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Leveraging Analytics to Close DEI Access & Attainment Gaps

Post author By Lindsey Downs
Post date August 20, 2021
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Today’s post from Adam Cota with the WCET Steering Committee working group on Diversity, Equity, and Inclusion highlights how Adam’s institution, Western Governors University, uses data analytics to accomplish equity and diversity goals. This post continues the series started earlier this month on “Enabling Difference.”

We’re so thrilled to continue this series and focus on DEI throughout this month and thank Adam and the other members of the WCET DEI work group for working with us on these posts. Make sure to register now for our Closer Conversation on Diversity, Equity, and Inclusion in Digital Learning on August 27th. Registration is free and open to current WCET members but limited to the first 50 registrations. All participants are invited to interact via video and or chat.

Enjoy the read and enjoy your day,

Lindsey Downs, WCET

 

In last week’s blog post, Janelle Elias provided an analysis of strategic plans from WCET’s membership to understand how they are being used to advance Diversity, Equity, and Inclusion (DEI). With the vast majority of institutions mentioning DEI concepts in their strategic plans, it’s encouraging to see the increased focus and attention this topic is receiving.

In this week’s post, we’ll review how one institution – Western Governors University (WGU) – is leveraging advanced analytics to help drive our access and attainment goals.

We do not believe that one’s ethnicity or income should be predictive of college access or attainment.

At Western Governors University we have set the goal of closing the 4-year graduation rate gap for Black, Latinx, Indigenous and low-income students by 50% within 5 years and eliminating it completely within 10 years. These gaps are measured relative to other student groups. In addition, we want our student body demographics to reflect those of our nation within 10 years. We do not believe that one’s ethnicity or income should be predictive of college access or attainment. This does not mean that success rates for other student groups will remain flat. We want success rates for all student groups to improve, but we want them to improve faster for certain groups to close our achievement gaps.

Advanced Analytics Equity Initiative

To help achieve these objectives, WGU created the Advanced Analytics Equity Initiative in July 2020. This cross-department effort is spearheaded by three academic analytics teams – in Faculty Experience, Learning Analytics, and a dedicated Advanced Analytics team – which work with departments across the university towards a long-term goal of personalizing the student experience at scale to achieve our equitable access and attainment goals.

In the short-term, we are focused on three areas of research:

(1) Outcome driver research

While outcome gaps exist across ethnic groups at many universities, ethnicity is not the driver of these outcomes. Ethnicity is however correlated with many of the underlying drivers of student success. One objective of our Advanced Analytics Equity Initiative is to identify all drivers associated with the gap in performance between ethnicities. At that point, we will be able to adequately characterize the factors correlated with ethnicity that are driving differences in performance.

a person on a computer seen from above
Photo by Avel Chuklanov on Unsplash

Many of the drivers identified to date are unsurprising and associated with systemic racism. For instance, prior academic preparation and income correlate strongly with ethnicity and zip code and are indications of unequal academic and economic opportunity. Other drivers – such as students with a COVID illness or household COVID illness, students working overtime, or students experiencing webcam or software issues – are less well-recognized. Our early research indicates not all drivers of student success are correlated with ethnicity while others may be correlated in ways inconsistent with relative student success measures. For instance, individual attributes such as procrastination or persistence are not correlated with ethnicity or may correlate in a way that offsets the gap in attainment.

In addition to individual learner characteristics (e.g., prior academic experiences and outcomes; professional goals; learning preferences; beliefs about self, higher ed, employment; financial resources) we’re also examining historical and contextual experiences (e.g., geographic factors such as internet access and employer demand; life circumstances). Their experiences at WGU, which we classify into friction points and interventions, are perhaps the most important drivers we’re looking at (see below).

While such efforts are complicated by cross-correlations, questions of causation and data availability, we feel there is substantial work to be done in this area before we can truly understand and eliminate our achievement gaps.

(2) Friction points research

Learner characteristics and geographic contexts do not drive student outcomes in isolation. Ultimately, outcomes are determined by the interaction effects between learners and their educational experiences. These experiences may create friction or build momentum towards student success. While we want to eliminate friction and increase momentum and performance for all students, initiatives that will contribute to the elimination of our access and attainment gaps are a high priority for our university.

Our early research indicates that certain experience may create more friction for some learners than others. For instance, after submitting a WGU application, students with prior higher education experience must request transcripts before being accepted and enrolling. We found that far fewer low-income students of color were completing this process driving up to 60% of the gap in app-to-new start conversion. In response, we are piloting efforts to obtain transcripts on behalf of all students. While that should help access for all students, we expect it will have a greater impact on our Black, Latinx, Indigenous and low-income students. In addition, we’re looking for evidence of bias or other friction points in our curriculum. For instance, we are looking for course-level performance gaps between student groups that are larger than that of the average course.

Working with our operational leaders, we have identified over 1,000 potential friction points across student-facing processes. We have organized these friction points into four vectors of research:

  1. academic policies and metrics;
  2. community of care;
  3. curriculum & assessments content and design;
  4. operational transactions.

Our analytics teams will be running analyses to prioritize these friction points by expected impact and identify friction points that differentially impact students of color, women and low-income students.

(3) Intervention’s research

Over the last several years, WGU has created a set of mentor or course instructor trigger-based interventions. In addition, departments across WGU have identified over 160 grassroots initiatives to help us achieve our equitable access and attainment goals. We’ll be assessing the effectiveness of many of these efforts through our Advanced Analytics Equity Initiative to identify differential impact for different groups of learners.

Our early results have identified several initiatives that may be having a differential impact. For instance, participating in certain student groups was associated with greater increases in student success for students of color and low-income students. Awards for excellent performance on assessments similarly show greater impact for these student groups.

…participating in certain student groups was associated with greater increases in student success for students of color and low-income students.
Awards for excellent performance on assessments similarly show greater impact…

Our research is just beginning but we are committed to the road ahead. Armed with information of drivers, friction points, and interventions associated with the achievement gap we will change some experiences for all students (e.g., obtaining transcripts on behalf of all students). Other initiatives could lead to a more targeted response (e.g., greater encouragement to participate for students we expect to benefit most from student clubs). Ultimately, we’ll want these insights to contribute to ‘personalization at scale’ through a combination of our Community of Care (faculty and other student supports) and AI-enabled recommendation engines.

We know that many other institutions are pursuing similar lines of research. We’d love to hear about insights from your institution. What drivers of student success have you identified? What experiences are creating friction or momentum for different groups of learners? What have you changed in response?

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Leveraging the Strategic Planning Process for Diversity, Equity, and Inclusion Work

Post author By Lindsey Downs
Post date August 12, 2021
3 Comments on Leveraging the Strategic Planning Process for Diversity, Equity, and Inclusion Work
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Today’s post from Janelle Elias with the WCET Steering Committee working group on Diversity, Equity, and Inclusion reviews her research on how WCET member institutions are addressing equity work in strategic plans. This post continues the series started earlier this month on “Enabling Difference.” WCET leadership will continue the series throughout the month of August 2021! Thank you to Janelle for conducting this study and presenting the results to us today!

Enjoy the read and enjoy your day,

Lindsey Downs, WCET

The strategic planning process is a critical opportunity for institutions to reflect on current-state performance and outcomes, engage internal and external constituent groups, identify areas of continuous improvement, and envision roadmaps to future success. Governing and accrediting organizations expect institutions to use qualitative and quantitative data – in alignment with organizational vision, mission, and values – to drive planning and inform resource allocation. In an ideal state, strategic goals, objectives, initiatives, metrics, and targets will be explicitly defined for public consumption. Taking this lens into account, WCET was curious to understand how its member institutions are addressing the work of Diversity, Equity, and Inclusion (DEI) within their publicly documented strategic plans and initiatives in an effort to identify trends and best practices. 

The study

As of May 2021, WCET’s membership network was comprised of 395 organizations from the following sector types: Corporation (N=22); Governing/Coordinating Agency (N=36); Non-profit organization (N=29); Private, independent institution (N=75); Public, 2-year institution (N=68); and Public, 4-year institution (N=165). We selected a 10% random, stratified sampling of 41 strategic plans from the WCET membership for qualitative analysis. Member organizations from 24 states were randomly selected. 

Five organizations out of the 41 selected did not have strategic plan documents nor strategic plan web pages published, bringing the total sample size down to 36 plans. One plan was expired but included in the analysis because it was still published. The two corporate organizations did not publish strategic plans.

WCET Membership Strategic Plan Sample

Type Total sampled analyzed
Corporation  22 2 0
Governing/ Coordinating Agency 36 4 4
Nonprofit 29 3 2
Private, Independent 75 8 8
Public, 2 – year  68 7 6
Public, 4 – year 165 17 16
Totals 395 41 36

Five organizations (14% of the sample size) did not have strategic plans published.

We reviewed whatever strategic planning documentation was publicly available. In cases where a strategic plan document was unavailable, we analyzed the publicly available content on any strategic planning website. A limitation of this approach is that we understand other strategic initiatives, metrics, and targets may be established and underway that are not published on the institution’s public-facing website; however, the public-facing content may be a directional indicator of this body of work.

The variation in planning documentation is significant, ranging from a few paragraphs on the web to more than 30 pages including thoroughly quantified metrics of success. Wide variation is expected since strategic planning documentation reflects the context and culture appropriate to each institution. 

The results

We intentionally sought to study the language used to describe Diversity, Equity, and Inclusion (DEI) strategic efforts, and we assumed these terms would be used. However, we expanded our search to include the following terms:

  • Access
  • Attainment
  • Success 
  • Graduation
  • Completion
  • Diversity
  • Diverse
  • Equity
  • Equitable
  • Inclusive 
  • Inclusion

The concepts of Diversity, Equity, and Inclusion were used by all but three organizations in the sample, with “Diverse/Diversity” being referenced 222 times; “Inclusive/Inclusion” referenced 117 times; and “Equity/Equitable” referenced 110 times. In one plan, “Diversity” was mentioned 35 times.

