Author: Lindsey Downs

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

Practice

1984 to 2025: What Four Decades of Technology Taught Me About AI’s Promise

By Lindsey Downs

August 7, 2025

In 1984, I was 15 years old, living in Midland, Texas, and Apple had just released the Macintosh 128K, their first Mac computer. My father, who had never touched a computer in his life, for some reason decided that “these computer things” weren’t going away and that his kid should know how to use one. I don’t know why he chose a Macintosh, but he did. He brought it home, set it up on a desk in the family room, handed me the user’s manual, and suggested that I figure out how to use it.

I didn’t realize at the time the extent to which technology would consume my professional and personal lives, but I do remember the wonder of exploring that computer and creating things that I never imagined. Fast forward to 2025, where the smartphone that I carry in my pocket can store seven million times more data than the Apollo guidance computer and has a processor that runs more than 100,000 times faster. Back then, my dad and I had no idea just how much technology would reshape our lives, or how quickly we’d need to learn to keep up with it.

Image of an Apple Macintosh 128K, released in 1984 — *The Apple Macintosh 128K, released in 1984*

The rate of technological change has been breakneck over the last several decades, yet that rate is poised to seem like a snail’s pace compared with where AI is taking us. And, let’s face it, that’s exhausting. AI fatigue is a real thing. It’s hard not to be exhausted with the rate of change and frustrated by the hype surrounding AI. But AI is here, and it is changing higher education. No technology, including AI, is a magical silver bullet that is going to solve the myriad of challenges facing higher education, no technology is, but AI is forcing us to rethink our practices and processes both inside and outside of the classroom.

AI’s potential impact on the job market is monumental. In its 2024 Employability Report, Cengage Group reported that 47% of employers expected job applicants to possess AI skills, 41% said that AI skills made applicants more competitive, and 66% said that they wouldn’t hire an applicant who did not have AI skills. At the same time, employers are indicating that AI skills are not enough; they expect recent graduates to also possess so-called “soft skills,” like adaptability, problem solving, communication, research, and writing. In fact, the World Economic Forum, in its 2025 Future of Jobs report, indicated that only one of the top ten job skills employees would need was connected to technology. Those skills were, in order:

Analytical thinking
Resilience, flexibility, and agility
Leadership and social influence
Creative thinking
Motivation and self-awe
Technology literacy
Empathy and active listening
Curiosity and life-long learning
Talent management
Service orientation and customer service

What does this all mean for higher education?

I believe that it means that we can’t afford not to instill digital literacy skills, including AI skills, in our students, faculty, and staff. But not at the expense of what higher education has historically done best: teach learners how to be critical thinkers, problem solvers, and communicators to a wide range of audiences. At the end of the day, AI will never replace human capabilities, but it can amplify them, making skills like analytical and creative thinking, curiosity, and life-long learning more valuable than ever before.

August with WCET

This month, WCET is sharing a variety of AI resources that focus on AI literacies and institutional policies. We began our AI journey two years ago with the release of our first survey of institutional AI policies and practices, followed by WCET’s AI Policy and Practice Framework and toolkit. Since then, we’ve published dozens of blogs about AI at institutions and worked with Every Learner Everywhere and Teach Access on a report and webinar focused on AI and accessibility. Later this month, we’ll be releasing the results from our second survey of institutional AI policies and practices, as well as previewing work that we will be doing in collaboration with D2L on AI literacies. This work will culminate in an AI literacies toolkit later this fall. And for those of you who will be joining us at WCET 2025 in October, we hope you consider joining us for a preconference workshop on AI, “genAI in Higher Education: Ethics, Innovation, and Empowerment.”

A lot has happened since that first Macintosh came out in 1984. The internet, at least for a non-academic audience, was still nine years away before Mosaic would emerge in 1993. And we wouldn’t see peak dial-up internet until 2000, when about 43% of American homes accessed the internet through a dial-up connection (anyone remember the excitement of AOL’s “You’ve got mail!” message?). But one of the constants has been WCET. From our beginning in 1989, we’ve worked with institutions to understand the changing technical landscape and how emerging technologies can be used to expand student access to high-quality educational opportunities and improve their success. And we’ll continue to do so through the breakneck speed of technical change that artificial intelligence is driving. So, whether you’re early in your AI journey or well along that pathway, we’re here to help you navigate the changes. Please let us know how we can help. That 15-year-old Van with his clunky Macintosh couldn’t imagine the AI world of 2025, and today’s AI moment is creating opportunities for higher education that we are just beginning to understand. We know change is coming; how will you shape it?

