Today’s post from Chantae Recasner, Dean, Academic Success with Northeast Lakeview College – Alamo Colleges District and the WCET Steering Committee working group on Diversity, Equity, and Inclusion, who joins us to close out the Frontiers series started at the beginning of this month on “Enabling Difference.”
During the month of August, members of this working group shared their advice, strategies, and research regarding equity and inclusion in higher education digital learning. As Chantae confirms below, this isn’t the end of WCET’s work on diversity and inclusion in higher education, but just the start.
Stay tuned to learn more about our work in the future.
Thank you again to our WCET leadership for your outstanding work with us on this topic and your dedication to improving the educational experiences for all of our students.
Enjoy the read,
Lindsey Downs, WCET
This month’s examination of diversity, equity and inclusion has been but one example of how WCET is invested in living its values and engaging the expressed concerns and interests of its members. Our theme of “Enabling Difference” was intended to inspire openness about how we approach DEI challenges and aspirations as individual professionals and organizations.
From conceptualization of terms to strategic planning, from data analysis to eliminating barriers in tech, this series offered members a place to start, a place to re-engage, a place to re-consider. While the month has ended, DEI engagement for the WCET Steering Committee, the DEI Workgroup, and all of you does not and should not stop here.
Online Learning as an Emergency Response
As we wrap up this series, Hurricane Ida is raging through Louisiana—a triggering moment for anyone who, like me, has experienced trauma associate with natural disasters, especially hurricanes. In many ways, the nested realities of a natural disaster amidst a global pandemic is yet another provocateur of debates about access. As I write this, the entire city of New Orleans is without power. What an apropos description of a city where the majority of its residents identify as members of a historically minoritized group, less than 50% have earned a higher education credential, and the average person earns about $35K a year. My house in San Antonio is currently occupied by family who evacuated from my hometown of New Orleans in search of safety, and my mind is now overrun with thoughts of how safety and recovery are intimately connected to equity and justice.
16 years ago, in the wake of Hurricane Katrina, we saw stimulation of the digital marketplace in higher education as many colleges and universities across the country enabled online course offerings in partnership with those campuses most victimized by the storm. Thus, online learning as emergency response was not a new idea when leaders gathered to determine how we would continue instruction in the wake of the COVID-19 pandemic. Systemic inequities can indeed seem most evident during moments of great distress, but they also manifest in micro-moments that distress individuals greatly.
My point here is that from the microaggression to the natural disaster, we are literally still navigating recovery strategies from historic inequities and building preparedness strategies as safeguards against future injustice. As we learned from the “Closer Conversation” on Friday, many of us are doing great work in our personal lives and at/with our institutions, but the challenges are varied if not vast. Are our different lived experiences enabling common conceptualizations of equity, equality, justice, inclusion? No. But, it is in the drudges of critical, courageous, brave, safe conversations that we at least build collective will to pursue the ideal, if not robust and clear strategy.
Where Do We Go From Here?
So where do we go from here? The best lesson I ever learned in instructional design was that well designed instruction is iterative. We look back to learn where to clear paths and innovate for higher achievement and for greater learning. Our journey toward creating greater access and equity in higher education in general and digital integration specifically is contingent upon our collective willingness to identify, value, and empower difference.
As Tina Parscal and Van Davis acknowledged, “…erasing equity issues at our institutions is everyone’s job,” and we press forward ever mindful of Janelle Elias’s counsel that “planning to plan is a critical part of centering DEI work.” In other words, we will never be able to “change some experiences for all students” and provide what Adam Cota described as “personalization at scale” if we fail to plan and then refuse to act. We should find comfort in taking a chance at doing it differently, thinking about it differently, and assessing it differently because there is no true failure in operating with the intention to increase access and eliminate inequity. If the concept of iteration holds, then we will continue to grow as we go. Thus, as Anna Porcaro exclaimed, “Educators have a responsibility — and really an exciting opportunity — to identify and remove as many [barriers] as they can as they build and revise online courses.”
“…what happens in the world impacts the classroom and what happens in the classroom impacts the world.“
I would extend the vision of that impact opportunity beyond the course itself. If classrooms are but microcosms of our world(s), then the symbiotic influence holds—what happens in the world impacts the classroom and what happens in the classroom impacts the world.
So, let’s keep talking, planning, and doing. WCET would like to thank all you for engaging the blog series this month, and we invite you to continue the conversations with us and among your colleagues.
Today we begin one of my favorite parts of the year – and no, it’s not pumpkin spice season (although that is up there…), it’s WOW celebration season!
