Author: Lindsey Downs

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Policy

Survey of a State Authorization Professional

Post author By Lindsey Downs
Post date July 9, 2024

Essential Requirements and Critical Roles

In today’s ever-evolving landscape of higher education, Distance Education/State Authorization Compliance[1] plays a crucial role in ensuring institutions follow laws, regulations, and guidelines. This process:

  • is critical for institutions to ensure that they are operating within the legal requirements of each state, and,
  • provides protections for both students and the institution itself by helping to facilitate the quality of education.

Distance Education/State Authorization compliance can be a complex and time-consuming process, as each state has its own set of regulations and requirements for out-of-state institutions. These requirements may include obtaining approval from the state’s higher education agency, registering with the state’s attorney general’s office, or submitting to regular audits and reporting.

As such, compliance positions and roles are critical for colleges and universities that offer distance education programs, as failure to comply with these requirements can result in serious consequences for institutions, including fines, loss of accreditation, and/or sanctions. Even more, non-compliance can also impact students, potentially leading to issues with financial aid eligibility or transferability of credits.

To ensure state authorization compliance, institutions must stay informed of the latest regulations and requirements in each state in which they operate. The professionals who complete this work often must work closely with legal counsel, regulatory affairs professionals, academic officers, faculty, and staff.

In recent months, the State Authorization Network’s (SAN) Special Interest Team (SIT) completed the study, 2023 Profile of a State Authorization Professional: An Analysis of a Growing Field in Higher Education. The study examined various work-specific/occupational variables of professionals in the field. The variables reviewed included job titles, degree attainment, salary, and job responsibilities.

While 276 compliance professionals participated in the study, two major themes emerged from their responses. The information gleaned from the study’s findings will help to inform future research and may be beneficial for higher education administrators when identifying professionals working in these areas who may need additional support, and when reimagining new compliance tools, or even pinpointing areas for improvement.

Key Research Themes

Theme 1: Salary Variations, Differing Job Titles, & Contrasting Job Duties

Distance Education Compliance Professionals play a vital role in ensuring that higher education institutions adhere to laws and regulations. As such, their expertise and skill set should be highly valued by institutions looking to avoid costly legal battles and maintain a good reputation. One would expect that individuals serving (successfully) in these roles would be compensated and respected accordingly. However, research indicates that the salaries for these professionals vary greatly and often correlate to one’s location, experience, title/position, educational attainment, and other factors.

One of the main factors that can influence a compliance professional’s salary is their title/position within the organization. For example, survey results reveal that the average salary for these compliance professionals in the United States is between $60,000 to $65,000 annually. However, this figure can range from as low as $25,000 for entry-level positions/titles such as “Coordinator” or “Assistant” to over $100,000 for those with senior-level roles/titles such as ‘Director, Assistant/Associate Vice Provost”. Interestingly, some of the lower salaries can be attributed to the 7% of these professionals who are employed only on a part-time basis.

An additional indicator of salary was educational attainment. Approximately 24% of research participants earned over $100,000 per year. However, many of those earners held advanced degrees (master’s or terminal degrees). Those with advanced degrees, such as a Master’s, Doctoral degree (EdD or PhD), Juris Doctor (JD) degree, etc., tend to command higher salaries than those with high school credentials, or even an Associate’s or Bachelor’s degree.

Regional Differences

textbox Further, as can be imagined, the region in which a person is employed impacts their salary. In the case of the 2023 survey, the majority of the data (54.3%) comes from a single region (the Southern Regional Education Board), while only 4.1% of the responses came from the New England Board of Higher Education (NEBHE) region. Although the survey was distributed nationally, the responses are not representative of all regions. Obtaining a more equal distribution of responses would allow salary data that is more reflective of the national landscape of State Authorization Professionals.

Further, as can be imagined, the region in which a person is employed impacts their salary. In the case of the 2023 survey, the majority of the data (54.3%) comes from a single region (the Southern Regional Education Board), while only 4.1% of the responses came from the New England Board of Higher Education (NEBHE) region. Although the survey was distributed nationally, the responses are not representative of all regions. Obtaining a more equal distribution of responses would allow salary data that is more reflective of the national landscape of State Authorization Professionals.