Sum of Diversity References Sum of Inclusion References Sum of Equity References
222 117 110

As you might imagine, the terms were used inconsistently and often coupled or combined in their usage. For example, common couplings were “Equity and Inclusion” or “Diversity and Inclusion” or “Diversity, Equity, and Inclusion”. The concept of “Inclusive Excellence” was presented as a gold standard, and multiple organizations emphasized “cultural competence”. Just one organization cited “racial and cultural tolerance.”

In most cases, the terms “Diverse,” “Equitable,” and “Inclusive” were used as adjectives throughout the strategic plan to define the community, the student population, and the culture. There did not appear to be relevant distinctions by sector type. 

There were three cases (8% of the sample) where these terms of “Diversity”, “Equity”, and/or “Inclusion” were absent from strategic planning documents. In five cases (14% of the sample), institutions used Diversity, Equity, and Inclusion (DEI) terms as core values and commitments, yet there was an absence of definitions, goals, initiatives, metrics, and/or action plans. We found six institutions (17% of the sample) included definitions of the concepts; one institution shared a framework for DEI; and one organization had a diversity statement.

In five cases (14% of the sample), institutions used Diversity, Equity, and Inclusion terms as core values and commitments, yet there was an absence of definitions, goals, initiatives, metrics, and/or action plans. 

In six cases (17% of the sample), there were explicit goals focused on DEI. One organization was working on a DEI plan in conjunction with strategic planning processes, and at least three organizations indicated that developing a DEI committee/task force/council/office and producing a DEI plan would be part of their strategic initiatives. Just one institution was explicit about integrating DEI work into all other goals and objectives.

When referring to DEI goals and initiatives, the following themes emerged from the sample in order of frequency:

  • Processes for recruiting, retaining, and promoting staff and faculty.
  • Recruiting students.
  • Culture and environment.
  • Policy development and implementation.
  • Professional development and training.
  • Curriculum and co-curriculum.
  • Committee/Task force/Council/Office.
  • Action plan.
  • Pay equity.

In reviewing strategic plans, we also reviewed the concepts of “Access and Attainment” to determine if goals and targets were explicit in these areas, if they addressed DEI interests, and if they were measurable with explicit targets for success. We found 21 organizations focused on increasing access, and yet only nine of these (not even half) had published measurable targets. The eight private institutions sampled did not have goals or targets on increasing access. 

Approximately 10 times, the concept of “access” was associated with financial affordability of higher education, and organizations listed financial aid, scholarships, lowered tuition, tuition freezes, Open Educational Resources (OER), and reducing the cost of textbooks, as ways to increase access. More than five times, organizations referred to “access” as increasing technology and hybrid and online modes of delivery.

word cloud of several words from post: Access Attainment Success Graduation Completion Diversity Diverse Equity Equitable Inclusive Inclusion Underserved Under-represented Minority Female First time in college Low income

Institutions focused on increasing access for specific student populations, using a wide variety of language to describe these target populations, such as:

  • Underserved.
  • Under-represented.
  • Minority.
  • Female.
  • First time in college.
  • Low income.

In addition to setting access goals as a means of improving diversity, equity and inclusion, some institutions also focused on attainment goals. 25 institutions in this sample (nearly 70%) had explicit “attainment/completion/graduation” goals; however, only 17 of these had published measurable targets. Part of the challenge here is that institutions are measuring student success in vastly different ways. In general, institutions focused on course completion, degree attainment, transfer rates, and employment rates.

After a summer spent with some of your strategic planning documents, we observed a spectrum of approaches to diversity, equity, and inclusion within the WCET membership:

  • Some institutions made no reference to diversity, equity, and/or inclusion in their strategic plans while others embedded these concepts into their institutional values, mission, and vision.
  • Institutions often paired these concepts together and wrote about diversity and equity or equity and inclusion in their plans.
  • Many institutions created a stand-alone diversity strategic goal/initiative rather than integrating it throughout the strategic plan.
  • Institutions operationalized DEI planning work in a number of ways, including creating DEI committees, councils, task forces, action plans, and leadership structures.
  • Institutional training is an important way that schools are approaching DEI.
  • DEI audits and action plans, policies, and procedures were often cited in strategic plans.
  • DEI efforts sometimes included specific plans for improving recruitment, hiring, retention, and promotion for faculty and staff.
  • Some institutions had DEI efforts geared specifically for students including efforts around student recruitment and onboarding and other student success and completion initiatives.
  • Some, but not many, institutions had measurable DEI outcomes.
  • One institution integrated DEI throughout all goals and initiatives.
  • One institution developed a DEI agenda through the concept of “Inclusive Excellence.”

A study of the intentional language used in higher education strategic planning documents, as well as the lack of consistent language or the absence of DEI language across sector types and locations, may illustrate early stages of awareness and change in the industry. One thing is clear – planning to plan is a critical part of centering DEI work in the strategic planning process.

Best practices

Strategic plans can be powerful documents in an institution’s efforts to improve diversity, equity, and inclusion (DEI). When developing or executing a strategic plan, institutions should consider the following:

  1. Given this unprecedented confluence of internal and external factors affecting the higher education industry, especially calls for improved social justice in higher education during 2019-present, it is the ideal time to plan for the institution’s future success and to document institutional strategic resource allocation – both of which are critical when addressing DEI in strategic planning. 
  2. Define the terms associated with DEI work at your institution. This is a process of making meaning within the context of each institution’s culture. One institution published a DEI framework to increase a shared understanding. 
  3. Define what student success looks like and how it is measured. Monitor student success rates by demographic groups to ensure that you are staying focused on removing systematic barriers to success for all student groups.

Conclusion

image of quote "culture eats strategy for breakfast."

At the conclusion of this project, I reviewed my institution’s strategic plan through this renewed lens.

Our strategic plan and culture statements (mission, vision, values, and practices) make it explicitly clear that diversity, equity, inclusion, and belonging are top priorities for Rio Salado College and the driving force behind all the work we do. We also define success by an individual student’s goal attainment. These concepts are difficult to measure, yet we work hard to understand them at our institution.

There is deep, internal culture work that must occur before anyone can expect the results of this strategic work to impact equitable outcomes. Peter Drucker warned us that “culture eats strategy for breakfast” so it is encouraging to see so many institutions of higher education focus on fostering cultures that promote DEI. Through this strategic work, governance, policies, practices, curriculum, and outcomes can be improved.

Elias brings her lens as a first-generation student, with decades of higher education online education experience, and a keen understanding of how to leverage data to innovate student-centric solutions. Elias holds expertise in institutional effectiveness, change leadership, and systems development.

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Diversity, Equity, and Inclusion and Digital Learning

Post author By Lindsey Downs
Post date August 5, 2021
2 Comments on Diversity, Equity, and Inclusion and Digital Learning
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Conversations about diversity, equity, and inclusion (DEI) have recently taken center stage on many college and university campuses. Institutions are setting goals to make their campuses more diverse and inclusive and embarking on strategic initiatives to close equity gaps. Within these strategic imperatives, institutions are also explicitly exploring ways to create equitable and inclusive digital learning environments. So, what does this mean for digital learning leaders?

Definition of diversity, equity, and inclusion

Before we dive into some considerations, let us first explore some definitions. The challenge in this work is the absence of a single authoritative voice on the definition for diversity, equity, and inclusion. Throughout the month of August, WCET Frontiers will host a series of articles about DEI. In these articles, we will utilize some working definitions borrowed from the sources noted below.

Diversity is “a synonym for variety. A diversity focus emphasizes ‘how many of these’ we have in the room, organization, etc. Diversity programs and cultural celebrations/education programs are not equivalent to racial justice or inclusion. It is possible to name, acknowledge, and celebrate diversity without doing anything to transform the institutional or structural systems that produce, and maintain, racialized injustices in our communities.” (YWCA, 2016).

Equity is “the effort to provide different levels of support based on an individual’s or group’s needs in order to achieve fairness in outcomes. Working to achieve equity acknowledges unequal starting places and the need to correct the imbalance.” (YWCA, 2016).

Inclusion refers to “a state of belonging, when persons of different backgrounds and identities are valued, integrated, and welcomed equitably as decision-makers and collaborators. Inclusion involves people being given the opportunity to grow and feel/know they belong. Diversity efforts alone do not create inclusive environments. Inclusion involves a sense of coming as you are and being accepted, rather than feeling the need to assimilate” (Kapitan, 2017).

Equity vs. Equality

It’s also important to note that there is a fundamental difference between equity and equality. Whereas equality strives to provide everyone with the same resources and opportunities, equity recognizes that different people need different resources to succeed. As the George Washington University Milken Institute School of Public Health writes, “Equality means each individual or group of people is given the same resources or opportunities. Equity recognizes that each person has different circumstances and allocates the exact resources and opportunities needed to reach an equal outcome.” 

The Equity Problem – Why This Matters

Higher education, including online education, has an equity problem. The 2020 Digest of Education Statistics reports that the graduation rate for the 2012 first-time, full-time student cohort varies considerably by race.

American Indian and Native Alaskan 24.4%
Asian 52.6%
Black 23.8%
Hispanic 34.1%
Pacific Islander 31.7%
Two or more races 39.3%
White 48.3%
Graduation rate from first institution attended for first-time, full-time bachelor’s degree-seeking students at 4-year postsecondary institutions, by race/ethnicity, time to completion, sex, control of institution, and percentage of applications accepted: 2012, Digest of Education Statistics

And although there has been an increase in graduation rates across all groups, we are still left with the reality that the graduation rate of most racially-minoritized groups still lags considerably. Although comparable data for online learning is unavailable, the data that exists indicates similar challenges for online learning. For example, the California Community Colleges System’s 2017 Distance Education Report indicated that while the success rate of Black, Latinx, Native American, Filipino, and two or more races online students had improved since 2005-06, the success rate still lagged behind that of white students.

cover image of suddenly online report

We also know that the pandemic has made these inequities worse. Data released by the National Student Clearinghouse Research Center in April of this year indicates a general undergraduate enrollment decline of 5.9% and an even steeper community college enrollment decline of 11.3%. And this decline has disproportionately impacted racially-minoritized students. For example, Native American student enrollment decline was 13% while Black student enrollment declined 8.8%, and at community colleges Latinx students experienced a 13.7% decline.