For the next several weeks, WCET Frontiers will feature blog post authors from our 2021 WCET Outstanding Work (WOW) Award Winners. This year we took a slightly different focus and asked for stories that described the intensely hard work that WCET member institutional staff, instructors, administrators, and students heroically stepped up with to the meet the challenges brought on by the COPVID-19 pandemic.
Congratulations to the 2021 WOW awardees:
Colorado Technical University.
Miami University Regionals E-Campus.
University of Alabama.
University of Louisville.
University of North Dakota.
University of Texas at San Antonio.
To kick off the award season, Kara Anand-Gall, Instructional Designer with Miami University Regionals E-Campus, joins us to discuss their online course development process and how they shifted in response to the pandemic to create an updated course development process for online, hybrid, synchronous courses and by the end of 2020, had 350 faculty “online-certified” for teaching remote-delivery courses using their new models.
Congrats to Miami University Regionals E-campus and the digital learning heroes highlights in today’s post.
Enjoy the read and enjoy your day,
Lindsey Downs, WCET
Online since 1999, Miami University Regionals, in partnership with E-Campus, has long had a process in place for developing online/hybrid asynchronous (what we have named “-A”) courses in accordance with regulations and best practices for distance learning course development. This process has resulted in a robust catalog of online courses, including nearly 300 courses representing nine fully online programs and thirteen different departments. The pandemic challenged us to build on this solid foundation to design a framework for developing online/hybrid synchronous (“-S”) courses.
Building from a Strong Foundation
Our longstanding -A course development process includes three phases: Online Faculty Orientation (E1), Course Planning (E2), and Design and Production (E3).
E1: Online Faculty Orientation
Managed by our E-Faculty Engagement team, the first phase was designed to prepare faculty to teach or develop their first online course with E-Campus. E1 includes opportunities to:
learn about best practices in online teaching and learning,
introduces faculty to common technologies used by our E-Campus faculty,
provides training in accessibility and course management techniques, and,
gives them the experience of being an online student in the University’s LMS, Canvas.
Completing E1 satisfies higher education standards for professional practices for online instruction, which are required by our regulatory bodies. Additionally, it gives our faculty an opportunity to advance their career, and – most importantly to our mission – maximizes their potential to impact student’s learning. Over time, this orientation has been baked into the culture at Miami University Regionals so that new faculty hires complete the E1 phase as part of their onboarding.
E2 and E3: Course Planning, Design, and Production
The second and third phases of the course development process are facilitated by our Instructional Design team. These phases, each eight weeks, entail collaboration between an instructional designer and either an individual or small team of faculty course authors. The E2 process entails planning the course, with a focus on alignment between course learning outcomes, module learning outcomes, learning activities, and assessments. E2 culminates in a blueprint, or curriculum map, of the online course. From here, faculty proceed to E3, the design and production phase, in which the faculty/instructional designer team moves the blueprint to a reproducible course shell. At the conclusion of E3, the course is internally peer reviewed using Quality Matters and OSCQR standards.
A New Audience, A New Context, A New Process
The COVID-19 pandemic presented us with a brand-new audience: faculty who traditionally teach in face-to-face environments. New to us, new to virtual environments, new to technologies, they scrambled to quickly transition their courses to online -A and -S course formats.
Our team quickly pivoted to support, train, and encourage this brand-new audience. We expanded our support resources to address their needs. We adjusted our development schedule to accommodate additional courses. We facilitated 26 workshops and three faculty learning communities, all focused on pandemic-response teaching, reaching 120 unique participants. Additionally, we published 52 articles incorporating evidence-based best practices for online learning, addressing such topics as screencasting technology, video conference software, and Canvas features. Our hallmark pivot was the design of a new process specifically for the development of -S courses. Initially, we drew from the key elements of our -A course development process to this new framework, focusing on the stages of learning, planning, designing, and reviewing.
We knew that we had neither resources nor time to overlay our existing -A course planning and design processes to -S course development. And for a while we found ourselves stuck in the mindset of the best practices we’d used for -A course development. We’ve learned that, almost always, getting “unstuck” is best achieved by collaboration, so our E-Faculty Engagement team, under the ECCOE initiative, formed an interdisciplinary committee of faculty, student, and E-Campus representatives to create a new process specifically for the development of -S courses. Their primary objectives were to maintain regulatory compliance and create a consistent experience for students, within the context of faculty autonomy.
With guidance from the committee, E-Campus developed and implemented a process that includes a reproducible Canvas template that adheres to regulations, allows for flexibility and personalization, and provides a consistent student-experience; a course development checklist; and a pre-course delivery consultation with faculty to ensure the delivery of high-quality synchronous courses. The E-Faculty Engagement team acts as partners throughout this process to guide faculty through the process, resources, and requirements. Starting Fall 2021, all -S courses at Miami University Regionals are required to meet the following minimum requirements:
Completion of E1: Online Faculty Orientation.