This post was written by Van Davis, WCET

Artificial Intelligence, Managing Digital Learning, Online Learning, Technology

Practice

Securing Support, Building Trust: Why Buy-In Matters in Compliance

By Lindsey Downs

July 31, 2025

When it comes to institutional change and implementing new processes, gaining buy-in for the plan is critical. In 2022, a team at the University of Memphis (UM) made this strategy their priority. This unfolded when UM officials realized its need to rapidly transition from the Desire2Learn (D2L) Learning Management System (LMS) to the Instructure/Canvas platform. Because this transition required the migration of over 27,000 courses and needed to be completed within six months, all who were involved knew that this would be a daunting task (K16 Solutions, n.d.). However, the UM project/transition team had a strategy; they understood that securing ‘buy-in” from one of their major stakeholders, the faculty, would be the key to a successful integration.

Group of professionals around a table, showing how professionals may work together to build buy-in

Accordingly, UM’s project leaders involved the university’s faculty early and often in the process. The project team incorporated faculty in their three-phased pilot testing, which gave them visibility to dozens of courses from various schools and colleges across the campus. As such, they were able identify issues, provide critical feedback which prompted real-time adjustments. UM faculty also participated in weekly check-in calls, which helped maintain course integrity and build faculty confidence resulting in a smooth transition with 99.9% data accuracy (K16 Solutions, n.d.)

Although the term “buy-in” is frequently used, it is often misunderstood, both in its true meaning and in the significance it holds for successful implementation and collaboration. While there are many scholarly articles surrounding the term (Kotter and Whitehead, 2010, Martin, 2012, Shtivelband & Rosecrance, 2010), what does “buy-in” really mean?

According to Moon (2009), buy-in is a commitment to agreements about work and it involves some degree of trust between the change agent and stakeholders. Jakobsen (2020) defines it as the process of securing support, agreement, or endorsement from stakeholders regarding a specific idea, initiative, or decision.” All agree that obtaining it plays a critical role in all organizational settings where achieving consensus and alignment among team members is key to effective implementation and long-term success.

Why Buy-in is a Must

Developing buy-in/support in higher education compliance programs is crucial for ensuring the effectiveness, sustainability, and integrity of institutional operations. It is essential for achieving meaningful, sustainable progress across academic and compliance efforts.

Large group of individuals around a table, view from above them - showing how professionals may work together to build buy-in

Gaining buy-in also fosters and promotes a culture of integrity and accountability. Instead of viewing compliance as simply a checklist, garnering buy-in reinforces the idea that compliance is part of the institution’s core values.

Having the backing of faculty, staff, and leadership promotes a shared commitment to ethical conduct. Without institutional buy-in compliance efforts can easily become fragmented, overlooked, or unsustainable, putting the institution at legal and financial risk.

Because institutions within academia are often decentralized, securing buy-in ensures that all stakeholders are aligned around shared goals, policies, and practices. Having a mutual commitment improves adherence to policies and regulations, reduces resistance, and fosters a sense of ownership, leading to higher motivation, productivity, and better outcomes.

Developing Buy-In at Your Institution

Developing buy-in requires a strategic, phased approach that blends communication, collaboration, leadership, and accountability. Here are ten tips, best practices, and actionable steps to help garner support at your own institution.

Secure Leadership Commitment and Alignment

Conduct briefings with leadership on the compliance risks and institutional impact.
Ensure visible and sustained support from top leadership (e.g.: Chancellor, President, Provost, Deans).
Include a public endorsement and inclusion of compliance goals in the institution’s strategic plans.
Employ leadership to communicate the value and necessity of compliance, setting the tone for institutional culture.
Incorporate compliance as a standing agenda item in leadership meetings and campus-wide communications.

Engage Key Stakeholders Early in the Process

Identify key stakeholder groups including faculty, staff, student services, general counsel/legal, IT, and HR.
Host listening sessions and/or focus groups to gather input prior to launching initiatives.
Appoint stakeholder representatives/champions to compliance advisory committees.

