A Call to Action: Let’s Move from Insight to Opportunity

decorative arrows pointing to the upper right, indicating it's time to take action and move forward

The 2025 WCET survey findings underscore that ignoring AI is no longer a viable strategy for higher education institutions. As AI becomes increasingly ubiquitous, colleges and universities must mitigate its challenges while maximizing its benefits. By investing in training, developing clear policies, and fostering a culture of experimentation, institutions can harness AI to enhance their core missions, transforming higher education in the process.

Looking ahead, the success of AI integration will depend on proactive strategies that prioritize ethical considerations, equity, and sustainability. Higher education stands at a critical juncture, and the insights from the report provide a roadmap for building a future where AI augments, rather than disrupts, the human-centered mission of learning.

WCET looks forward to helping its member institutions build that future.

This post was written by Judith Sebesta

Artificial Intelligence, Digital Learning, Distance Education, Faculty, Managing Digital Learning, Online Learning, Professional Development, Student Success, Teaching, Technology

Policy

Your Opportunity to Inform the Department of ED: New Rulemaking Impact on Digital Learning

By Lindsey Downs

August 13, 2025

TLDR Catch our video summary Watch Now. WCET Frontiers. Link to video.

Another year, another round of U.S. Department of Education Negotiated Rulemaking, and once again, the results could have a big impact on students and the institutions serving them through distance education.

On July 25, 2025, the Department released Public Hearing; Negotiated Rulemaking Committees. Two committees will be formed to develop future regulations affecting Title IV Student Aid programs:

The Reimagining and Improving Student Education (RISE) Committee will address changes to the Federal student loan programs.
The Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee will address changes to institutional programmatic accountability, the Pell Grant Program, and other changes to the Title IV, HEA programs.

Image of a hand holding a tv remote pointed toward a blurry television

For our digital learning community, the AHEAD Committee is the one to watch. In this post, we’ll break down the Department’s goals, explain why this matters for you, and highlight how you can get involved.

While the Biden Administration’s higher education focus leaned heavily toward student consumer protection, the current Trump Administration is signaling priorities of accountability and efficiency.

We encourage everyone in our digital learning community to offer their voice through two different opportunities:

Submit a written public comment via the Federal eRulemaking portal through August 28, 2025.
1. Corrected Docket ID: ED-2025-OPE-0151
Nominate a negotiator from a designated constituency group listed in the announcement through August 25, 2025.
1. RISE Committee – email nominations to: nominationsfederalstudentloans@ed.gov
1. AHEAD Committee – email nominations to: negregnominations@ed.gov

Rulemaking Announcement

The Federal Register announcement marks the first step of a legislatively mandated process for an administrative agency to develop regulations to implement Federal statutes. The Department indicated that this rulemaking is necessary to implement recent statutory changes to Title IV HEA programs that were addressed in the recent enactment of the One Big Beautiful Bill Act (OBBBA). Please review our recent WCET Frontiers article on its impact on digital learning.

Because these regulations affect Title IV HEA programs, the Department must follow a special process called negotiated rulemaking. This means that the Department will convene a committee of stakeholders, nominated by the public, to discuss and draft the rules together. We will be given the opportunity to watch the committee meetings virtually. Later in the rulemaking process, proposed rules will be released for public comment. If you have any additional interest in the elements of rulemaking, please review our one-page SAN Resource, U.S. Department of Education Rulemaking Process.

The following is pertinent information from the announcement about the AHEAD Committee.

AHEAD Committee Issues

The Department shared the following proposed issues for negotiation for the AHEAD Committee:

Changes in institutional and programmatic accountability measures, including loss of Direct Loan eligibility for certain programs with low earnings outcomes for 2 out of 3 years, and Financial Value Transparency and Gainful Employment.
Establishment of program eligibility requirements for a new Workforce Pell Grant for students enrolled in programs that last 8-15 weeks, are transferable to a recognized postsecondary credential or degree, are approved by the state governor, and have strong outcomes.
Exclusion of Pell Grant assistance for students who receive grant or scholarship aid covering their entire cost of attendance or for students with a Student Aid Index in excess of twice the maximum Pell Grant award.
Other provisions included in Public Law 119-21 that are effective upon enactment, on July 1, 2026, on July 1, 2027, or on July 1, 2028.