And in addition to the pandemic’s impact on enrollment, it has also exacerbated the digital divide. In July 2020, Every Learner Everywhere in collaboration with Digital Promise and Tyton Partners released Suddenly Online: A National Survey of Undergraduates During the COVID-19 Pandemic. This study found that Latinx students experienced greater internet connectivity challenges (23%) than white (12%) and Black students (17%).

What’s Next – Join WCET in Enabling Difference

Fostering diversity on campus, creating inclusive learning and working environments, and erasing equity issues at our institutions is everyone’s job. This includes those of us working in digital learning environments. In the coming weeks we will share examples of how colleges and universities make DEI a strategic imperative, how data is leveraged in DEI work, and strategies to foster equity in online environments. We invite you to share your own stories as we examine these critical topics. And please join us on August 27th for a Closer Conversation on Diversity, Equity, and Inclusion in Digital Learning. Registration is free and open to current WCET members but limited to the first 50 registrations, so register now! All participants are invited to interact via video and or chat.

References:

California Community Colleges Chancellor Office. (2017) 2017 Report: Distance Education Report. Available at: https://www.cccco.edu/-/media/CCCCO-Website/About-Us/Reports/Files/2017-DE-Report-Final-ADA.pdf

Digital Promise, Every Learner Everywhere, and Tyton Partners. (2020) Suddenly Online: A National Survey of Undergraduates During the Pandemic. Available at: https://www.everylearnereverywhere.org/resources/suddenly-online-national-undergraduate-survey/

George Washington Online Public Health, “Equity vs Equality: What’s the Difference?” November 5, 2020. Available at: https://onlinepublichealth.gwu.edu/resources/equity-vs-equality/

Kapitan, Alex (2017) “Should I Use the Adjective ‘Diverse’?” Radical Copy Editor, October 2, 2017. Available at: https://radicalcopyeditor.com/2017/10/02/should-i-use-the-adjective-diverse

YMCA (2016) “Our Shared Language: Social Justice Glossary.” Available at: https://www.ywboston.org/wp-content/uploads/2016/02/MISS_VIT_BLD-SUPP-FOR-MISS_TRN-AND-DEVEL_SJ-GLOSSARY_ MARCH_2016.pdf

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New Tool Helps Leaders Leverage Open Educational Resources to Advance Equity

Post author By Lindsey Downs
Post date July 29, 2021
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Today Frontiers is excited to welcome Rebecca Karoff, Associate Vice Chancellor for Academic Affairs with The University of Texas System to tell us about the work of the DOERS3 Collaborative, specifically the OER Equity Blueprint and the Equity Through OER Rubric. WCET agrees that while higher education can see the benefits of open educational resources in many facets of our field, it’s wonderful to hear stories of how this work can advance equity and inclusion for college and universities. Thank you Rebecca for sharing these tools with us!

Enjoy the read,

Lindsey Downs, WCET

Since Open Educational Resources (OER)’s formation, the social justice origins and equity motivation have been clear—think the 2007 Cape Town Open Education Declaration. However, the individual and multiple equity dimensions of OER have been less obvious. A new tool created by the Equity Work Group of the DOERS3 Collaborative seeks to change that.

Background

The DOERS3 Collaborative is a group of 25 public higher education systems and state- and province-wide organizations committed to supporting student success by promoting free, customizable OER. DOERS3 works across member organizations to realize the promise of high-quality, accessible, and sustainable OER implementations to achieve equity and student success at scale. Leveraging their collective strength, DOERS3 members build capacity to take established OER initiatives to scale and shape national and state innovation in the areas of OER research, data, policy, accessibility, equity, and quality.

The DOERS3 Equity Work Group has spent the last eighteen months developing resources—collected into the OER Equity Blueprint—that build on growing attention to equity and contribute—we hope—to outstanding initiatives and research underway across the post-secondary sector, including WCET – the WICHE Cooperative for Educational Technologies, and its lead role in the Hewlett-funded National Consortium of Open Educational Resources (NCOER), Every Learner Everywhere, AAC&U’s OER Institute, the Achieving the Dream OER grant, and so many other impactful projects.

The OER Equity Blueprint includes a set of initial case studies, designed to share stories of OER work that advance equity, including specific initiatives, projects, research and analysis, whether completed, underway, or just beginning. We are looking for additional case studies to include, and submission guidelines can be found on the DOERS3 website.

Of course, this work has taken place in a broader national context that evolved as we developed the project. Calling COVID-19 and the country’s still incomplete reckoning with racial injustice “disruptions” doesn’t do justice to their ongoing impact, nor to their exposure of inequities—educational, health, economic, environmental—that have been in place for centuries. Yet, the pandemic and the racial consciousness-building and activism following the murder of George Floyd (and too many others), have effectively engendered a collective sense of urgency for those of us in higher education to do more, and do better in advancing equity. 

As we worked on the OER Equity Blueprint and Equity Through OER Rubric, DOERS3 members heard from the OER community: all of us need greater guidance in closing gaps in opportunity and attainment for our students, especially when it comes to race and ethnicity. OER’s capacity to drive down costs and improve educational affordability are well documented and the pandemic has sharpened our focus on digital equity. There are now phenomenal—if still under-utilized—resources available to meet the accessibility requirements for differently-abled students. Less visible has been the potential for OER to advance racial equity. Indeed, we both heard and experienced ourselves a hunger to engage equity in all its multifaceted-ness—more intentionally, deeply and holistically—across and within higher education institutions and systems, and to identify the individual and collective roles, functions, and responsibilities of practitioners and leaders.

The Equity Through OER Rubric and OER Equity Blueprint

example of the OER rubric. see oer rubric webpage for full details.

With this in mind, the DOERS3 Equity Work Group created the Equity Through OER Rubric, a comprehensive self-assessment tool designed to guide students, faculty, administrators, and other academic leaders toward better understanding and also acting on the equity dimensions of OER. With members from the university and community college systems in Colorado, Georgia, New Hampshire, New York, Texas and the Massachusetts Department of Higher Education, the creators of the Blueprint tapped into a diverse range of identities, perspectives, and institutional roles to develop guidance on how to apply an equity lens to all aspects of OER engagement.

The OER Equity Blueprint includes a set of initial case studies, designed to share stories of OER work that advance equity, including specific initiatives, projects, research and analysis, whether completed, underway, or just beginning. We are looking for additional case studies to include, and submission guidelines can be found on the DOERS3 website.

The rubric is the centerpiece of a larger project, the DOERS3 OER Equity Blueprint, which includes a theoretical and research overview, and an initial set of case studies designed to tell stories of OER work that advances equity. The Blueprint defines equity as a corrective process that demands fairness for marginalized and minoritized populations by reducing gaps in opportunity and achievement through systematic efforts. Two of the core values in the Blueprint state that:

  1. Equity and quality should be understood as constituent components of one another—inclusive, capacious, and interdependent; and
  2. Achieving equity results in increased student success in terms of access, participation, persistence, completion and entry into the workforce. Both these core values are present throughout the Equity Through OER Rubric.

The Blueprint also summarizes the growing body of research providing compelling evidence of how OER lowers the cost of education for students; deepens student learning across populations; and improves levels of persistence and completion—all of which are equity issues. Those who engage with the Equity Through OER Rubric will be able to contribute to that growing body of evidence as they work through the stages of adoption. 

Indeed, the rubric is the tangible application of the theoretical framework proposed in the Blueprint, bringing it into the practice and action realm by identifying roles and responsibilities of institutional players, and proposing levels of engagement, action, and assessment required to aid OER in fulfilling their promise. The rubric can be used to assess the institution as a whole, and/or may also be used by units and offices. It breaks down how to assess the level of OER adoption across the institution with an equity lens, based on three organizational categories: students, practitioners, and leadership.

Within these categories, rubric users can evaluate themselves based on whether a dimension is not present in their institution, beginning, emerging, or established. For example:

  • how aware of OER are students and which institutional units inform students about OER?
  • Do students have the technology to access them?
  • Who is teaching with OER and are the materials culturally inclusive and relevant?
  • How do institutional leaders take responsibility and how are they held accountable for progress on OER equity goals?
example portion of the OER equity rubric. For more details please see the webpage.

As users engage with the rubric, they can determine where their institution is doing well and where it can improve as they move across the stages of adoption to leverage OER in support of equity across multiple dimensions.

While institution-focused, we believe there are a lot of actionable components for university systems, organizations, and SHEEOs. The rubric seeks to make clear that all stakeholders have leadership roles to play in advancing equity through OER and invites higher educators to use it to both recognize and honor their commitment to equity, as well as evaluate progress and act on those areas identified as requiring additional focus and effort. Given that OER engagement is still nascent at many U.S. institutions of higher education, where resource constraints are all too real, the established stage will remain aspirational for many.

The holistic planning embedded in these stages is intended as a blueprint for reaching equity by correcting the gaps in opportunity and achievement through systematic efforts. Moreover, the rubric’s comprehensive approach provides a blueprint for quality OER—by and for students, practitioners and leadership, with assessment, accountability, and continuous improvement built in.

Next Steps for our Work

The next phase of the work entails seeking institutional partners who would like to pilot the rubric with us, and we already have a number of potential partners, including WCET members. We are working now on formalizing the pilot process, one which we know will enrich the rubric and engage more stakeholders—including administrators and leadership—in that more intentional support of equity through OER. The rubric is open, and we look forward to seeing how higher educators will adopt and adapt it. We also recognize the current version inevitably has blind spots–regarding populations of opportunity and intersectional identities not adequately attended to, as well as neglected dimensions of quality OER implementation. We will keep WCET and others informed as we issue a call for pilot partners in coming months.