Build Cross-Departmental Collaboration

Create compliance committees or task forces with representatives from key departments (e.g., compliance office, legal, academic units, student affairs, IT).
Encourage regular meetings to share updates, identify risks, and coordinate responses, breaking down silos that hinder unified action.
Engage stakeholders early in policy development and training initiatives to foster ownership and establish relevance.

Develop Clear, Accessible Policies and Procedures

Draft compliance policies that are straightforward, actionable, and regularly updated.
Make all compliance documents easily accessible using tools like the intranet, an LMS, or a compliance portal.
Provide summaries or FAQs for complex regulations to enhance understanding across all campus roles.

Implement Targeted and Ongoing Training

Create engaging training modules tailored to different audiences (faculty, staff, students, administrators) and be sure to offer a flexible format for training.
Use self-paced online modules and in-person workshops; incorporate real-world scenarios and knowledge checks.
Integrate compliance training into onboarding for new hires and require annual “refresher” courses for all employees.

Foster a Culture of Compliance and Ethics

Normalize compliance as a part of campus culture.
Encourage leaders and managers to model compliant behaviors and ethical decision-making.
Empower individuals to voice concerns without fear of retaliation by promoting confidential reporting channels.
Recognize and reward compliance champions or departments that demonstrate exemplary commitment.

Communicate Proactively and Transparently

Develop a communications plan with tailored messages.
- Use multiple communication channels (e.g., email, newsletters, campus forums, digital signage, social media, etc.) to share compliance updates, deadlines, and success stories.
Send regular reminders about key regulations and upcoming training or policy changes.
Emphasize that compliance supports institutional integrity, student protection, safety, and accreditation.
Ensure disclosures about compliance requirements are timely, clear, and relevant (Note: This is especially critical when considering stakeholders such as the enrollment/admissions and financial aid teams).
Track participation and follow-up with non-completers supportively.

Involve the Community in Continuous Improvement

Solicit feedback from faculty, staff, and students on compliance processes and training effectiveness.
Establish mechanisms for reporting compliance gaps or suggestions for improvement (surveys, suggestion boxes, open forums).
Use feedback to refine communication strategies and address emerging risks collaboratively.

Leverage Technology for Communication and Monitoring

Implement compliance management software to centralize documentation, track training completion, and automate reminders.
Use data analytics to identify engagement trends and target communication to areas with low buy-in or understanding.

Monitor, Assess, and Report Progress

Conduct regular compliance assessments and audits to identify gaps and measure program effectiveness.
Share progress reports and compliance metrics with leadership and the broader campus community to maintain transparency and accountability.
Adjust strategies based on assessment outcomes and evolving regulatory requirements.

Summary Table

Tip Number	Strategy	Action
1	Leadership Commitment	Visible support, regular communications, agenda integration.
2	Stakeholder Engagement	Identify stakeholders, host focus groups, appoint representative to advisory committee.
3	Cross-Departmental Collaboration	Establish committees, share updates, break silos.
4	Establish Clear Policies & Procedures	Draft, update, and disseminate accessible policies.
5	Provide Targeted Training	Tailor modules, integrate into onboarding, require refreshers.
6	Develop a Culture of Compliance	Model behaviors, empower reporting, recognize champions.
7	Establish Proactive Communications	Utilize multiple channels, regular reminders, clear disclosures.
8	Community Involvement	Solicit feedback, open forums, refine based on input.
9	Leverage the use of Technology	Compliance software, use analytics for targeted messaging.
10	Monitoring & Reporting	Regular assessments, share metrics, continuous improvement.

Developing buy-in is a foundational component in successfully implementing higher education distance education compliance programs. As institutions continue to expand their online learning offerings, they must navigate a complex regulatory environment that must adhere to federal, state, and state authorization requirements. Without widespread understanding and agreement across the institution, compliance efforts may be viewed as bureaucratic or secondary to teaching and learning; thus, undermining their effectiveness. Developing buy-in ensures that compliance is integrated into the fabric of online education rather than treated as an external obligation.

Fostering buy-in facilitates a culture of trust and accountability that benefits the entire institution. Doing so also provides an environment where stakeholders feel included, respected, and informed. This creates a culture where they are more likely to raise concerns, share innovations, and contribute to continuous improvement. This cultural shift is particularly important in academia, specifically in distance education, where rapid growth and evolving regulations demand agility and cooperation.