Integration of -S course Canvas Template into all -S course Canvas sites.
Utilization of Canvas for course management and communication of key course details including, at a minimum, Syllabus, Announcements, Assignments, Grades, Instructor Contact information, and virtual meeting links.
Consultation with E-Campus’ E-Faculty Engagement team to record the -S course details for regulatory reporting purposes.
The Impact
In his article “Beyond COVID-19: What’s Next for Online Teaching and Learning in Higher Education?,” John Nworie writes,
“It is important to acknowledge that there is a difference between well-planned and developed online courses or distance education programs and the eclectic methods cobbled together hurriedly to meet the urgent demands of the situation.”
– John Nworie
As an E-Campus, we know the value of the well-planned and developed online course. As a result of our strategic application of both -A and -S course development processes, by the end of the 2020, 350 “online-certified” faculty were teaching remote-delivery courses. Adjusting our schedule to accommodate additional development resulted in a 62% increase in the production of new -A course offerings completed in 2020. Over the summer, we rolled out our new -S course process, and at the start of Fall 2021, 126 -S courses taught by 65 instructors were ready for delivery, all of which successfully followed the new framework.
These efforts have been – and will continue to be – critical to our open-admission, low-tuition mission, which has been successful in serving the surrounding population and communities, which are primarily low-income, first-generation, and urban Appalachian. 27% of our students are minority, 36% are non-traditional, and 31% are first-generation. Our actions served as a buffer against the cognitive cost of COVID-19 for a population of students who already face significant disadvantages and disparity in contrast to their peers.
We would be happy to share in greater detail the steps of our -A or -S development processes. Get in touch with us at eccoe@miamioh.edu with questions.
Kara Anand-Gall is an instructional designer with the Miami University Regionals E-Campus. A former English instructor with nearly two decades experience in curriculum design, teaching, and graphic design, her goals are to leverage digital platforms and pedagogical best practices to develop meaningful, relevant learning programs that result in student engagement and retention. She is currently pursuing her MFA in Creative Writing at Miami University.
About Miami University Regionals E-Campus: The Miami Regional E-Campus office is the hub for all online and hybrid courses and programs at the regional campuses. We work with faculty to create interactive and rich online and hybrid learning experiences that allow students a more flexible Miami learning environment. Our office provides faculty training and support while monitoring online and hybrid course compliance. We use Quality Matters as a guide to our quality online experiences.
On July 1, 2021, the Department of Education released the final set of proposed regulations stemming from the 2019 Negotiated Rulemaking process (the Distance Education and Innovation Regulations). As part of these regulations, the definition of “distance education” in Chapter 34, §600.2 was updated, including specifically defining the critical terms: instructor, regular, and substantive.
This was an important update, as “regular and substantive interaction” is what distinguishes “distance education” from correspondence, which has important implications for federal financial aid eligibility. However, until now, those terms were not defined by regulation, and guidance on the meaning of those terms was incomplete. Failure to comply with regular and substantive interaction requirements jeopardizes an institution’s access to federal financial aid if more than 50 percent of their courses are classified as correspondence courses, or more than 50 percent of their students are enrolled in correspondence courses.
Regular and substantive interaction” is used in the “distance education” definition as a consumer protection mechanism for students and to delineate federal financial aid eligibility for courses and competencies.
In talking with personnel from institutions about these updated regulations, there were commonly raised questions and concerns, and it was clear that further guidance from the Department would help institutional personnel understand what actions to take to best serve students and assure compliance. Earlier this month, WCET and the State Authorization Network submitted questions to the Department of Education based on discussions with our members and questions raised during presentations. Institutional compliance personnel across are seeking further guidance to assure compliance with this important distinction. We look forward to providing an update and analysis pending a response from the Department.
While we do not have all the answers at this time, we thought it was important to provide an overview of our best interpretations of these requirements and issues that have been brought to our attention as it relates to the federal definition of distance education. Please feel free to contact us with additional questions.
Definition of “Distance Education” in the Guidance for Program Approval by Accrediting Agencies
As we covered in a June blog post, the Department issued new Guidance on Accreditation and Eligibility Requirements for Distance Education about when an institution needed to seek institutional accreditation approval for offering distance education programs. In particular, the Guidance states that 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.”