Rebecca Karoff
Associate Vice Chancellor for Academic Affairs
The University of Texas System
rkaroff@utsystem.edu

About Author

Dr. Rebecca Karoff leads systemwide student success initiatives at The University of Texas System as Associate Vice Chancellor for Academic Affairs. Her work addresses the student success continuum, PK-20 and into the workforce, and recognizes the remarkable responsibility and opportunity of the University of Texas System to achieve more equitable access and outcomes for the state’s increasingly diverse students. She leads the UT System’s momentum-building strategy on Open Educational Resources (OER), emerging initiatives on curricular innovation, and engaging faculty in embracing their roles in student success.  She is a co-author of the NASH Equity Action Framework, a tool designed for university systems to assess their progress toward, and she chairs the Equity Work Group of DOERS3, the Driving OER Sustainability for Student Success Collaborative, resulting in the OER Equity Blueprint and Equity Through OER Rubric. 

 

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Policy

Institutional Compliance by August 1, 2021 – When Serving Students Receiving Veterans Benefits

Post author By Lindsey Downs
Post date July 21, 2021
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Institutions that offer programs to students who utilize Veterans Benefits must be aware of institutional compliance requirements that are to be observed by August 1, 2021. Our colleague Leah Matthews, Executive Director and CEO, Distance Education Accrediting Commission (DEAC), joins me today to explain what the law is and to highlight several sections institutions that serve veterans must address immediately.

Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020

Isakson and Roe became federal law on January 5, 2021. The purpose of the law is described in the law’s preamble:

“To provide flexibility for the Secretary of Veterans Affairs in caring for homeless veterans during a covered public health emergency, to direct the Secretary of Veterans Affairs to carry out a retraining assistance program for unemployed veterans, and for other purposes.”

Title I of Isakson and Roe addresses Education, and adds new requirements for educational institutions participating in the educational assistance programs of the Department of Veterans Affairs (VA). We will address 2 of the 24 Sections of Title I – EDUCATION; Subtitle A – Education Generally, for which we believe institutions should review and seek additional guidance:

military officers walking in front of a body of water
Photo by Pixabay on Pexels.com

We are aware that institutions have been seeking compliance guidance. Veterans Services offices have offered training for the School Certifying Officials (SCO’s), but clarification is still needed. At the June 14-15, 2021, Council of College and Military Educators (CCME) Annual Symposium, Charmain Bogue, Executive Director of the Educational Services Veterans Benefits Administration, indicated that they are aware of the many questions about implementation of the 30 provisions found in Isakson and Roe. She expressed that it is their intention to offer guidance including a waiver process and indicated that it is not their intention to disapprove schools on August 1 as institutions are working to come to compliance. Charmain Bogue provided testimony titled “Isakson-Roe at Six Months—An Update on Implementation of Education Improvements” in a July 20, 2021, hearing of the House of Representatives VA Committee.

Guidance Offered by Veterans Services

Guidance on both sections was emailed to institution School Certifying Officials in July 2021. The complete content of these emails is not currently available on the Isakson and Roe Veterans Health Care and Benefits Improvement Act of 2020 webpage, however we have included the guidance below. The email on July 13, 2021 provided guidance addressing Section 1018. The email on July 19, 2021 provided guidance addressing Section 1015.

Section 1015

On July 19, 2021, School Certifying Officials received important guidance on Section 1015 of the Johnny Isakson and David P. Roe, M.D. Veterans Health Care and Benefits Improvement Act of 2020. Section 1015 established the new requirement for accredited institutions to be approved and participate in the Department of Education’s (DoE) federal student aid programs in order to continue to participate in educational assistance programs offered by the Department of Veterans Affairs, such as the GI Bill. This change essentially resulted in an amendment to Section 3675 of title 38, United States Code, in subsection (b) by adding a new paragraph:

“(4) The educational institution is approved and participates in a program under title IV of the Higher Education Act of 1965 (20 U.S.C. 1070 et seq.) or the Secretary has waived the requirement under this paragraph with respect to an educational institution and submits to the Committee on Veterans’ Affairs of the Senate and the Committee on Veterans’ Affairs of the House of Representatives notice of such waiver.”

And also by adding at the end the following new subsection:

‘‘(d)(1) The Secretary shall submit to Congress an annual report on any waivers issued pursuant to subsection (b)(4) or section 3672(b)(2)(A)(i) of this title.

2) Each report submitted under paragraph (1) shall include, for the year covered by the report, the following:

(A) The name of each educational institution for which a waiver was issued.

(B) The justification for each such waiver.

(C) The total number of waivers issued.

(b) REQUIREMENT FOR APPROVAL OF STANDARD COLLEGE DEGREE PROGRAMS.—Clause (i) of section 3672(b)(2)(A) of such title is amended to read as follows:

(i) Except as provided in subparagraph (C) or (D), an accredited standard college degree program offered at a public or not-for-profit proprietary educational institution that—

(I) is accredited by an agency or association recognized for that purpose by the Secretary of Education; and

(II) is approved and participates in a program under title IV of the Higher Education Act of 1965 (20 U.S.C. 1070 et seq.), unless the Secretary has waived the requirement to participate in a program under title IV of the Higher Education Act of 1965 (20 U.S.C. 1070 et seq.).’’

Institutions that are accredited by an agency recognized by the U.S. Department of Education but do not currently have a Program Participation Agreement with the U.S. Department of Education to participate in Tile IV federal student aid will need to ensure that they obtain and fulfill the waiver requirements set forth by Veterans Service guidance on July 19, 2021. The VA, however, has made it clear to School Certifying Officials that there is no expectation of immediate disapproval on August 1, 2021 when PL 116-315 Section 1015 is to become effective. Once an institution has submitted a waiver request, it will be placed in a “pending waiver decision” status. No adverse action under section 1015 will occur while a request for a waiver is pending a decision from the Department of Veterans Affairs (VA). All waiver requests will be considered by VA on a case-by-case basis and institutions should not assume that a waiver will be granted.

To request a waiver, submit an email to VBACOSECTION1015WAVR@va.gov. The waiver request package must include a cover letter on the organization’s letterhead requesting approval for an Education Service Waiver under 38 U.S.C. §§ 3675(b)(4) and 3672(b)(2)(A)(i)(II). The request must include the following information:

An open envelope sitting on top of a letter
  • Date of last application for participation in the Federal funded student financial aid through the Department of Education and the result of that application;
  • If the school has a currently pending Program Participation Agreement with the Department of Education and proper documentation of the submission (VA may verify this submission with the Department of Education); and
  • Enumerated list of the specific provisions of Title IV with which the institution is unable or has chosen not to comply. For each non-compliant provision, a reason or justification for non-compliance.

For those institutions that are accredited and currently have a Program Participation Agreement with the Department of Education, it is expected Title IV eligibility and participation continue beginning August 1, 2021. If eligibility is lost or participation ceases at any point after August 1, 2021, a waiver would need to be sought to continue GI Bill® eligibility.

Section 1018

Guidance addressing Section 1018 was emailed from state veterans services offices to the institution School Certifying Officials on July 13, 2021.The guidance describes Section 1018 as follows: “Many of the requirements are consistent with the requirements of the Principles of Excellence, currently in Executive Order 13607; however, there are requirements in addition to those embodied in the Principles of Excellence which schools must also satisfy to maintain approval for GI Bill® participation”.

The guidance provides an opportunity for the institutions to seek a waiver if the institution cannot satisfy the requirements of Section 1018 by August 1, 2021, the institution must apply for a waiver by August 1, 2021. Institutions should note the following:

  • Waiver process is described in the guidance.
  • Upon submission of the waiver request, the institution will be on pending waiver decision status.
  • No adverse action under Section 1018 will occur while the request is pending.
  • If waiver request decided favorably, it will be for 1 year period not to exceed one year beginning Aug 1, 2021.
  • If waiver request decided unfavorably, it will be reported to the State Approving Agency and a caution flag will be added to the GI Bill comparison tool.

Despite Ms. Bogue’s testimony indicating that the VA “communicated the requirements to schools and State approving agencies on several occasions and held an “Office Hours” training event for School Certifying Officials (SCO),” there are two items that remain unclear after the Veterans Services guidance for Section 1018.

First, the first part of Section 1018 includes a list of notifications that must be provided directly to the student prior to enrollment. Item 9 on the list of notifications addresses courses leading to a licensed or certified occupation. The notification requirement in the new law, for purpose of Veterans benefits, is described differently than professional licensure program notifications required by 34 CFR 668.43 (a)(5)(v) and 668.43(c) required for compliance to participate in Title IV HEA programs. Institutions should note that these are different requirements to provide different benefits to students.

Isakson and Roe requires the institution to provide:

“any additional requirements including training, experience, or examinations that are required to obtain a license, certification or approval for which the course of education prepares the individual.”

It appears that the notifications must include more than educational requirements, but the terms “training” and “experience” do not provide clear parameters of what is being asked. Additionally, we are wondering if the student is located in a different state, what state’s information should be shared? The guidance did not address interstate activity nor any more specificity regarding the parameters of this notification. This specific notification is not described in the original Principles of Excellence, in order for us to obtain direction.

Second, in a later portion of Section 1018, the guidance indicates: “Accredited educational institutions agree to obtain approval of the respective accrediting agency for each new course or program.” It appears that the author of the guidance attempted to summarize this portion of the law, but in doing so, created an obligation that is beyond what is required by accreditors.

The law itself states (bold lettering for emphasis):

“(F) With respect to an accredited educational institution, obtain the approval of the accrediting agency for each new course or program of the institution before enrolling covered individuals in such courses or programs if the accrediting agency determines that such approval is appropriate under the substantive change requirements of the accrediting agency regarding the quality, objectives, scope, or control of the institution.”

Please note that the law indicates this requirement under a specific circumstance despite the guidance seemingly indicating required approval for EVERY new course of program.