AHEAD Committee Constituency Groups for Stakeholder Public Nominations

Students who are currently enrolled and receiving assistance from the Title IV, HEA programs.
Students who are veterans, U.S. military service members, or groups representing them.
Employers and groups representing the business community, including small, medium, and large businesses.
Legal assistance organizations that represent students, consumer advocates, and civil rights groups that represent students.
Public institutions of higher education, including institutions eligible to receive Federal assistance under Title III and Title V of the HEA, Tribal Colleges and Universities, and Historically Black Colleges and Universities.
Private nonprofit institutions of higher education including institutions eligible to receive Federal assistance under Title III and Title V of the HEA, Tribal Colleges and Universities, and Historically Black Colleges and Universities.
Proprietary institutions of higher education, as defined in 34 CFR 600.5.
State workforce agencies and workforce development boards.
State grant agencies, and other state and non-profit higher education financing organizations.
State higher education executive officers, State authorizing agencies, and other State regulators.
Accrediting agencies recognized by the Secretary of Education.
Organizations representing taxpayers and the public interest.

AHEAD Committee Meeting Schedule for Negotiations

The committee meetings will be held in person, but will also be live-streamed.

Times: 9:00 a.m. to 12:00 p.m. and 1:00 p.m. to 4:00 p.m. Eastern time
Session 1: December 8, December 9, December 10, December 11, and December 12, 2025.
Session 2: January 5, January 6, January 7, January 8, and January 9, 2026.

Insights from the August 7 Virtual Public Hearing

The Department’s virtual hearing featured a diverse set of speakers, from student advocates to higher ed associations to veterans’ organizations. Overall, the theme of participant requests was for the Department to develop clear language of definitions, offer direction regarding implementation of the regulations, and provide information for the public to understand the changes.

Notably, the moderator was more interactive with commenters than in past hearings, offering editorial comments that were more sympathetic with student concerns, clarifying issues predating this administration, and indicating support for the administration’s priorities.

For our community, five themes stood out:

More diverse representations on rulemaking committees. Comments called for additional seats on the rulemaking committee to represent community colleges, financial aid offices, representation by minority-serving institutions, and civil rights advocates.
Clear definition of professional student. There are requests for clarity and an expanded definition of who is a professional student. There is interest in a broader definition that includes programs that the Department may not have considered, such as education for pilots and the advanced postgraduate law degree (LLM). Some said that the Department should also provide a list of programs.
Accountability measures for public service programs. Concerns that accountability measures should account for high-value but lower-salary occupations (teaching, social work, and other public service programs).
Regional variability of salaries. It was recommended that regional variability in states be considered as states determine state median salaries related to program outcomes.
Additional guiderails for Workforce Pell. Comments and recommendations that Workforce Pell incorporate guardrails to prevent bad actors from being approved to offer programs. Additional comments requested state direction by the Department to include shared definitions, data support, and tools to navigate the oversight of the program intended for this grant opportunity.

These comments will likely influence the Department’s initial issue papers, which could be the starting point for committee negotiations in December.

How to Participate

There are several ways our community can make its voice heard in this rulemaking. There will also be more opportunities as the process unfolds. Here are two initial ways to participate now and one opportunity that will be available when the rulemaking meetings begin.

Nominate a Committee Member

As noted earlier, the Federal Register announcement lists specific stakeholder groups the Department considers key for this rulemaking. Institutions or organizations may nominate someone outside those groups, but acceptance is not guaranteed. The nomination process is detailed in the “Nominations Process” section of the Federal Register announcement. Please follow those instructions carefully.