Job Duties

Higher education institutions often face financial constraints that make recruiting full-time staff and offering competitive salaries difficult. The financial challenges facing colleges and universities are immense. This situation can result in high workloads for existing staff.

As such, many compliance professionals report that they perform a myriad of duties.

Thus, the range and duties/tasks a person performs can impact salary. Accordingly, the survey results reveal that the overwhelming majority of respondents (92.5%) have additional responsibilities outside of state authorization and general compliance. As seen in the 2017 original survey, many of the respondents who earned over $100,000 were senior-level administrators who spent less than 10% of their time on state authorization or general compliance.

Theme 2: Policy and the Regulatory Landscape   

Approximately five years passed between the time of the original state authorization professional survey and the second. In that time, state authorization and distance education compliance requirements and responsibilities burgeoned and gained more focus at the national level. Also, during that time, the number of states and institutions participating in reciprocity through SARA (State Authorization Reciprocity Agreements) increased and we’ve seen a flurry of regulatory activity from the U.S. Department of Education. These regulations have added and modified institutional responsibilities relating to state authorization, distance education, professional licensure compliance, and tying compliance to eligibility for federal financial aid.

Additionally, institutions have become more aware of compliance obligations to the states when conducting out-of-state activities. And, importantly, as we globally persevered through the COVID-19 pandemic, which saw institutions of all kinds forced to quickly shift to emergency remote learning. Although data suggests that enrollment in distance education courses is not currently as high as it was during the pandemic, it does suggest that enrollment in distance education courses is higher now than pre-pandemic. Each of these factors, and many more, influence the responsibilities of State Authorization Compliance professionals at an institution.

As noted earlier, in the 2023 survey, most respondents (92.5%), indicated that they have additional responsibilities outside of state authorization and general compliance, compared to 80% from the 2017 survey. The additional responsibilities range from instructional design and faculty development to accreditation and student success. For a list of the additional responsibilities submitted by survey respondents, please refer to the expansive information in Appendix I of the report.

Between both surveys, the amount of time spent on state authorization work appears to remain consistent. In 2017, 56% of respondents spent 25% or less of their time on state authorization, while another 15% spent all their time on state authorization. In 2023, approximately 58% of respondents spent 20% or less of their time on state authorization, while only 4% spent all their time on state authorization. The increase in participation in reciprocity could account for the small decreases we see here.

However, a notable change came in terms of the time spent on professional licensure compliance. In 2017, 67% of respondents did not work on professional licensure at all. In 2023, the number of individuals not working on professional licensure at all had dropped to 13.7%, and 69% of respondents spent between 1-39% of their time on professional licensure, with 2.5% even spending all their time on professional licensure.

The major shifts we see in responsibility, especially the increase of professional licensure compliance duties added to the state authorization professional, show how this role is growing and adapting to the regulatory requirements relating to distance education and out-of-state activities. To participate in SARA, institutions have professional licensure compliance responsibilities. The U.S. Department of Education also has professional licensure compliance requirements tied to federal financial aid. It is important to note that the 2023 survey was completed before the final rules relating to certification procedures enhanced institutional obligations relating to professional licensure programs. If this survey is repeated in the coming years, we recommend an analysis of the impact of those regulations on the State Authorization Professional.

In future surveys and research opportunities, we believe it would be highly important to track the changes in a similar manner to those discussed above. Doing so, over time would allow us to better understand how these policy changes influence the responsibilities, salaries, and work environments of State Authorization and Distance Education Professionals.  

Leveraging the Survey Information: Addressing Staffing Needs

As many of the survey respondents noted that they often feel overwhelmed and understaffed due to the myriads of tasks required, and to the fact they operate as a “team of one”, we encourage all to utilize the survey information to benefit your role at the institution. Though the survey has limitations, we encourage institutions and state authorization professionals to analyze the data to assist in making informed decisions regarding staffing requirements, and to the scope and duties of the state authorization professional.