This is an example of how institutions should read the specific language of the law as the guidance is secondary authority to the law. If there is conflict of language, the law itself is the primary authority.

Our Suggestions for Institutions

With the deadline looming at the end of the month, we urge institutions serving students who obtain Veterans Benefits to do the following:

WCET will continue to follow this topic and provide updates if we receive them. If you have additional questions let us know!

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Practice

Credential Transparency and Informed Decision-Making in Indiana

Post author By Lindsey Downs
Post date July 16, 2021
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We, at WCET, often hear how institutions and state systems are being pushed by state leaders to be more attentive to state workforce needs. We also hear about the innovations that are happening in the many types of postsecondary credentials that are now available. We are pleased to have as our guest, our friend, Ken Sauer from the Indiana Commission for Higher Education. With Ken’s help, Indiana has been a leader in thinking about how consumer needs in the confusing credentials market and transparency about what is being offered. Ken shares Indiana’s advances in partnering with Credential Engine. Good work Ken and thank you for sharing!

 -Russ Poulin, WCET

Because postsecondary education is not compulsory, it functions like a market. To function well, markets require sufficient and reliable information, upon which to base decisions, hence the need for credential transparency.  

Here “credentials” refers to any award that signifies mastery of a set of competencies by the person earning the award, including diplomas, certificates, and degrees as well as certifications, badges, other micro-credentials, licenses, apprenticeships, and military training. “Transparency” refers to the ability of anyone – learner, policymaker, or other stakeholder – to easily access, navigate, and compare as much information as possible, all in a common language, about credentials of interest.

Indiana is committed to credential transparency. For more than four years has looked to Credential Engine and its Credential Transparency Descriptor Language (CTDL) as the means and common language to achieve this goal. Initiated by the Indiana Commission for Higher Education (the “Commission”), multiple state agencies and all public colleges and universities are now working in partnership to further credential transparency.

Efforts to date have focused on publishing a critical mass of information to the Indiana Credential Registry (the “Registry”), a state-specific subset of the national Credential Engine Registry. While much data has already been published, and more information is continuously being added, increasing attention is now directed to integrating the data in the Registry with existing tools that help prospective students and other learners to think through their career goals and find education and training programs to achieve those goals.

Data Already Published or In Process

As the state postsecondary education coordinating body, the Commission was well positioned to jump start scaling up the Registry by publishing, initially on behalf of the institutions, a set of basic information about all certificate and degree programs at both the undergraduate and graduate levels offered by all public two- and four-year colleges and universities…some 3,000 programs. We also have two Indiana independent universities on the Registry, as well as one proprietary university, and would like to have the remaining two dozen Indiana independents on as well.

This basic data included the program name, a description of the program, a URL to a departmental or program-specific landing page, the number of credit hours required to complete the program, tuition and fee information, institutional accreditation, and whether the program was offered through distance education.

With this foundation in place, attention shifted to publishing additional data about programs:

  • Specialized Accreditation. This is an important indicator of quality, so the Commission began by publishing the specialized accreditation held by programs in engineering, nursing, social work, dental hygiene, athletic training education, nutrition and dietetics, and clinical laboratory sciences. Other specialized accreditations are steadily being added through institutional efforts and visiting web sites of selected accrediting agencies.
  • Licensure. In partnership with the Professional Licensing Agency, the state’s umbrella agency for most licensing boards, twenty health-related licensing boards, and the 47 licenses they issue, were added to the Registry. Links have been published between State Board of Nursing approved nursing programs and the LPN and RN licenses they qualify graduates to earn. We will do the same thing for the other health and non-health licensing boards/licenses and the education programs that prepare graduates to become licensed. Something similar is being done in tandem with the Department of Education, which is responsible for licensing teachers in Indiana. Working with the State Board of Nursing, we have also published pass rates on the NCLEX exams on the Registry; we intend to do the same for other fields where licensure exam results are available.
  • Return on Investment. The Commission, the Indiana Department of Workforce Development (DWD), and the state’s Management Performance Hub have generated earnings data for graduates of all programs one, three, five, and ten years after graduation. We are in the process of publishing this data for all programs whose data was not suppressed due to small cohort size.
  • Transfer of Credit. The Indiana College Core, a 30-semester hour general education core based on competencies, and some 20 Single Articulation [2+2] Pathways, also competency-based, all of which transfer statewide throughout the public sector, have been published to the Registry.
  • Competencies. The most important of the 500+ CTDL Descriptors is one describing the competencies a credential holder is supposed to have mastered. Ivy Tech Community College, Indiana’s statewide community college system accredited as a single institution, has published competencies for all of its associate degrees and is doing the same for its certificate programs. Purdue University Global has also published competencies for all of the degree programs it offers. Our goal is to publish competencies for all programs offered by public institutions.
  • Eligible Training Provider List (ETPL). While colleges and universities are at the center of our educational and training ecosystem, non-traditional, non-collegiate providers can also provide a valuable entry into employment and a foundation for further education. Indiana’s DWD is committed to publishing the ETPL to the Registry, and Indiana is piloting the Education Equity Outcomes Standards (EQOS) framework to assure the quality of these non-traditional providers.
  • Certifications. Industry and professional certifications valued by employers can represent important credentials for career mobility, both at the entry and advanced levels. Working with other states, Credential Engine, and organizations like Workcred and Advance CTE, Indiana is committed to expanding the certifications published on the Registry, including those on DWD’s list of Promoted Certifications, and connecting those to the education and training programs that prepare learners to earn them.
  • High Schools. Some 64 percent of recent Indiana high school graduates completed their secondary education while also earning postsecondary credit. Indiana’s extensive, well-supported dual credit system is focused on making it possible for high school students to complete before they graduate:
    • postsecondary certificates,
    • the Indiana College Core. and/or,
    • certificates available through our Next Level Programs of Study, as Indiana CTE programs are currently called.

An important element of this initiative is to be clear about which high schools meet the criteria to be listed as delivery sites for the Indiana College Core. Being listed will encourage other school leaders to consider how they too might meet these criteria, thus expanding dual credit opportunities. To that end, we have published more than 90 high schools on the Registry, which currently meet these criteria. In partnership with the Governor’s Workforce Cabinet, the Commission will also publish career centers that make available postsecondary CTE credentials.

Using the Registry

Image by Pexels from Pixabay

As a pioneer scale-up state, much of Indiana’s emphasis over the past four years has been devoted to refining and expanding data published to the Registry, which now represents a unique and rich source of information about Indiana’s education and training ecosystem. While much more data remains to be published, our attention is now turning to how learners of all ages can equitably access this data and use it effectively for informed decisions about how to achieve their career and personal goals through education and training. To that end, Indiana’s newly licensed statewide Career Explorer software will point to the Registry for information about education and training.

Digital Credentials

Through a long-standing partnership with Parchment, Indiana has a mature Indiana e-Transcript Program, which is universally used at the high school-to-college level (200,000 transcripts sent annually) and is now being implemented at the college-to-college level. Ivy Tech Community College has licensed Parchment’s Award Diploma Services product that permits all its graduates to be issued a digital credential, which has a navigation link to the Registry and allows an employer to access all the information about the credential and the College that has been published to the Registry, including the competencies associated with that credential.

Concluding Thoughts

Credential Engine has revolutionized the way we think about credentials and increased exponentially our ability to transform previously isolated data into linked, open data. Our state’s commitment to break down data silos has also helped catalyze inter-agency collaboration to unprecedented levels. Indiana’s embrace of credential transparency aims to give learners the information they need to make informed decisions about educational choices.

Ken Sauer
Senior Associate Commissioner and Chief Academic Officer
Indiana Commission for Higher Education

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Practice

The Promise of Blockchain in Education

Post author By Lindsey Downs
Post date July 8, 2021
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Today’s blog is a conversation with a Feng Hou, Founder of Pistis.io and Chief Digital Transformation Evangelist at Maryville University. Feng talks about the power, potential, and application of digital ledger technology, i.e., blockchain, in education. Feng’s a visionary who has taken the promise of the digital ledger technology into practice by developing an open access blockchain solution.

Blockchain is an abstract concept for many of us. In a 2019 WCET Frontiers Blog we explained the concept:

“Blockchain is the technology that supports a distributed ledger, the data can be distributed but not copied and has only one owner. According to a Mission.org blog:

 “The information is constantly reconciled into the database, which is stored in multiple locations and updated instantly. That means the records are public and verifiable. Since there’s no central location, it harder to hack since the info exists simultaneously in millions of places. Blockchain technology was invented in 2008, but only came into the public conversation when Bitcoin launched.” ~ Paul Dughi.”

Now for the conversation with Feng, who is also WCET’s July Ask the Expert and contributor of the upcoming Closer Look guide, both will be available to WCET members in wcetMIX our virtual, member-only community. If you are a WCET member and interested in joining the Ask the Expert community, let us know.

Megan Raymond, WCET

Q & A with Fend Hou

Question: You have had quite the circuitous journey through education, how did you get involved with blockchain?

a series of connected computers
Image by Tumisu from Pixabay

I have held numerous leadership roles in higher education and consider it my calling. In my roles as CIO, Chief Digital Learning Officer, and now Chief Digital Transformation Evangelist at Maryville University in St. Louis, I have had the unique opportunity to work with and implement some innovative solutions such as blockchain technology all for the betterment of the student experience, institutional efficiency, and cost savings.

Working with blockchain, I immediately recognized the tremendous and transformative potential for education. I have been on the front lines supporting both the faculty and the student’s IT needs. I experienced firsthand the disappointment of not having access to information people needed. I have seen and we all recently experienced the pain, the vulnerability and sense of hopelessness when our information has been ransomed, altered, or inaccessible.

Living through this drove me to find an answer. I was part of the early design and architecture teams to make a breakthrough with blockchain in higher education. I shared their frustrations on the slow progress made in this area. Sometimes it was surprising how quickly discussions bogged down on just defining and establishing standards. I am thrilled that WCET is providing this opportunity for us to discuss what blockchain can do for higher education with many practical use cases.