Email nominations to:

RISE Committee: nominationsfederalstudentloans@ed.gov
AHEAD Committee: negregnominations@ed.gov

The nomination deadline is August 25, 2025. The Department will confirm receipt and later post the final list of negotiators on its webpage for Negotiated Rulemaking 2025.

Submit a Public Comment

WCET and SAN strongly encourage members to submit comments when invited. This is your best chance to share questions, concerns, recommendations, or support for specific issues. Practitioner perspectives are invaluable in shaping rules that can be implemented effectively.

Anyone may submit a comment, but do not state that you represent your institution or agency unless you have official authorization. For tips, see SAN’s one-pager, Writing an Effective Public Comment.

The public comment deadline is August 28, 2025 (updated from the original August 25 date). Submit your comment(s) via the Federal eRulemaking Portal. The deadline and submission process are the same for both committees. This deadline was changed when the Department made a Correction to Docket ID, published on July 29, 2025.

Make a pre-registered Comment During the Negotiated Rulemaking Meetings

Once negotiations begin, the Department reserves the last 30 minutes of each day for pre-registered public comments. This is another opportunity to make your perspective part of the official record.

After negotiations conclude, the Department will publish the Notice of Proposed Rulemaking (NPRM), typically with a 30-day written comment window. We will share guidance on participating in that stage when the time comes.

Next Steps

We recommend that you discuss this process and your interest in active participation in the rulemaking with others at your institution or agency. Even if you don’t plan to submit comments or nominate someone directly, designate someone on your team to follow the process closely. These issues are significant and will likely affect your work. As we noted in our OBBBA analysis, this administration has made accountability measurement, for all programs and across all sectors, a top priority. That means your processes may need to change once the new structures are in place.

You may also find new opportunities to serve students through Workforce Pell, but that will require planning and building the right institutional processes.

In the meantime, SAN and WCET will help you prepare for what’s ahead by tracking developments and sharing updates, analysis, and practical guidance on how the proposed rules could affect you.

This post was written by Cheryl Dowd, SAN

Department of Education, Digital Learning, Distance Education, Higher Education Act, Negotiated Rulemaking, SAN, State Authorization, State Authorization Network, U.S. Department of Education

Policy

Understanding the Trump Administration’s Educational AI Policies

By Lindsey Downs

August 11, 2025

Stylized and abstract image representing AI

On July 22^nd, the White House released its national AI action plan, and, on the same day, the Department of Education followed up with the release of both a Dear Colleague Letter on the use of federal funds for Artificial Intelligence (AI) as well as a call for public comment on the Secretary’s supplemental priority and definitions on advancing artificial intelligence in education.

Collectively, these documents provide us with an excellent indication of this administration’s AI priorities and policies. Although the impact of these documents on higher education is middling, it’s still important to understand the administration’s priorities and its approach to artificial intelligence.

Winning the Race: America’s AI Action Plan

Last month, the White House released Winning the Race: America’s AI Action Plan. Proclaiming that America is in a “race to achieve global dominance in artificial intelligence,” the administration goes on to proclaim that, “Winning the AI race will usher in a new golden age of human flourishing, economic competitiveness, and national security for the American people… An industrial revolution, an information revolution, and a renaissance—all at once. This is the potential that AI presents.”

The plan itself consists of three pillars:

Accelerate AI Innovation,
Build American AI Infrastructure, and,
Lead in International AI Diplomacy and Security.

And although much of the plan is out of the purview of higher education, there are a few items that will potentially impact colleges and universities. The plan:

outlines the need to encourage open-source and open-weight AI models and ties the development and use of those models to academia, among other players;
advocates for the development of AI Centers of Excellence and domain-specific efforts that would include academic stakeholders in order to accelerate the development and adoption of national AI systems;
calls for empowering American workers in the age of AI by having the Departments of Education, Labor, and Commerce, along with the National Science Foundation, prioritize AI skill development “as a core objective of relevant education and workforce funding streams,” and,
Calls for the empowerment of American workers through the training of a skilled workforce that can facilitate the development of AI infrastructure. This would not only include engineers and computer scientists but also trades such as HVAC and construction. To do so, the plan goes on to state, “Led by DOE, expand the hands-on research training and development opportunities for undergraduate, graduate, and postgraduate students and educators, leveraging expertise and capabilities in AI across its national laboratories. This should include partnering with community colleges and technical/career colleges to prepare new workers and help transition the existing workforce to fill critical AI roles.”