Note that the Guidance referenced distance education at the program level and set a lower bar for review than the 50% level that had been used by accrediting agencies for many years. In light of this Guidance and the transition to remote and digital learning during the pandemic, we received many questions about under what circumstances the variations of distance education would be considered “offered in whole or in part through telecommunications”. We also wondered if that program level threshold also be applied to courses, since that is the unit of measure for “regular and substantive interaction” reviews. Due to these questions, in our letter we asked that the Department clarify whether this guidance means that courses using any distance education variation (such as but not limited to blended learning, hybrid learning, hyflex learning, flipped classroom, adaptive learning, etc.) are now considered distance education and thus necessitates approval.
Definition of “Distance Education” as Applied to Courses in §600.2
The final definition of distance education in 34 CFR 600.2 in its entirety is as follows (emphasis added):
Education that uses one or more of the technologies listed in paragraphs (1)(i) through (1)(iv) of this definition to deliver instruction to students who are separated from the instructor or instructors, and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.
The technologies that may be used to offer distance education include —
The internet;
One-way and two-way transmissions through open broadcast, closed circuit, cable,microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
Audio conferencing; or
Other media used in a course in conjunction with any of the technologies listed inparagraphs (1)(i) through (1)(iii) of this definition.
For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by the institution’s accrediting agency.
For purposes of this definition, substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also includes at least two of the following—
Providing direct instruction;
Assessing or providing feedback on a student’s coursework;
Providing information or responding to questions about the content of a course or competency;
Facilitating a group discussion regarding the content of a course or competency; or,
Other instructional activities approved by the institution’s or program’s accrediting agency.
An institution ensures regular interaction between a student and an instructor or instructors by, prior to the student’s completion of a course or competency—
Providing the opportunity for substantive interactions with the student on a predictable and scheduled basis commensurate with the length of time and the amount ofcontent in the course or competency; and
Monitoring the student’s academic engagement and success and ensuring that aninstructor is responsible for promptly and proactively engaging in substantiveinteraction with the student when needed, on the basis of such monitoring, or uponrequest by the student.
Note that there were minor revisions to language found in the first part of the definition relating to the technologies that can be used to offer distance education. The Department updated the types of technologies that are being used or may be used and removed references to outdated technologies.
However, when it comes to oversight of the requirements for regular and substantive interaction and distinguishing distance education from correspondence education, the Department outlined the five factors on which it will focus in the preamble to the final regulations:
The institution’s online instruction is delivered through an appropriate form of media;
The instructors with whom students regularly and substantively interact meet the requirements of the institution’s accrediting agency for instruction in the subject matter;
Instructors engage in at least two forms of substantive interaction meeting the regulatory requirements for the course or competency;
The institution has established scheduled and predictable opportunities for substantive interaction between students and instructors and create expectations for instructors to monitor each student’s engagement and substantively engage with students on the basis of that monitoring; and
Instructors are responsive to students’ requests for instructional support.
The following sections break down the definition of distance education in more detail. In those sections, we will do our best to answer some of the most common questions WCET has received relating to that piece of the definition, including how the Department may go about making determinations about the above five factors.
As a helpful illustration, we’ll complete the following summary table throughout the rest of the blog to illustrate how our understanding of the requirements has changed with the new definitions and information from the Department. The “Previous Interpretation” column is derived from an analysis of guidance and findings against institutions that was conducted in 2016 by Russ Poulin, WCET, and Van Davis, then of Blackboard and now of WCET.
PREVIOUS INTERPRETATION
CURRENT (AFTER JULY 1, 2021)
INTERACTION
Only initiated by the instructor
INSTRUCTOR
Meets accreditation standards
SUBSTANTIVE
Of an academic nature
REGULAR
Regular and somewhat substantive
Definition of Instructor
In part three of the distance education definition, instructor was defined as follows:
For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by the institution’s accrediting agency.
Over the years, institutions pieced together requirements from departmental guidance and Office of Inspector General (OIG) audit reports. Those reports generally indicated that to qualify as an instructor the individual had to meet the institution’s accreditor standards; however, that guidance was not always consistently applied. The definition above explicitly relies on accreditor approval for purposes of determining whether an individual would qualify as an instructor.
Below are the most common questions WCET received on the definition of instructor. We asked that Department issue guidance to confirm this interpretation of the definition of instructor and additional guidance as necessary into the types of qualifications needed for Teaching Assistants, Graduate Assistants, and other instructional team members to meet the definition of instructor.
Does the definition of instructor encompass instructional models involving team instruction or unbundled instruction?
In the preamble, the Department asserted that the current regulatory language accommodates the use of instructional teams and that no change in language was necessary in order to further encourage their use.
Who counts as an instructor? Do Teaching Assistants or Graduate Assistants count, or does it depend on what they do?