Question: Once you dedicated your talents and energies to blockchain, what were the next steps in the journey like? I imagine there were some ups and downs and friends and foes.

As the founding Chair of Education Blockchain Architect (EASIS) under the Linux Foundation, and the current Chair of Education Vertical under Blockchain Chamber of Commerce, I have been invited to the White House, the U.S. Department of Education, as well as T3 Innovation Network under U.S. Department of Commerce and Chamber of Commerce to discuss blockchain solutions for education. I continued to see my fellow educators anxiously looking for answers on how to address security and preserving the integrity of student records and other sensitive information as we all know how easy it is to manipulate credentials, falsify qualifications, or worse, have your identity stolen.

Since I am doer, when I saw the need for blockchain in education, I took actions and co-founded a blockchain service company called Pistis.io Inc. I fully understand some perceptions that blockchain is still aspirational and too early on the adoption curve, there are early adopters like Maryville University, Oral Roberts University, MIT, and Central New Mexico Community College, just to a name a few, that have proven the value of using blockchain and smart contract to transform their student digital experience, dramatically improve their institutional efficiency and reduce operational costs.

There are on-going discussions and debates on establishing a learner record which has led to some confusion, if not some turf wars. Another directional challenge is either a school should join some consortium or “blockchain ecosystem,” create an open access system not tied to any institution so that learners can own and control their credentials. The SSI (Self-Sovereign Identity), an international guideline, states that learners should own their credentials.

I agree with SSI because some of the solutions today continue to limit or restrict access unless you are part of an institution that happens to belong to a blockchain consortium. What happens when you switch schools, graduate, and go onto graduate school, or forego and get specialty training or online self-certification courses? In a closed system/institutional access, whatever you accomplished is tied to that institution or could be potentially lost because it was never captured. This tension helped stoke my desire to make a difference and help spur the universal adoption of blockchain which is open access and agnostic to the platform on which the blockchain was designed.

Question: Transcripts seem like the logical first implementation of blockchain, being a distributed ledger leads to a highly secure, immutable, learner-owned record. Talk more about how blockchain is being used in this capacity.

Yes, another key driver for blockchain in education is addressing the security of credentials that are received, and the time, expense, and resources needed to manually verify all sources of content. Institutions receive 10s of thousands of applications and its resource intensive to attempt to verify every item. Even if we wanted, requesting transcripts, particularly for international students, is next to impossible with potentially weeks, if not months, of turnaround.

Image by chenspec from Pixabay

Distributed ledger technology empowers learners by providing access and ownership to their learner record. As learners gain skills and credentials the blocks continually build and showcase the depth and breadth of knowledge acquired. Additionally, the learner maintains control over who they share the record with. There is potential to democratize the transcript and employment process.

What we have done at Maryville University is to implement an on-demand blockchain transcript solution that takes only five seconds to put transcripts at the learner’s fingertips whenever they need them. For all learners and particularly the digital natives, this has been a game changer because the transcripts are secure, immutable, readily verifiable, and shareable, and they only need to request the transcript once. And that’s not all – since the entire transcript request process is automated, it has reduced the time for the university staff to support the students; it has also saved the costs by more than 50% from other transcript service providers.

Question: Where are we at now with blockchain in education?

I am happy to share that there are many blockchain initiatives that are going on in higher education today. At the beginning of the year, ACE announced their first round of blockchain initiatives and listed Pistis.io as one of the national blockchain resources. I am also thrilled to see that our federal government including the U.S. Department Education and U.S. Department of Commerce, along with ACE and the U.S. Chamber of Commerce, have started their blockchain initiatives such as the T3 Innovation Network. Pistis.io is currently running a pilot to let lifelong learners post their own learning artifacts including video clips, soundbites, and even executable programming codes on blockchain as verifiable credentials. Many national and regional organizations such as Blockchain Chamber of Commerce, where I serve as the Education Vertical Chair, Colorado’s C-Lab, and the Learning Economy Foundation, as well as the newly founded Texas Blockchain Council, etc., have all been promoting blockchain adoption in higher education.

While many of those blockchain initiatives are focused on credential record keeping and sharing, which are important, early blockchain adopter schools such as Maryville University have leapt forward to leverage smart contracts to automate student services and manage hiring and vendor contracts. With the recent publicity about NFTs (non-fungible tokens), which is basically a blockchain token that certifies something to be unique, there is now new interest to use tokens to track student learning, job seeking, and even possibly financial aid and the use of cryptocurrency and NFTs as donations and gifts, etc.

The COVID-19 pandemic only exacerbated the strain on resources and budgets with many schools that are in cost containment and cutbacks. The true cost efficiencies of blockchain are being realized, and the speed and performance of the technology, at less than ten seconds, coupled with the data security, is unparalleled.

Blockchain can help create open access to address the urgent needs for Diversity, Equity, and Inclusion initiatives, as learners will have lifelong free access to their learning credentials that they own and control. Learners can post and use what they believe to be the best way to show their talents and skills to prove what they know instead of where they went to learn it. There is no restrictions and boundaries, learners own their credentials, which can be verified and shared instantaneously when and where they need it.

Question: What’s next for blockchain in education?

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Image by Pete Linforth from Pixabay

Allowing students to truly own their credentials. How can our students differentiate themselves against the millions of unemployed with years of experience? How do they compete? What if we can highlight with verifiable examples of soft skills and expertise beyond just a course description or what is written on a resume. How about giving students the ability to securely capture their unique capabilities, learnings, and experiences? What if they can provide a portfolio showcasing these learnings through computer executable files, audio recordings, pictures, and video recordings all stored safely and securely on blockchain? Then allow them to access 24×7 and share with whomever and whenever they wish. They now have a fighting chance to compete in the corporate world, truly democratizing the education and employment process.

What seemed impossible just a year ago is happening. Job seekers can apply immediately for jobs, learners can transfer to another school, advance to higher degrees, and capture their self-certifications. Imagine the empowerment of having the ownership of your information and the ability to share it with whom you want and when you want it every day of the year.

Question: What’s next for you and Pistis.Io?

Well, we created Pistis.io to be a partner with higher education institutions and education organizations, such as WCET, to introduce, share, promote, and help implement blockchain solutions. That has been my passion and I have been really fortunate to have had the opportunity to share the success stories of Maryville University on the national stage, as well as to assist many schools to start their own blockchain journeys. And I intend to continue doing so.

pistis.io logo

As for Pistis.io, we are about to launch NFT4Education.com, which provides a blockchain platform for anyone who wants to share, trade, and donate their knowledge and IP based products and services; and as its name suggested it is dedicated to education.

NFT is a simply a blockchain token where creator’s ownership is recognized and kept in the metadata It is immutable. Since student learning experiences and instructor teaching methods are unique, they can be tokenized and shared. Also, imagine receiving a piece of artwork as a donation to the school. What if you created an NFT of a piece of art and it grew in value exponentially, adding much needed revenue and funds for the school? Or providing authorship and attribution to open education resources?

Pistis.io has developed the smart contract engine and is creating a Smart Contract as a Service model for schools to use these tools as a “plug and play.” You can take any process, no matter how complex or how many different departments that it will touch, and convert a week or months of manual, and costly workflow processes into seconds. Yes, you heard it right! Seconds. Hiring faculty or adjunct faculty, the entire process handled in second. Payment agreement plans, study abroad, leaves of absence, and more, again, automated to a matter of seconds.

We think higher education institutions have done a wonderful job, particularly during the COVID-19 pandemic, to help their students achieve their educational goals. With the help from digital technologies such as blockchain, institutions can now offer their students secure, immutable, verifiable, and shareable learning credentials all in seconds.

Thank you so much to Feng for this amazing interview! This post officially kicks off WCET’s Blockchain Month, sponsored by Pistis.io! All month long we will be sharing new content about the promise of Blockchain to digitally transform higher education WCET members can look forward to special events, new resources centered on this topic, and more! Not a member? Learn more about WCET membership so you, and all staff at your organization, can access these and our other great member-only resources!

Thank you to Feng Hou and Pistis.io for participating in Blockchain month and for sharing your insights in today’s post.

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Policy

One Year Anniversary of the Federal Regulations for Professional Licensure Notifications – How are you Celebrating?

Post author By Lindsey Downs
Post date July 1, 2021
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Maybe it is a little cheeky to say celebrating, but we are all on this crazy journey together to manage these institutional requirements. The federal regulations require notifications in order for institutions to participate in Title IV HEA programs, and SARA closely aligned their requirements to the Federal regulations for SARA participating institutions to address programs subject to SARA policy. Our colleagues, Jeannie Yockey-Fine with NC-SARA and Shari Miller with Institutional Compliance Matters are back with me again today to help me celebrate this anniversary by sharing the notifications story including the purpose, what is required, the history, challenges, a wish list to help with compliance, and resources to help with compliance management.

Purpose

The purpose of these notifications is transparency to protect and support students pursuing a required professional license or certification to be employed in an occupation. In this 21st century mobile society we see student movement to other states to enroll face-to-face in licensure programs as well as increasing numbers of licensure programs provided by distance education to students living across the country. With the varying educational requirements in each state for each profession, the students are at risk of not completing necessary educational requirements in a state in order to obtain a license or certification. The age-old notion of completely placing the responsibility on the student to research the requirements in a state is no longer acceptable, as the stakes are too high.

What is Required?

Analysis of the federal regulations has been provided through many WCET|State Authorization Network available resources and WCET Frontiers posts. However, along with the analysis, you are strongly urged to review the specific language of the federal regulations, 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c), regarding institutional notifications for educational programs leading to a license or certificate.