Department of Education’s July 22, 2025, Dear Colleague Letter

RE: Guidance on the Use of Federal Grant Funds to Improve Education Outcomes Using Artificial Intelligence (AI)

The purpose of this Dear Colleague Letter is to:

provide grantees with guidance on the use of federal funds for artificial intelligence;
outline how grantees can use AI to “enhance teaching and learning; and,
expand access, and support educators, without replacing the critical role they play.”

Towards this end, the letter outlines three areas that funds can be used for:

AI-based high-quality instructional materials, including adaptive instructional tools; high-quality personalized learning materials; and training for educators, providers, and families on how to use AI tools effectively and responsibly.
AI-enhanced high-impact tutoring, including intelligent tutoring systems for individualized and real-time academic support; hybrid human/AI tutoring platforms; and diagnostic and scheduling tools that leverage AI to match learners and tutoring services.
AI for college and career pathway exploration, advising, and navigation, including AI platforms that help students identify and explore career pathways; virtual advising systems that assist students with course planning, financial aid, and other transitions to postsecondary education or careers; and predictive models that assist in identifying students in need of additional support.

Perhaps more importantly, the Dear Colleague Letter includes five principles of responsible AI use that include:

Educator-led: AI should support teachers, providers, tutors, advisors, and education leaders.
Ethical: Within the K-12 realm in particular, educators should help students navigate AI to be able to evaluate the validity of AI outputs, to understand the appropriate use of AI in the context of social media, to learn with—rather than exclusively from—AI, and to leverage the promise of AI to be contributing members of a free society.
Accessible: AI tools or systems should be accessible for those who require digital accessibility accommodations, including children, educators, providers, and family members with disabilities.
Transparent and explainable: Stakeholders, especially parents, should understand how systems function and participate meaningfully in decisions about the adoption and deployment of new technologies.
Data-protective: Systems must comply with federal privacy laws, including the Family Educational Rights and Privacy Act.

Call for Public Comment Proposed Priority and Definitions

Secretary’s Supplemental Priority and Definitions on Advancing Artificial Intelligence in Education
(Docket ID ED—2025—OS—0118)

On July 20^th, the Department of Education also released a call for public comment regarding the Secretary’s supplemental priority and definitions on advancing artificial intelligence in education. In this call for public comment, the Department lays out its priorities around artificial intelligence as well as a proposed regulatory definition of artificial intelligence literacy. Arguing that “As AI becomes more integrated into the tools and systems that shape elementary, secondary, and postsecondary education, it is increasingly important for students to develop AI literacy.” The Department goes on to discuss what it refers to as “powerful opportunities” for AI to support teaching and learning. These include:

personalized instruction,
analysis of student progress,
identification of learning gaps, and,
tailored student support.

Although much of this document focuses on K-12 instruction, it does include several higher education areas, including the recommendation that colleges and universities “Expand offerings of AI and computer science courses as part of an institution of higher education’s general education and/or core curriculum.” It also advocates for providing professional development around AI skills for pre-service and in-service teachers, a role that higher education is uniquely qualified to fill. Additionally, the Department suggests that institutions should create dual enrollment opportunities for students to earn postsecondary and industry-recognized credentials in AI coursework. Finally, of note, the Department urges that AI be leveraged to “Promote efficiency in classrooms and school operations through the application of AI technologies that reduce time-intensive administrative tasks.” The call for public comment also includes a proposed definition of artificial intelligence literacy:

Artificial intelligence (AI) literacy means the technical knowledge, durable skills, and future ready attitudes required to thrive in a world influenced by AI. It enables learners to engage, create with, manage, and design AI, while critically evaluating its benefits, risks, and implications.