Group of professionals shaking hands

We also believe that this data can be used to better educate and inform administrators and/or senior-level leaders on the importance of the role. Moreover, some professionals have noted that they may utilize the survey data to justify the hiring of new staff. Therefore, utilizing the survey data to justify the hiring of new staff is a strategic approach that can provide valuable insights into the operational needs of an institution.

Because the survey results not only contain important details regarding the typical tasks required of these positions (such as: researching, analyzing regulations, completing complex state applications, data reporting, etc.), the data also provides insight into the timing and commitment required to complete said projects. Thus, the survey can really be of value to institutions and staff when establishing the scope of responsibilities typically handled by state authorization professionals so that job roles can be clearly defined and allocated more efficiently. This may include planning to ensure the institution has the necessary resources in place to support compliance, whether that be personnel or technological resources.

Expanding the Research 

The purpose of this study, like any research project, is to advance, challenge, and extend the existing knowledge in this field. However, our primary hope is that the experiences and insights shared by these professionals promote confidence and impart wisdom for newcomers to the field when considering regulatory, ethical, and operational opportunities. We also hope that this research will spark conversations among campus leaders about the importance of the work and the critical need for increasing budgets to expand compliance teams.

Even more, the research can be expanded to cover a number of additional topics. Because the field of state authorization and distance education compliance has grown rapidly over the past decade, institutions and their respective staff are still learning how to best develop these roles and empower these professionals to be successful.

That stated, as the field continues to grow, so does the opportunity to learn, grow, and gain experience about the trends in the role and how we might advance the research of the profession. Some possible avenues for the future that could expand on the research in meaningful ways include:

  • Region-specific challenges: Identify whether state authorization professionals face challenges specific to the region in which the institution is located (geographic region, urban/rural, etc.).
  • Role-specific challenges: Identify whether state authorization professionals face challenges specific to different types of institutions (public/nonprofit, large/small, etc.).
  • Impact of regulatory changes: Analyze the impact that regulatory or policy changes have had on the allocation of duties and resources at the institution.
  • Impact of technology: Investigate whether new tools or technologies are impacting the effectiveness of the role of the state authorization professional.
  • Work-life balance and job satisfaction: Investigate factors influencing work-life balance and job satisfaction among state authorization professionals.
  • Dive more deeply into team and/or departmental structure: Gain a better understanding of the impact of centralized vs. decentralized structures.
  • Risk Management: Understand the importance of risk assessments and management, note benchmarking strategies to mitigate risk, and utilize data analytics.
  • Career Development: Identify strategies to promote growth in the field, pinpointing areas that require additional training, development, and networking.

Concluding Thoughts

Maintaining compliance with distance education activities is vital for today’s colleges and universities. Failure to comply could lead to stiff fines, penalties, accreditation issues, and even the loss of Title IV eligibility. The individuals who bear the responsibility of ensuring compliance with the distance education-related regulatory standards/guidelines are critical to safeguarding the success and reputation of an institution.

Professional woman working at a computer

These compliance professionals often have a myriad of responsibilities and are also required to collaborate with numerous stakeholders. Their peers run the gamut of the General Council and Legal Departments, Financial Aid officials, Offices of Assessment and Accreditation, Provosts, Deans, and many more. Moreover, these professionals are responsible for interpreting and implementing federal, state, and local regulations that affect higher education institutions. Many of the individuals work closely with faculty, staff, and administrators to develop policies and procedures that ensure compliance with laws such as the Clery Act, Title IX, FERPA, and the Americans with Disabilities Act.

Not only must these professionals stay abreast of changing regulations, but also with industry standards/best practices from the field, so they can effectively manage compliance efforts. In addition to managing regulatory compliance, these professionals also contribute to the overall success of institutions by promoting a culture of ethics and accountability. They also provide training and resources to campus community members on compliance issues, and they investigate complaints and violations to ensure prompt resolution. Their expertise and dedication to compliance not only protects institutions from legal and financial risks, but also helps to foster equitable, safe, and inclusive environments for students, faculty, and staff.