As mentioned above, the definition above explicitly relies on accreditor approval for purposes of determining whether an individual would qualify as an instructor. Therefore, it is up to your institutional accreditor (and potentially programmatic accreditor pending applicability). Our understanding is that most accreditors accept teaching assistants who are doing instruction, grading tests, or facilitating breakout session, however the institution should check with its accreditor(s).
In the preamble, the Department stated that it will evaluate whether an instructor meets an accrediting agency’s requirements by:
reviewing the agency’s written standards; and
any communication between the agency and the institution regarding the agency’s requirements or whether the instructors in question met such requirements
In the event the Department cannot determine whether an instructor meets the accreditor’s requirements after going through the steps above, the Department may contact the accreditor directly to obtain a determination.
PREVIOUS INTERPRETATION
CURRENT (AFTER JULY 1, 2021)
INTERACTION
Only initiated by the instructor
INSTRUCTOR
Meets accreditation standards
Explicit reliance on accreditor approval
SUBSTANTIVE
Of an academic nature
REGULAR
Regular and somewhat substantive
Definition of Substantive
In part four of the distance education definition, substantive interaction was defined as follows:
For purposes of this definition, substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also includes at least two of the following—
Providing direct instruction;
Assessing or providing feedback on a student’s coursework;
Providing information or responding to questions about the content of a course or competency;
Facilitating a group discussion regarding the content of a course or competency; or,
Other instructional activities approved by the institution’s or program’s accrediting agency.
In previous blog posts addressing the definition of regular and substantive interaction, we provided an overview of how the Department may interpret the meaning of the terms based on OIG audit reports. In those audit reports, the OIG defined substantive as “relevant to the subject matter” and provided further examples of what is not substantive interaction.
As seen in the above definition, the Department has now defined substantive interaction with specific examples and requires institutions to meet at least two of the listed requirements.
What type of evidence is needed to document compliance with the definition of substantive interaction?
In the preamble, the Department stated that an institution is expected to maintain policies or procedures that create expectations for faculty to substantively interact with students. The Department also stated that it does not expect institutions to document the exact amount of time spent on any substantive interaction. In our letter, we asked the Department to confirm these expectations. In the meantime, we recommend that institutions document any policies, procedures, or actions taken to establish expectations around faculty substantively interacting with students. For example, having course syllabi clearly delineate instructional activities.
What is “direct instruction”?
The Department does not define “direct instruction” in the regulation. In the Department’s April 2021 webcast on the regulations, in response to a question from WCET staff the Department indicated that direct instruction is intended to be a situation in a synchronous environment where both the instructor and student are present at the same time and are both engaged. However, in the same webinar, the Department stated that would be a “version” of direct instruction, implying there may be other acceptable practices that would constitute direct instruction.
We believe that “direct instruction” would likely include asynchronous activities, such as participating in discussions, providing feedback, and office hour interactions with students focused on the subject of the class.
Even if the Department defines “direct instruction” as synchronous-only, most distance courses should still meet the substantive requirement by meeting two of the other four criteria.
Would video lecture be considered direct instruction (synchronous or asynchronous)?
A real-time, synchronous video lecture would count as direct instruction. Based on the Department’s April 2021 webcast, a recorded lecture would likely not count as direct instruction. However, we want to emphasize that direct instruction is only one option in a list of five options for substantive interaction, two of which must be met for direct instruction to be fulfilled. Therefore, an instructor could still use recorded video lectures in a course if combined with other direct instruction interaction activities.
We will note that, in our letter, we asked the Department to clarify what constitutes “direct” instruction, including if it may be synchronous or asynchronous, as the information we have sourced conflicts.
Do assessments count as substantive interaction? What about “auto-graded” assessments or “computer-generated” feedback?
Assessments would meet the second bullet point in the list of activities that qualify as substantive interaction, “assessing or providing feedback on a student’s coursework.” However, we emphasize that institutions remember that they must provide at least two of the listed opportunities for interaction, so assessments alone would not meet the requirements.
The Department indicated in the preamble that interactions with artificial intelligence, adaptive learning systems, or other forms of interactive computer-assisted instructional tools will not meet the statutory requirements for regular and substantive interaction. The Department noted that such interactions may qualify as forms of “academic engagement” but in the context of regular and substantive interaction it would not satisfy the requirements.