Securing buy-in is a critical component for successfully implementing compliance initiatives for higher education institutions that are navigating complex regulatory environments. This was exemplified by the University of Memphis’s rapid six-month transition to a new LMS, where early and ongoing faculty involvement was key to success.

When developing buy in, institutions must engage leadership, involve stakeholders early, promote cross-departmental collaboration, ensure clear policies, offer targeted training, and cultivate a culture of ethics and transparency. By embedding these practices into strategic planning and daily operations, institutions can elevate compliance from a procedural task to a shared institutional value, a principle that is especially vital in the dynamic and ever-changing landscape of distance education.

References

K16 Solutions. (n.d). University of Memphis: A mid-year LMS transition made easy. Inside Higher Education.
Jakobsen, M. (2020). Buy-in to a credible vision! Why leaders make prospector responses to learning oriented performance reform. Public Organization Review, 20(2), 277-299. https://doi.org/10.1007/s11115-019-00438-4
Kotter, J. (2007). Leading Change. Boston: Harvard Business Press.
Kotter, J.P., & Whitehead, L. (2010). Buy-in: saving your good idea from getting shot down. Boston, MA: Harvard Business School Publishing.
Martin, A. (2012). For social media buy-in, lead with the “why”. Harvard Business Review. Retrieved from http://www.hbr.org
Robertson, D., & Hjuler, P. (2002). Innovating a turnaround at LEGO. Harvard Business Review.
Shtivelband, A., & Rosecrance, J. (2010). Gaining organizational buy-in: Lessons learned from fifty ergonomists. Proceedings of the Human Factors and Ergonomics Society Annual Meeting, 54(17), 1277-1281. doi: 10.1177/154193121005401703
Stobierski, T. (2020). Organizational change management: What It Is & Why It’s Important. Harvard Business School Online. Available online: https://online.hbs.edu/blog/post/organizational-change-management (accessed on April 4, 2025).

This post was written by Jana Walser-Smith

Compliance, Distance Education, Leadership, Managing Digital Learning

Policy

What the “One Big Beautiful Bill Act” Means for Digital Learning in Higher Education

By Lindsey Downs

July 22, 2025

There is no shortage of news items about Congress recently passing the One Big Beautiful Bill Act (OBBBA). We know that the OBBBA was a massive budget bill that was passed using an expedited process, created by the Congressional Budget Act of 1974, called “reconciliation.” This process allows for the Senate to pass the legislation by a simple majority, rather than the more restrictive sixty-vote supermajority.

Additionally, this process avoids a potential Senate filibuster. This special process is used specifically for addressing legislation pertaining to taxes and spending. Reconciliation is subject to oversight by the Senate Parliamentarian, utilizing a Senate rule called the Byrd Rule. In short, the Byrd Rule provides that the Senate Parliamentarian can remove bill provisions that are deemed extraneous to the purpose of developing budget policy. For more information about the nuanced reconciliation process, you may wish to review The Reconciliation Process: Frequently Asked Questions provided by the Library of Congress.

While this budget-focused bill touches a lot of policy areas, it includes some notable changes that affect higher education. The original U.S. House of Representatives version of the bill included items with a more significant impact on higher education, dramatically affecting students and institutions. The Senate’s version of the bill mitigated the impact, as we will discuss. The House accepted the Senate’s changes, passed the bill, and sent the approved version of the bill to President Trump for his signature into law.

In this post, we will focus on four key areas from OBBBA that affect digital learning in higher education:

Loan Limitations & Title IV Eligibility
Pell Grants (including the new Workforce Pell)
Regulatory Relief
Institutional and Program Accountability, including a discussion of “gainful employment” and how it expands to all programs.

We’ll also share how institutions can adapt to better serve their students and effectively manage the changes.

Loan Limitations & Title IV Eligibility:

OBBBA introduces significant changes to student loans, particularly for graduate and professional learners. The ultimate effect of these changes will be the limitation of federal options for students to have access to federal funds for their education. Here is what is changing and what has stayed the same.