By understanding the importance of these roles and how to fulfill them effectively, leaders in the academy can better serve their institutions. This research goes a long way to close the gap on the dearth of information that has long since permeated this field. The report also makes an important case for identifying the vast duties required for campuses to remain compliant with state and federal requirements.

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Policy

Navigating State Barriers: Challenges for Formerly Incarcerated Students in Licensing Programs

Post author By Lindsey Downs
Post date June 27, 2024

Higher education has an important role to play when it comes to providing information to students searching for educational programs that leads to a license or certification. In that light, what information should be provided by the institution to formerly incarcerated students who are looking for professional or licensure programs? While some states do have barriers that this student group must, many do not prohibit these students from accessing certain programs and may want to ensure they are providing the required and helpful information when needed.

We often hear the U.S. Department of Education (Department) express concern for a student’s “worthless degree.” Such a descriptor is typically applied when a student cannot gain employment in their chosen field. Public disclosures regarding state prohibitions to employment for formerly incarcerated individuals were addressed recently in new regulations for prison education programs for currently incarcerated individuals receiving Pell Grants. However, the question remains: how should colleges and universities support formerly incarcerated students who have enrolled at their institution? Many of these students need assistance and guidance to navigate the various state laws and processes to make informed decisions about education and career goals. Additionally, how can we support the students without requiring them to self-identify as formerly incarcerated individuals?

The State Authorization Network (SAN), as an organization that regularly addresses state variation of laws and regulations, determined that since states differ so widely, we should begin to address the differences and similarities of rules and regulations for licensed professions for employment of formerly incarcerated individuals. To pursue an initial review of the variations, SAN obtained the assistance of two undergraduate interns to compare a sample set of state rules, with the sample representing each region of the United States. We are pleased to welcome our guest contributors, Charisma Barrow and Chrischen Thompson, to share their findings on state processes and opportunities. 

As you will see from the interns’ preliminary research, states vary, as expected. However, what is consistent is that there are prohibitions for employment based on the incarceration status of the student. These students would have difficulty navigating the variations and requirements and may ultimately pursue a degree program for which they would be prohibited from seeking employment in the occupation. We hope that by sharing this preliminary research, institutions will consider how they share program information publicly to avert student disappointment if they encounter barriers to employment after completing the educational program.

Analysis by Charisma Barrow, Fayetteville State University

Researching the occupational licensing restrictions for recently incarcerated individuals in a specific set of states reveals variation in such restrictions among the states. The states analyzed in this section include:

  • California,
  • Minnesota,
  • New Jersey, and,
  • Wyoming,

State Comparisons

California stands out with its lenient approach, allowing inquiries into criminal history primarily when mandated by law or for positions in criminal justice. In contrast, Minnesota, New Jersey, and Wyoming impose stricter restrictions, often barring individuals from professions directly related to their convictions. For example, Minnesota restricts those convicted of offenses involving vulnerable adults from working in nursing homes, while New Jersey’s broad exclusions encompass various crimes of moral turpitude, which impacts a wide range of occupations. Wyoming’s rules also reflect a direct connection between the nature of the offense and professional duties, with long-term bans in place for certain severe crimes. Each state, however, offers programs to support the reintegration of ex-offenders into the workforce, highlighting efforts to balance public safety with the goal of reducing recidivism through gainful employment.

California

California has the most lenient restrictions when it comes to recently incarcerated individuals. Employers can only ask about an individual’s criminal history if the employer is a criminal justice agency, or a state or local agency required by law to conduct a criminal background check. A history of felonies, misdemeanors, and arrests are permitted to be requested for up to 7 years after conviction. Employers in California cannot inquire about marijuana convictions that are more than 2 years old. Juvenile criminal records are also off-limits to employers.