PREVIOUS INTERPRETATION
CURRENT (AFTER JULY 1, 2021)
INTERACTION
Only initiated by the instructor
INSTRUCTOR
Meets accreditation standards
Explicit reliance on accreditor approval
SUBSTANTIVE
Of an academic nature
Has a list of activities (instruction, assessment, tutoring, answering questions)
REGULAR
Regular and somewhat substantive
Definition of Regular
In part five of the distance education definition, regular interaction was defined as follows:
An institution ensures regular interaction between a student and an instructor or instructors by, prior to the student’s completion of a course or competency—
Providing the opportunity for substantive interactions with the student on a predictable and scheduled basis commensurate with the length of time and the amount ofcontent in the course or competency; and
Monitoring the student’s academic engagement and success and ensuring that aninstructor is responsible for promptly and proactively engaging in substantiveinteraction with the student when needed, on the basis of such monitoring, or uponrequest by the student.
Our previous understanding, based on Dear Colleague Letters and OIG Audits, was that instructors were expected to interact with students on a fairly set schedule with those communications not too far apart.
In addition, in a December 2014 Dear Colleague Letter, the department stated that:
“We do not consider interaction that is wholly optional or initiated primarily by the student to be regular and substantive interaction between students and instructors. Interaction that occurs only upon the request of the student (either electronically or otherwise) would not be considered regular and substantive interaction.”
With the new definition in effect, the Department requires institutions to meet two criteria to demonstrate regular interaction. It was originally intended by the negotiators that institutions must meet one requirement or the other, and not both, but the final committee settled on requiring both.
The new language also allows for interactions “upon request of the student” for the first time. Previously, only interactions initiated by the instructor were counted. However, as discussed below, these student-initiated interactions alone will not suffice without additional instructor-scheduled opportunities for interaction.
Q: What is needed to show that interactions be “commensurate with the length of time and the amount of content in the course or competency”?
In the preamble, the Department stated that, due to the variety of distance education instructional modalities, it did not believe it to be practical to offer a specific timeframe, sequence, or frequency by which interactions need to occur within the course or competency for purposes of regular interaction. The Department noted that the Distance Learning and Innovation subcommittee that worked on these regulations believed that a specific timeframe would be overly prescriptive, excessively complex, and would be tough to adapt to courses of different lengths.
We recommend that institutions develop policies or procedures that create expectations for faculty to substantively interact with students on a predictable and scheduled basis and to monitor each student’s engagement and success and follow up with the student as needed. An example of “predictable” would be to say that a new lesson is released every Monday, Friday, or some equally predictable timeframe. An example of “scheduled” is the course syllabi in outlining when activities will happen in the course.
It is not strictly required that interactions take place on a weekly basis. There could be course or competency considerations that justify instructor-initiated interactions more or less frequently. For example, a course may be strengthened by having a two-week period in which students are working on a project and there is no new instruction from the instructor. However, the instructor should be available for student-initiated questions.
Q: What is meant by predictable and scheduled and could scheduled “office hours” be used to fulfill the regular interaction requirements?
During the Department’s April 2021 webcast on the regulations, the Department affirmed that, for competency-based education and adaptive learning, scheduled “office hours” may be used to fulfill the regular interaction requirement. In addition, the Department’s preamble indicated that the requirement could be met if instructors made themselves available at a specific time and modality, regardless of whether students chose to attend.
Furthermore, the Department noted that the negotiators and the department agreed to frame this requirement as an “opportunity” for interaction rather than a required interaction. The Department asserted that, in so doing, it allows institutions to demonstrate compliance at the program design level without requiring institutions to document every interaction between students and instructors. With the increase of competency-based education and other modalities that are by design on an irregular schedule, this inclusion of office hours was a necessary compromise.
We have heard that some in the financial aid community disagree that this is allowable under the definition of academic engagement. This is a deviation from past practice, and we thought it was important enough to raise with the Department again.
Q: What is meant by “prompt and proactively” and how does an institution demonstrate compliance with this requirement?
As mentioned above, the Department indicated that institutions could demonstrate compliance with the requirements at the program design level without documenting “each and every” interaction. We believe this implies that specific information in a course syllabus or other similar document shared with students that illustrates how quickly students can expect responses from their instructors may suffice to meet this requirement. However, as part of our letter to the Department, we asked them to confirm whether policies and faculty development were sufficient, as well as detail any additional criteria or metrics that institutions should consider.
For monitoring student engagement…Rather than purchasing new software or sophisticated analytics tools, we want to emphasize that institutions may be able to leverage data collected by their current learning management system as evidence of both interactions in online courses and of monitoring of student’s academic engagement and success.
Q: How does an institution monitor a student’s engagement and success in accordance with this definition?