Key New Limitations:

Graduate Plus loans are eliminated effective July 1, 2026. There are provisions to allow enrolled students who are borrowers to continue and complete their programs.
Graduate loans will be limited to $20,000 annually for a graduate student and $50,000 annually if the student is in a professional program. There is an aggregate loan limit of $100,000 and $200,000, respectively. Professional is defined in federal regulation, 34 CFR 668.2.
Lifetime $257,500 borrowing cap for federal student loans, excluding Parent PLUS loans. Provisions allow enrolled students who are borrowers to continue under the already established limits for the lesser of three academic years or for the time expected to complete the program.

Pell Grants

Workforce Pell has been approved! For several years there has been bipartisan interest in what has also been called “Short Term Pell.” In previous years, political parties had disagreements on the structure of this grant program. The new law provides Pell eligibility for programs that are for 8-15 weeks in length as a way to provide additional opportunities for learners to obtain education and employment training.

The House bill would have permitted programs from non-accredited entities to be Pell eligible. However, that provision initially caused the Senate Parliamentarian to remove this Pell opportunity. The Senate removed the non-accredited entity provision, causing the revised provision to move forward.

Programs delivered via distance education are not excluded in the language of the OBBBA, a win for digital learning providers.

While we should expect a negotiated rulemaking and U.S. Department of Education guidance to help provide structure to implement the Workforce Pell plan, the OBBBA provides the following parameters:

Remedial, non-credit, English language learning, correspondence, and study abroad courses are not eligible.
Programs must:
- Be stackable credentials with transferable credits that meet the hiring requirements of potential employers in the sectors or occupations.
- Prepare students to pursue one or more certificates at one or more institutions.
- Be approved by the state governor as aligned with in-demand jobs and meeting employers’ needs.
- Have been offered by the institution for at least one year.
- Meet performance benchmarks, including having a ≥70% completion rate, ≥70% job placement rate (within 180 days).
- Must not cost more than the average amount graduates earn in three years after completing the program, as compared to earnings before completing the program

Key Pell Grant Provision Not Included in the Final Version of the OBBBA

A proposed increase in minimum credit hours for full-time student eligibility was removed. The House version of the bill would have increased the full-time student minimum hours for an academic year to 30 credit hours. This increase would have been a significant challenge for working learners, with a substantial impact on community college learners. The provision was removed, and the law maintains the full-time minimum hours at 24 credit hours per academic year.

Regulatory Relief

90/10 Rule revision was not included in the final legislation. An earlier version of the bill sought to repeal the 90/10 rule affecting for-profit institutions. Regulations effective in 2023 implementing the 90/10 rule were subject to a Department announcement on July 7, 2025, revising guidance provided in the preamble of the final regulation announcement. The announcement clarifies that schools may include non-federal revenue generated through distance education in their 90/10 calculation.
Gainful Employment Rule revision was not included in the final legislation. The House proposed to permanently remove “gainful employment” from several statutory definitions to determine eligible programs for aid. The Senate did not include this provision plan. See the next section on the status of gainful employment.
Borrower Defense to Repayment – delays the implementation of the 2022 regulations until July 1, 2035. Rules revert to those that were effective July 1, 2020, as the legislation indicates the 2022 rules shall not be in effect.
Closed School Discharge – delays the implementation of the 2022 regulations until July 1, 2035. Rules revert to those that were effective July 1, 2020, as the legislation indicates that the 2022 rules shall not be in effect.

Institutional/Program Accountability

A major shift in the OBBBA is that accountability measures tied to aid eligibility will apply to all programs, not just “gainful employment” programs. The OBBBA creates a new accountability measure for all programs for schools participating in federal financial aid. In short, programs could lose aid eligibility for undergraduate and graduate programs for failing metrics in two out of three years, tying aid eligibility to student earnings. Digital learning leaders need to prepare now. The law will link financial aid eligibility to graduate earnings, and the metrics will be applied regardless of modality. The effective date of this provision is July 1, 2026.

History

Federal statute, the Higher Education Act (HEA), directs that to be eligible for Title IV funds, certain non-degree programs at non-profit institutions and, with few exceptions, programs at for-profit institutions must lead to “gainful employment in a recognized occupation.”

Federal regulations provided metrics that institutions must meet for the program to be eligible for Title IV federal financial aid. The regulations were immediately the focus of scrutiny and legal challenges because the regulations primarily targeted for-profit institutions. Through negotiated rulemaking, the first Trump administration rescinded the regulations in 2019.