Recently, the California Workforce Development Board (CWDB) announced new opportunities in the state for training, education, career opportunities, and other supportive services for formerly incarcerated or otherwise justice related residents.

Minnesota

In the states of Minnesota, New Jersey, and Wyoming, a person can be barred from obtaining a license in a profession that directly corresponds to a previous conviction. For example, in Minnesota, if the offense involved a vulnerable adult, the individual would likely be unable to work in any position in a nursing home or group home. This also includes other occupations such as working security or law enforcement if the crime had anything to do with firearms. If the crime included money, the individual would be barred from working at a bank or other financial institution.

The Federal Reserve Bank of Minneapolis is working to help mitigate these barriers by assisting individuals who have criminal records in finding sustained, gainful employment to produce savings and other benefits for both the ex-offenders and society.

New Jersey

The New Jersey State Board of Medical Examiners and the New Jersey Bar will revoke or not allow a license to individuals convicted of a crime involving moral turpitude. These crimes include sexual assault, theft, domestic violence, fraud, forgery, theft, endangering the welfare of a child, manslaughter, tax evasion, and bribery. Those convicted of drug crimes and other offenses under the category of “moral turpitude” are barred by law from many positions, from public employees and firefighters to insurance adjusters. Said individuals would also be barred from obtaining a teaching license if they are guilty of all first and second-degree crimes, sexual offenses, certain drug offenses, and crimes against children. Many former prisoners will also have their driver’s license suspended 6 months to up to 2 years.

One way New Jersey is helping those impacted by these barriers is through the state’s career services. Here, they can help remove some of the common barriers to employment for ex-offenders, assisting with issues such as driver’s license restoration, referrals to community mental health programs, job search preparation classes that take place at halfway house facilities, and community release programs under Parole supervision.

Wyoming

In the state of Wyoming, a prior conviction cannot be considered regarding employment if the convictions are more than 20 years old, with a few exceptions. These exceptions include the person still being under a sentence, or the sentence was completed fewer than 10 years ago if the offense is “directly related to the specific duties and responsibilities of that profession or occupation.” Examples of this include convictions of violent crimes or sexual misconduct. In that case, that person will be barred from occupations such as teaching, being a guide, being a social worker, being a family or marriage counselor, being a nurse, chiropractor, or dental hygienist.

Wyoming’s Department of Corrections (WDOC) has implemented a release planning program for recently incarcerated individuals. Release planning includes several aspects, such as treatment, housing, supervision, employment, education, healthcare, and other services. The WDOC develops a transition plan by assessing the individual’s risk for recidivism and their treatment needs. Offenders identified as medium to high risk/special needs will have enhanced case management services, including additional release consultations, referrals, assistance with community transition, and additional case planning to address special needs and individual risk. The WDOC offers competency-based coursework designed to help students improve academic, vocational, or life skills.

Conclusion – Regulatory Spectrum for Supporting Students

In conclusion, the research into occupational licensing restrictions for recently incarcerated individuals across California, Minnesota, New Jersey, and Wyoming reveals a spectrum of regulatory approaches. California stands out for its leniency, allowing inquiries into criminal history primarily in positions mandated by law to conduct background checks. In contrast, Minnesota, New Jersey, and Wyoming impose stricter regulations, often barring individuals from certain professions directly related to their offenses. These states also offer various programs aimed at mitigating employment barriers for ex-offenders. The initiatives discussed above highlight ongoing efforts to balance public safety with rehabilitation and reintegration, underscoring the need for nuanced policies that support successful reentry while addressing societal concerns.

Analysis by Chrischen Thompson, University of Texas (UT)

This analysis examines the criminal justice reforms and barriers to reentry faced by individuals with criminal records in five U.S. states:

  • Colorado,
  • the District of Columbia (D.C.),
  • Louisiana,
  • Massachusetts, and,
  • Oklahoma.

State Comparisons

Each state presents unique challenges and approaches to addressing the complex issues surrounding reintegration into society for those with past convictions. By impartially examining their policies, reforms, and initiatives, we aim to highlight similarities, differences, and notable aspects while considering the need for a balanced approach that promotes rehabilitation and public safety.