In the preamble, the Department stated that its expectation was that instructors take a proactive approach to determining whether students need assistance. The Department gave some examples of how this may be done, such as:
Using sophisticated systems of technology to monitor student activity
Traditional person-to-person evaluation
Using tests or quizzes
Evaluating each student’s performance in regular class sessions or in regular assignments
Rather than purchasing new software or sophisticated analytics tools, we want to emphasize that institutions may be able to leverage data collected by their current learning management system as evidence of both interactions in online courses and of monitoring of student’s academic engagement and success.
PREVIOUS INTERPRETATION
CURRENT (AFTER JULY 1, 2021)
INTERACTION
Only initiated by the instructor
Mostly instructor initiated, some leeway
INSTRUCTOR
Meets accreditation standards
Explicit reliance on accreditor approval
SUBSTANTIVE
Of an academic nature
Has a list of activities (instruction, assessment, tutoring, answering questions)
REGULAR
Regular and somewhat substantive
Predictable and scheduled and tracking and intervention
Final thoughts
We believe that the definitions provided in the new regulations are a much-needed improvement from previous interpretations and guidance gleaned throughout the years prior. Even though questions remain, we are hopeful that the Department will issue sufficient guidance to address institutional concerns.
In the meantime, institutions would do well to evaluate, in line with the above-discussed guidance, the policies and procedures in place for their instructors to implement these requirements. Institutions should also consider whether there are the means and internal controls necessary to monitor and evaluate online programs over time to ensure compliance with the institution’s policies and regulatory requirements.
Finally, the regulations were based upon the backbone premise of more trust of the relationship between the institutional accrediting agency and the institution. In fact, some practices (e.g., who is an instructor, innovative “substantive” activities) requires input from the accrediting agency. Some of the answers will be found in conversations with your accreditor.
We will keep you updated on further announcements from the Department and will perform additional reviews and analysis as necessary.
Today’s post from Anna Porcaro and Robert McGuire continues our series on “Enabling Difference.” Today’s post, a joint post with Every Learner Everywhere, focuses on technology barriers to equity students face with ideas on how to move past them.
We’re so thrilled to continue this series and focus on DEI throughout this month and thank Anna and the other members of the WCET diversity, equity, and inclusion 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.
This week, we turn our focus to some of the early technology barriers to equity that students run into. Faculty may be tempted to think digital classrooms are equitable when technology tools address accessibility needs; when all videos are captioned or have transcripts, images have alt tags, and documents and web pages are properly formatted for screen readers.
However, we challenge you to be aware of other barriers that would make access inequitable in the online classroom. Put another way, implementing functional tools to provide “accessible technology” is only a part of making technology accessible.
Getting Started with Equity: A Guide for Academic Department Leaders, developed by Intentional Futures and Every Learner Everywhere, a WCET network partner, explains that “equity is achieved when the varied needs of people are considered when developing programming, policies, and pedagogies. While equality is often deployed in the interests of placation and pacification, equity is deployed in the interest of empowerment for traditionally disempowered peoples.”
“Programming, policies, and pedagogies” covers a lot of territory, and in that territory a large number of barriers to access and progress can grow over time. Educators have a responsibility — and really an exciting opportunity — to identify and remove as many of them as they can as they build and revise online courses.
For example, consider the varied ways online students interact with technology during a term. Apart from the work of learning — interacting with one another, with faculty, or with the material and assessments (all points of contact that can produce their own inequities) — they can have individual and significantly unequal experiences just logging in to a digital component for a class and getting started in order to participate. Below are four areas where early barriers to equity in digital learning can lurk, and ideas to help college and university instructors and administrators remove them.
Reading between the lines, however, shows significant inequity in the devices that students rely on to connect to their online education. For example, 3 percent relied on their cell phones, and for more than 25 percent, their device had fallen short of their needs in some way just in the prior week.
Image: EDUCAUSE, Student Experiences with Connectivity and Technology in the Pandemic
Meanwhile, the sudden shift to emergency remote learning during the COVID-19 pandemic revealed that many students relied on campus computer labs or other public computers, and many campuses responded by expanding laptop loaner programs.
The same EDUCAUSE survey showed that internet access at home is far from reliable enough for many college students using remote learning. Solving this problem is a significant source of stress and unanticipated expenses — 36 percent of respondents said they “always, very often, or sometimes struggled to find an internet connection that met their academic needs.”
Students described a range of creative solutions to their internet connectivity challenges, most of them involving doing work from their cars in the parking lot of a parent’s employer, in campus parking garages, and in the parking lots of 24-hour restaurants. One student described sitting in the driveway of their mother’s home to use that wifi during the pandemic but not being able to go inside because their stepfather was immunocompromised. Other students explained they had internet service but not enough to handle the new demands of videoconferencing, which required increased spending on higher internet connectivity.