Accountability for ALL programs was introduced with the Biden administration reinstating and expanding Gainful Employment (GE) regulations, tying aid to outcome metrics for GE programs, and introducing new Financial Value Transparency (FVT) reporting requirements for all programs. The new regulations expanded expectations for all post-secondary institutions and represented a renewed emphasis on student outcomes and financial value.

Many experts thought the current administration, which has emphasized deregulation, would try to eliminate the GE/FVT rules created under President Biden. However, the U.S. Department of Education not only indicated that it would defend those rules in a lawsuit, but the Republican majority led House and Senate expressed their interest in institutional accountability, although initially with different proposed plans.

Key Accountability Elements in the OBBBA:

Student Earnings Thresholds
- Undergraduate programs – earnings test compares the median earnings of students who completed the program four years after completion with the earnings of “working adults” with only a high school diploma or GED.
- Graduate programs – earnings test compares the median earnings four years post enrollment with the earnings of “working adults” with only a bachelor’s degree.Programs that fail earnings tests in two out of three consecutive years will lose eligibility for federal student aid.Notice to enrolled students that the program has low median earnings is required if the institution fails the earnings test for one year during the covered period but has not yet failed for two years.
- The institution may apply to regain eligibility after a period of not less than two years.

Original House Accountability Proposal

Risk-Sharing – The House proposed an accountability plan that would hold institutions financially responsible to the federal government for unpaid federal loans by former students. Critics of the proposal expressed that this plan would have been ultimately disastrous to students, as institutions would likely be compelled to consider risk management with their enrollments. The Senate did not support this plan.

Status of Gainful Employment/Financial Value Transparency (GE/FVT) Regulations

Implementation delays have occurred, with reporting deadlines extended multiple times. The Department most recently extended the deadline for evaluating Completers’ Lists and 2024 reporting data associated with the new GE/FVT rules until September 30, 2025. On July 9, 2025, the Department released a Reminder of the FVT/GE Required Reporting for the 2025 Cycle is due October 1, 2025. The pause for the legal challenge of the gainful employment rules continues. It is unclear whether the court will complete its review and issue judicial orders to set a new deadline or maintain the currently designated deadlines for reporting. for reporting.

What Should the Digital Learning Community Do Now?

We get it! This is a lot to process. It is clear that this administration places a high priority on return on investment for the learner and protecting the integrity of federal aid programs. We anticipate direction by regulation or guidance from the Department. But here’s where digital learning professionals should start focusing their attention:

Assess data readiness: Develop or enhance systems for collecting and analyzing data on graduate outcomes, debt levels, and earnings.
Collaborate institutionally: Engage teams from financial aid, institutional research, and distance education to ensure compliance and strategic program management.
Assess program value: Consider a cost-benefit analysis to determine whether and how to improve or redesign programs with less favorable outcomes.
Prioritize transparency: Update advising and program pages to align with the transparency goals related to the FVT regulation framework and meeting statutory earnings tests.

Conclusion

The One Big Beautiful Bill Act brings both challenges and opportunities for our community. While some of the more restrictive proposals did not make it into the final law, the new accountability measures and funding changes will require attention, especially for programs delivered online or across state lines. Distance education provides our students with flexibility and access. It is important for distance education programs to show this benefit by demonstrating a good return on investment.

As always, SAN and WCET are here to help you navigate what’s next. We will continue monitoring guidance and implementation updates, and we’re committed to providing the analysis, resources, and community support you need to serve your students and stay compliant in a rapidly changing policy environment.

This post was written by Cheryl Dowd

Financial Aid, Gainful Employment, Regulation, SAN, State Authorization Network, Student Success

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Loan Limitations & Title IV Eligibility:

Key New Limitations:

Pell Grants

Key Pell Grant Provision Not Included in the Final Version of the OBBBA

Regulatory Relief

Institutional/Program Accountability

History

Key Accountability Elements in the OBBBA:

Original House Accountability Proposal

Status of Gainful Employment/Financial Value Transparency (GE/FVT) Regulations

What Should the Digital Learning Community Do Now?

Conclusion

Support, Training, and Incentives: Building AI Literacy

Predictions for the Future

Recommendations for Institutions