A snapshot of the four key elements of the notification requirements:

a person studying while sitting on their bed.
Photo by Sincerely Media on Unsplash
  1. Notifications are for educational programs delivered by all modalities (includes face-to-face!),
  2. The type of educational program is defined in the regulation (designed for specific professional license required for employment or advertised as sufficient in a state).
  3. Public Notifications regarding the curriculum meeting state educational requirements in ALL states (list of states does, does not, or no determination made about the curriculum meeting state educational requirements).
  4. Direct Notifications in writing and individualized to the student and their location (to prospective students, if does not meet or no determination. To enrolled student, if does not meet).

Additionally, for purposes of programs subject to SARA policy, the institution must additionally comply with SARA Manual Section 5.2. Institutions participate in SARA to obtain state institutional approval through reciprocity to offer distance education in other SARA member states. Although reciprocity through SARA does not extend to professional licensing requirements, SARA participation requires that institutions satisfy all federal requirements for notifications as described above. This requirement applies to non-Title IV institutions, as well. Additionally, SARA policy directs that when institutions are unable, after all reasonable efforts, to determine if the curriculum meets state educational requirements, the institution must provide the current contact information of the applicable licensing board where the student is located and advise the student to make a determination.

How did we get here?

Federal Regulations

During the Department’s negotiated rulemaking in 2014, the committee addressed notifications for licensure programs. Specifically, the committee considered notifications regardless of modality and the requirement of a written acknowledgment that the student understands if the program does not fulfill the educational requirements in the student’s state. This rulemaking did not come to consensus. However, it was the basis for the Department to write the notifications rule that was released in December 2016 at the end of the Obama administration.

The state authorization and notifications regulations released in December 2016 were fraught with problematic issues, to say the least. The regulation addressing professional licensure notifications 34 CFR 668.50 required notifications for programs solely offered by distance education and were focused only where the institution’s enrolled students reside. Individualized disclosures were required if the program did not meet licensure prerequisites. The new regulation maintained the negotiated rulemaking committee’s idea to keep the required written student acknowledgment if the curriculum did not meet state educational requirements where the prospective student “resides.” We could talk all day about the challenges for implementation of these regulations caused by the language.

Because the regulations were released after November 1, 2016, the regulatory calendar required that the effective date of these regulations not occur until July 1, 2018. During that time, there was little information coming out of the new Trump administration in terms of guidance despite many inquiries and the Department’s request for public comment on regulations to be reviewed and revised. As the regulations were about to become effective in July 2018, the Department delayed the rules for review and revision. New rulemaking was announced in August 2018 and came to consensus in April 2019. Just weeks after consensus, while were awaiting release of the consensus language as proposed regulations, a U.S. District Court in California ruled that the Department’s delay of the previous federal regulations be vacated. This was a long story about procedural error, but the flawed and painfully difficult to implement regulations became effective starting in late May 2019.

The first package of regulations, which included the professional licensure notifications, was released in June 2019 as proposed regulations subject to public comment. The final regulations were then released by November 1, 2019 to meet the regulatory calendar requirements to become effective the following July 1, 2020. Additionally, the Higher Education Act (HEA) provides the Secretary with the authority to designate new regulations for early implementation. The state authorization and professional licensure notifications regulations were designated for early implementation giving institutions the choice to comply with the new regulations or the then current flawed regulations that became effective due to the U.S. District Court ruling. On July 1, 2020, the professional licensure notifications, as previously described in this article, became the only set of regulations for which institutions must comply to participate in Title IV HEA programs.

SARA Requirements

Throughout the series of events described to develop the federal regulations, institutions that participated in reciprocity for state institutional approval through SARA were already required to provide notifications to students for the courses and programs subject to SARA policy. Although SARA has no effect on state professional licensing requirements, the institutions have always been required to provide licensure notifications through SARA policy and affirmation on the SARA application.

Initially, SARA required that institutions provide a written notification to all students, applicants, and potential students whether the course or program meets the requirements for a state license. If the institution could not confirm whether the program met the requirements, the institution was required to provide the current contact information for the applicable licensing board and advise the student to make a determination.

With the federal regulations becoming effective in July 2020, the NC-SARA Board voted to more closely align the SARA notifications with the notification requirements of the new Federal regulations. SARA Manual Section 5.2 requires that the institutions follow 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c) for Title IV and non-Title IV institutions. SARA institutions must now provide general disclosures that were not a requirement before. Additionally, the SARA policy maintained their previous requirement of providing, in the direct notification, the current contact information for any applicable licensing board if the institution is not able to determine if the institution’s curriculum meets the state educational requirements where the student is located.

Challenges

Research

Research of out-of-state requirements for licensing boards and the challenges of providing the related disclosures has been the topic of many discussions and webinars. The first consideration is to review the regulation closely to determine which programs will require disclosures. Institutions have been creating varying strategies for determining whether their programs will meet requirements in other states. Because this research cannot be completed quickly, some institutions begin with the states that have the most students, or with the programs with most enrollments, or both.

The success of the research can depend on many variables. These can include clarity of the statutes and regulations at the state level, the willingness and availability of staff at the licensing boards to answer questions, and the size of the institution’s compliance team. Creating a process to determine requirements and following that process will be key in making these determinations, and for SARA purposes, meeting the “reasonable effort” requirement.

Institution Buy-in and Collaboration

In addition to determining a process for research, an additional challenge is creating awareness and understanding at departments outside the compliance staff at your institution. Creating a process that is understood and followed, by admissions, marketing, information technology, compliance, those creating curriculum and others will be key.

Tracking Student Location

None of the processes mentioned above will work without careful tracking of where your students are located prior to a financial commitment to the program and when they enroll in these programs.

Tracking of students is essential for state authorization and professional licensure purposes, and a defensible process for knowing where your students are is required. Many institutions have created a policy of checking every term. A process for periodic review for tracking as well as licensing requirements will be essential.

Wish List to Help with Compliance

Because it’s anniversary time, we have chosen to compile a wish list of information and tools that we believe would be of great use for institutions as they continue to move towards compliance with the disclosure requirements.

Guidance from the Department of Education:

The first wish that is shared uniformly by institutions is practical guidance from the Department of Education. While the regulations were generally straightforward, as institutions strive to be in compliance, they may encounter circumstances that are not necessarily addressed as clearly.

Triad Balance:

someone writing a list in a notebook
Photo by @glenncarstenspeters on Unsplash

The triad in education is, in theory, where balanced regulatory oversight is provided by the federal government (via the Department of Education), the state government and the accreditor. The key concept is that the regulatory oversight of institutions is “balanced” to ensure that the three legs of the stool are sitting level on the ground. Each party has its own specific area of review and they must be “equally” strong to be effective.

Increased collaboration and communication amongst the three parties would be a good start to ensure consistent evaluation of institutions for quality and positive student outcomes; equally important is that each party is accountable for institutional deficiencies within its regulatory scope and that there is balanced enforcement across sectors when bad actors are involved or where deficiencies are noted. Additionally, it would be helpful if the three parties would collaborate and issue guidance for institutions on what is expected of them in practical terms which could help reduce the number of varying interpretations.

Improved Communication at State Level:

It is important to be mindful that professional licensure boards, who are now key players in this arena, were not invited to the table during negotiated rulemaking and consequently, had no input into their involvement with institutional compliance as required in the regulations. A wish is that state higher education regulatory agencies and state professional boards develop a cooperative relationship and communication structure to provide a coordinated and transparent response to institutions that are seeking information on educational requirements. It would be beneficial to have the professional board websites specifically orient their content on educational requirements to the educators and trainers for the profession, as well as making it easy to locate with minimal effort.

Programmatic Accreditor Involvement:

Programmatic accreditors can be a valuable resource for institutions if the accreditors with involvement in understanding the individual state requirements, by making that information available to its accredited institutions in a consumable manner that aligns with its standards, and by providing additional guidance to their institutions.

A Regulatory Strategy that Addresses Mobile Students:

Addressing consumer protection for students by requiring disclosures about pre-licensure requirements as listed in the federal regulations is a good start but does not address the mobility challenges of our 21st century society as students relocate with much greater frequency than in the past. The Department of Education could provide support by sharing its resources with national and state leaders to ease the burden for students in a pre-licensure program who are relocating, while being cognizant of the various states’ rights to regulate public safety and protect its citizens from harm caused by ill-prepared or unlicensed professionals.

More Work on Post-Licensure Mobility:

On the other side of the coin regarding post-licensure, the Department of Labor and other federal and state agencies have been studying the barriers that licensed professionals face when trying to transport their licensed skills across state lines. There is still much work needed to reduce the obstacles that prevent the licensed professional’s mobility. This is particularly evident with military spouses who are licensed professionals.

Partnering with National Associations of Professional Boards:

There is a consistent plea from institutions for information on educational requirements from professional boards. It would be of great value if national associations of state licensing boards could act as clearinghouses of state regulatory information. At a minimum, these associations should encourage states to develop a structure for transparency for educational requirements on the state websites; optimally, all states should submit their content for listing on the national association website so that an institution can visit that website and quickly determine if the profession regulates the activity in a particular state, followed by the educational requirements in that state.

Two national associations that have been on the forefront of helping institutions with transparent and practical information are nursing and social work. The National Council of State Boards of Nursing (NCSBN) has created the State Licensure Requirements in which states submit their regulatory information and educational requirements to the national association to provide a collation of each state’s requirements. The Association of Social Work Boards (ASWB) offers a listing of educational requirements by state as well as fee-based consulting services to institutions to assist in determining if the institution’s social work educational program is in compliance with federal disclosure requirements at Help with federal financial aid disclosure requirements. We can hope that other national associations of professional boards will follow these two leaders which will ultimately save each state professional board much time in responding to repetitious institutional inquiries and will enable institutions to more quickly come into compliance with the disclosure requirements in the federal regulations.

Available Resources

SARA Resources

SAN Resources

Happy Anniversary!

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Photo by Siora Photography on Unsplash

While we still have more to do to engage all of the key stakeholders, we will keep moving forward to communicate and collaborate with professional boards, accreditors, and the Department to support the institutions’ work to be transparent with students. This is definitely a marathon and not a sprint to pull these entities together to play their part to ensure clear information is available. Is there anyone who feels like this is déjà vu from 10 years ago with not fully developed state higher education agency websites to address state requirements for institutional approvals?