Faculty should consider where students connect when planning class schedules, due dates, and participation policies. Requiring students to be online at particular times will tend to exacerbate inequity. Flexibility and creativity about those expectations help students who can’t get online consistently and reliably.
3. The Cost of Digital Tech
A study of student perceptions of adaptive learning courseware at the University of Mississippi showed that students can be sensitive to the cost of distance learning technology tools but don’t uncritically resent the expense in every case.
“It turned into a confusing situation for students because they never knew when they entered a class: Does my course fee pay for this, do I have to buy this, and if I have to buy this, what am I getting, and how long does it last?’” O’Sullivan explained. “There was no standard access period, point of sale, or package.”
Students were more likely to value the courseware in advanced courses in their majors and more likely to complain about the expense for introductory and general education courses outside their majors.
Courseware — along with old-fashioned textbooks — are only part of the expenses that can surprise students during a term. Test proctoring fees and virtual lab kits, for example, along with the unanticipated data overages and internet subscription costs discussed above, can create conditions of inequitable access.
Faculty should ensure the growing number of convenient tools available for remote learning don’t also create significant new cost burdens for students.
Specifically, some students have more experience with the inquiry-based, project-based, and self-directed digital learning that a college education extends, and other students experience digital learning that looks more like “drill-and-kill” worksheets on a computer screen.
Educators should design projects and assessments without assuming every student has the same familiarity with what Means calls “empowering” uses of technology. Institutions and individual faculty should consider ways to provide additional structured experiences to prepare students for self-directed digital learning.
What You, Your Department, and Your Institution Can Do
It may seem overwhelming to think through every permutation of inequitable access that students can experience. For example, among the many other issues we don’t describe here are specific personal technology requirements individual students might have (screen readers, translators, screen magnification tools, video playback control tools, etc.).
But keeping the student at the center of course design can help you move in the direction of equitable experiences without getting overwhelmed. One excellent resource that discusses many of these issues and offers practical suggestions is The Caring for Students Playbook from Every Learner Everywhere, Achieving the Dream, and The Online Learning Consortium. Many of the recommendations in it are premised on course policies with flexibility around due dates and participation so that technology connection issues and cost don’t become major barriers to academic progress.
lecture notes incorporated inside a slide deck as well as on a separate document,
collaborative note taking, which can help students learn during the lecture and also creates a resource that can be referenced after the lecture,
audio files as an alternative to video, because they require less bandwidth to download,
sharing video to platforms like YouTube, where they can easily be viewed without downloading, and
mailing printed materials to students who may not have any way to access the internet.
In short, faculty can provide materials in a variety of formats so that students have many options for accessing and engaging in a course. Additionally, a department or institution should:
consider the cost of all the materials, software, and databases,
implement courseware “scholarship” programs that reduce the cost,
move toward authentic assessments instead of technology to monitor cheating, and
expand and publicize laptop loaner and mobile hotspot loaner programs.
The Bottom Line: Your Tech Choices Send a Signal
Equity, diversity, and inclusion in digital learning can be difficult, but it is necessary and important work. Our advice here is only a potential starting point for your own DEI work in the digital classroom. We have focused on technology interaction, because it sends a signal to our students how engaged we actually are in promoting equity for all learners. Properly employed, digital learning technologies help support student success.
We have focused on technology interaction, because it sends a signal to our students how engaged we actually are in promoting equity for all learners. Properly employed, digital learning technologies help support student success.
Meanwhile there is also content, instructional design, classroom practices, assessment, formative assessments, etc. that aren’t discussed here and that also need to be considered in setting up your courses. These additional elements can also create or reduce barriers to access.
We’d like to end this post with a question: In what ways have you effectively used technology in the classroom to create better equity and inclusion and to foster a diverse environment? Leave a reply below, and WCET members can continue the conversation on the online community platform, wcetMIX. We look forward to continuing the conversation with you.
Anna Porcaro is Executive Director of Online and Adult Learning at Wichita State University and a WCET Steering Committee Member.
Robert McGuire is a freelance writer and editor for higher education institutions and related nonprofit organizations, including for Every Learner Everywhere.
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.
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:
academic policies and metrics;
community of care;
curriculum & assessments content and design;
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?
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.
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:
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.
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.
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
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.
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.
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.
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 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
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:
Equity and quality should be understood as constituent components of one another—inclusive, capacious, and interdependent; and
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?
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.
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:
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:
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:
Review the July 20, 2021, testimony of Charmain Bogue, Executive Director, Education Services, U.S. Department of Veterans Affairs to the U.S. House of Representatives VA Committee.
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.
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.
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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