WCET largely concurs with the Department’s priorities and definition of AI literacy. However, in our public comment, we proposed the following changes in bold: “Artificial intelligence (AI) literacies mean the interconnected technical knowledge, durable skills, and future-ready mindsets required to thrive in a world influenced by AI. They enable learners to engage, create with, manage, and design AI while critically evaluating its benefits and risks, as well as its ethical, social, political, economic, and cultural implications.” We believe, in accordance with the scholarship of experts such as Angela Gunder, CEO and Founder of Opened Culture, that it is more accurate to describe AI literacy as a plurality of literacies that operate on a continuum rather than dichotomously. We also believe that it is essential to underscore the critical implications of AI by explicitly calling out those implications.

We suggest that institutions or individuals who are interested in AI in postsecondary education consider submitting a public comment by August 20th.

In Conclusion: We’re at a Crossroads

Image of a crossroads - two different paths going different directions.

Even if higher education is only minimally called out in these documents, digital learning leaders have a strong role to play in influencing these policies both at the national level and at their institutions. Whether it’s through the public comment process or just staying abreast so you can help shape the development of your campus policies, digital learning leaders are well-positioned to advocate for the ethical, responsible, and effective integration of AI in teaching and learning.

Here at WCET, we are committed to helping you stay informed of the federal government’s AI efforts that directly impact higher education institutions. We are at a crossroads, and now is the moment for digital learning leaders to lend their expertise towards helping us navigate the increasingly complex landscape of artificial intelligence. Too much is at stake for us to stay on the sidelines.

This post was written by Van Davis, WCET

Artificial Intelligence, Department of Education, Distance Education, Negotiated Rulemaking, Student Success

1) A Governor’s “why” matters, and it’s squarely about outcomes

2) Speak plainly (or slow your own progress)

3) LER readiness is accelerating, design like your audience is listening

4) Move from learner agency to learner responsibility, and design for pride

5) The LER ecosystem has begun clicking – because it’s interconnected

6) What “all learning counts” can mean for higher ed

A closing nudge

Get the Handbook and Put it to Work

Overview of the New State-to-State Institutional Approval for Distance Education Handbook

Using the Handbook

Conclusion from Cheryl Dowd

SAN Major Reports:

What is the framework fog?

Cutting through the fog

Conclusion

Introducing WCET’s New Featured Member Series

About ASU

Why is digital learning important to your institution?

What challenges have you faced in digital learning, and how did you address them?

Looking ahead, what trends or initiatives are shaping your digital learning plans?

Why WCET?

Thank You!

Our Process

Step 1: Inventory Content

Digital Materials

Video Content

Step 2: Help! We need help!

Step 3: Out with the old, in with the new

Step 4: Juggling another ball at the same time – making sure that new content is accessible from the beginning

Focus on Progress and Work Toward Perfection

Key Findings

AI Use: A Focus on Instruction and Learning

Support, Training, and Incentives: Building AI Literacy ​

The Role of Policies and Guidelines

Challenges and Benefits

Predictions for the Future ​

Recommendations for Institutions ​

A Call to Action: Let’s Move from Insight to Opportunity

Rulemaking Announcement

AHEAD Committee Issues

AHEAD Committee Constituency Groups for Stakeholder Public Nominations

AHEAD Committee Meeting Schedule for Negotiations

Insights from the August 7 Virtual Public Hearing

How to Participate

Nominate a Committee Member

Submit a Public Comment

Make a pre-registered Comment During the Negotiated Rulemaking Meetings

Next Steps

Winning the Race: America’s AI Action Plan

Department of Education’s July 22, 2025, Dear Colleague Letter

Call for Public Comment Proposed Priority and Definitions

In Conclusion: We’re at a Crossroads

Support, Training, and Incentives: Building AI Literacy

Predictions for the Future

Recommendations for Institutions