On the bright side, we can celebrate the fact the many institutions are doing great work to manage these compliance requirements, many of which are regular contributors to the WCET/State Authorization Network (SAN). Be sure to look for more information as it becomes available from the key stakeholders. We will collate and share the resources they provide.

Happy Anniversary to these regulations!

 

 
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Practice

Distributed Leadership Can Help with Recovery After the Pandemic

Post author By Lindsey Downs
Post date June 25, 2021
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Today I am happy to welcome Vickie Cook with the University of Illinois Springfield, who joins us to discuss recent study undertaken on distributed leadership models and the experiences of using such models in our daily educational work. Thank you Vickie for sharing more about this leadership model and your experiences with this approach!

Enjoy the read and enjoy your day,

Lindsey Downs, WCET

Institutions of higher education must now make plans on how to create stronger and more effective learning opportunities for students in the post pandemic educational environment. It is imperative that those with skill and expertise to address these challenges be able and willing to step up and lead. Distributed leadership may be one approach to consider. This strategy is defined as a leadership approach which focuses on participation across an organization.

Spillane (2006) shared that…

… distributed leadership is an emerging set of ideas that allows leadership to occur both formally and informally throughout an institution. 

Overview of Distributed Leadership

Distributed Leadership builds an institutional culture to allow leader-teams to generate grassroots solutions and initiatives while solving issues. Leader-teams are small groups of employees from across an institution who have a stake in the outcome of the decisions made. These leader-teams should bring the knowledge and expertise related to the topic and a willingness to be responsible for a decision being made and effectively communicated. This can be a very useful model as institutions begin facing the aftermath of the pandemic.

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Photo by Markus Spiske on Unsplash

Distributed leadership requires the leader-team to accept responsibility toward a successful resolution of an issue or launching a new initiative. This means the leader-team accepts accountability to their colleagues for decisions, implementation, and outcomes made by the leader-team.

Distributed leadership is powerful because those leading this process hold the expertise and skills to move the institution forward. Positional leadership is not required nor necessarily recommended on the leader-team; however, the positional leaders of the institution must be willing to support leader-teams by allowing the process to work from implementation to fruition.

Benefits of Distributed Leadership Models

The practice of distributed leadership is effective because it reduces focus from a position to a leader-team who has the ability to design, implement, and evaluate the approach in a complex organization. This type of leadership model also allows voices from varied and perhaps conflicting points of view to be heard and appropriately investigate pathways forward for the organization. As higher ed professionals seek to change models of enrollment, instruction, business approaches, as well other highly complex practices and policies in the years following the pandemic, building trust across an organization while allowing for discourse to occur will be vital to a successful recovery.

Promising Practices to Consider When Implementing Distributed Leadership

There are seven areas of practice to consider for a successful distributed leadership process to occur.

Image by Gordon Johnson from Pixabay
  1. Build a community of trust and authenticity within and across the organization by explaining the process and seeing it through even though it may first appear to take more time to accomplish your stated objective than more traditional approaches.
  2. Give voice to detractors of the process, the nature of the problem, and the proposed solutions to ensure that inclusiveness is practiced.
  3. Invest in building collaborations and connections across campus to ensure multiple strengths and expertise are brought by the leader-team. Ensure that a strong understanding of the actual problem exists.
  4. Ensure that active listening occurs during planning or implementation of initiatives, and that communication includes a strong feedback loop.
  5. Lean into the ambiguity of the future. No one can make absolute predictions about the future of higher education. However, we do know that students are expecting different outcomes than they did prior to the pandemic. Not knowing a stated outcome creates dissonance, however leaning into ambiguity will assist with the authenticity of creating innovative solutions to the problems we are facing both today and in the future.
  6. Evaluate the planning and implementation process and outcomes of projects/initiatives. Determine what worked, what didn’t, and where changes need to be made for the future. Make those changes toward improvement.

My Own Experiences

In my own leadership practice at the University of Illinois Springfield, I find that having a distributed leadership approach can be especially effective when considering new initiatives and projects. Employing the skills and expertise of a variety of individuals and stakeholders across campus in the communication and decision-making process to move projects forward has delivered positive outcomes. Gathering the individuals who bring the skills needed and the knowledge required to create solid decision-making, as well as provide communication and transparency about both the process and the product may appear to take extra time. However, in my own experience, distributed leadership saves time as communication and building understanding and trust occurs simultaneously. Fewer mistakes are made and more positive outcomes realized. Distributed leadership is one leadership tool, not the only leadership practice to consider as part of leading complex tasks in a university setting.

vickie cook author headshot

Vickie S. Cook
Executive Director, Online, Professional, and Engaged Learning
Research Professor, Educational Leadership
University of Illinois Springfield

Reference and More Resources:

Spillane, J. (2006). Distributed Leadership. Jossey-Bass

More resources on this leadership model can be found at…

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Policy

Department of Ed Change May Result in More Institutions Needing Distance Education Approvals from Accrediting Agencies

Post author By Lindsey Downs
Post date June 18, 2021
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We are just now figuring out that both accrediting agencies and institutions may have more work ahead of them in meeting federal requirements regarding oversight of distance learning programs.

pin board with "change" spelled out
Image by kalhh from Pixabay

Sometimes at first look, we don’t fully comprehend the impact that a change in regulation or Department of Education (the Department) guidance might have out in the real world. And sometimes even with a second look, we might not fully comprehend that impact.

While we do not have all the answers, we thought it was important to highlight an issue brought to our attention and which has raised some important questions about accreditation and distance education.

The Change

In brief, the Department rescinded previous guidance regarding when an institution needed to seek institutional accreditation approval for offering distance education programs. Still in place is the requirement that the accrediting agency itself needs to have distance education as part of its “scope of recognition.”

  • The rescinded guidance: If an institution offered more than 50 percent of its courses via distance education, had more than 50 percent of its students enrolled in distance education, or offered more than 50 percent of an educational program via distance education, its distance education programs were required to be evaluated or approved by an accrediting agency with distance education in its scope of recognition.
  • The new guidance (emphasis added): “…a program offered in whole or in part through telecommunications is eligible for Title IV, HEA program purposes if the program is offered by an institution that is accredited by an agency that has accreditation of distance education within the scope of its recognition…before an institution offers any distance education programs that can be eligible for Title IV, the institution must be evaluated and accredited for its effective delivery of distance education programs by a recognized agency that has distance education within its scope of recognition.”

Cheryl Dowd (WCET’s Senior Director, Policy Innovations) actually covered the rescinded guidance and new guidance in January. The rescission of the Department’s 2006 guidance from Dear Colleague Letter GEN-06-17 was announced in the Federal Register last August. The new Guidance on Accreditation and Eligibility Requirements for Distance Education was released by the Department on January 19, 2021. This date was last full day of the previous presidential administration. When we covered the guidance in January, we were simply reporting on this new guidance. Since that time, we have obtained more information than was originally shared with the guidance.

A Little Background

Many open books in a pile

The change was made due to a review required by President Trump’s Executive Order 13891, which sought to ensure that “Americans are subject to only those binding rules imposed through duly enacted statutes or through regulations lawfully promulgated under them…”

As a result, the analysis showed that the now-rescinded guidance conflicted with 34 CFR 668.8(m), which states:

(m) An otherwise eligible program that is offered in whole or in part through telecommunications is eligible for title IV, HEA program purposes if the program is offered by an institution, other than a foreign institution, that has been evaluated and is accredited for its effective delivery of distance education programs by an accrediting agency or association that—

 (1) Is recognized by the Secretary under subpart 2 of part H of the HEA; and

 (2) Has accreditation of distance education within the scope of its recognition.

Yes, it is ironic that an Executive Order meant at limiting bureaucracy may have added to it.

A Few Questions

In conversations with knowledgeable accreditation and institution personnel, we now understand that there are several questions about this guidance. Additionally, depending on the response to those questions, the impact could be substantial. A few of the questions that we have:

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  • Does this mean that every program that has even one course that uses distance education will need to have approval from their accrediting agency for that program?
    • We don’t think so. We think this just expands the number of institutions requiring distance education approval for the institution. But, we are not sure and it will be good to ask.
  • Does the “in whole or in part through telecommunications” mean that courses using any distance education variation are now considered distance education and creates the need for approval of that program? Part of the distance education definition is “to deliver instruction to students who are separated from the instructor or instructors.” Possible variations that could be included: blended learning, hybrid learning, hyflex learning, flipped classroom, adaptive learning, and anything that allows that student / instructor separation.
    • We don’t know.
  • If an institution decides to change the modality of just one course within a program, does it need accreditor approval before making this change?
    • We don’t think so, but it will be good to ask.

Accreditors Authority Regarding Department Minimum Requirements & COVID Flexibilities

The Department provides minimum requirements that must be addressed by accreditors in order for institutions to participate in Title IV HEA programs. The institutional accreditors have the authority to impose more rigorous requirements. The Department’s guidance suggests that after approval by the accrediting agency, an institution may offer distance education programs without the need for further approval, unless delivery of a program exceeds 50% by distance education or the institution delivers more than 50% of its programs through the distance education modality. We have learned that institutional accreditors may wish to impose further approval earlier than the Department’s guidance indicates.

Additionally, the Department’s new guidance addressed that in response to the national pandemic that the Secretary exercised authority under the HEROES Act, 20 U.S.C. § 1098bb that the flexibilities with respect to institutional eligibility for distance education for purposes of Title IV that will continue until the national emergency is rescinded. However, these Department flexibilities as originally offered acknowledged that any flexibilities were subject to the requirements of the accreditors. We have learned that several accreditors are no longer extending these flexibilities.

What’s Next?

Please tell us if instances where you have run into this issue. And submit questions that you may have about the impact of this change.

We will compile questions to ask the Department. We will report the results to you.

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