Colorado

Colorado faces challenges in ensuring fair access to higher education and occupational licensing for individuals with criminal records.

Specific requirements based on sentence length and the disclosure of criminal histories during the college admission process hinder opportunities for incarcerated individuals.

Additionally, the absence of formal agreements for credit transfer complicates the reentry process for those seeking to continue their education (Johnson, 2020). While advocating for policy changes to expand educational opportunities, Colorado recognizes the importance of public safety considerations and may impose certain limitations based on the nature of offenses. Notable reforms include advocating for policy changes to abolish limits on sentence length for accessing postsecondary programs and prioritizing federal funding for education in correctional facilities.

District of Columbia (D.C.)

D.C. confronts substantial occupational licensing and postsecondary education obstacles for individuals with criminal records. Strict licensing regulations and limited access to federal financial aid exacerbate the challenges of reentry into society. However, community-based organizations and legal aid clinics are crucial in providing support and resources (Miller, 2019). D.C.’s approach includes advocating for policy changes to reform licensing laws and incorporating occupational licensing considerations into reentry planning while maintaining appropriate safeguards for public safety. Significant aspects of D.C.’s approach include advocating for policy changes to reform licensing laws and incorporating occupational licensing considerations into reentry planning.

Louisiana

Louisiana faces significant postsecondary education and occupational licensing barriers for individuals with criminal records. Strict occupational licensing regulations and moral turpitude clauses pose challenges, particularly in professions crucial to public safety and welfare. While supporting the rights of individuals with criminal histories through advocacy organizations, Louisiana also recognizes the necessity of considering public safety concerns when granting licenses for certain professions. Notable aspects include advocacy organizations such as Operation Restoration and Voice of the Experienced (VOTE), which both support the rights of individuals with criminal histories.

Massachusetts

Massachusetts has emerged as a leader in criminal justice reform, implementing strategies to remove barriers for individuals with criminal records seeking education and licensure opportunities. Example reforms include banning work placement denials based on convictions over five years old and preventing the use of certain criminal records in decision-making processes (Jones, 2020). It is essential to consider the nature and severity of infractions to strike a balance between promoting rehabilitation and upholding public safety standards. Massachusetts’ commitment to legal aid and advocacy organizations, reentry programs, and state-level policy reforms demonstrates a comprehensive framework for addressing barriers to education and licensure.

Oklahoma

Oklahoma has undertaken significant criminal justice reforms to reduce barriers for individuals with criminal records seeking education and occupational licenses. Notable reforms include banning work placement denials based on convictions over five years old and preventing the use of certain criminal records (Brown, 2019). While promoting reentry opportunities, the state maintains certain limitations and restrictions based on the severity of offenses, recognizing the importance of public safety considerations. Oklahoma’s focus on appeal rights for individuals with restricted licenses and data collection and reporting requirements highlights its commitment to transparency and accountability in the licensing process.

Comparative Analysis: Recognizing Common Themes and Differences

Different criminal justice reform approaches and reentry barriers are heterogeneous, especially across the five states included in this sample, but similarities can also be seen among others.  all of the states in this analysis emphasize discussion and consideration of the obstacles to attaining education and employment for people with criminal backgrounds and propose a balanced position addressing safety concerns at the same time.

Fairness and inclusivity in the resettlement process are two significant issues that have been repeatedly raised, as described in the development of state initiatives previously described, necessitating policy reforms and legal reforms to ensure justice. Some of the states have been successful through policy advocacy and law reform, such as Colorado, D. C., and Massachusetts. States like Louisiana and Oklahoma have adopted a different approach centered on community participation and supportive services that aim to remove systems of inequality and barriers to future employment.

Another reoccurring feature in this state sample was a focus on gathering and using data. Dealing with the collection and reporting of information is crucial for objective assessment of the challenges in each state and the impact of their initiatives. States like Massachusetts and Oklahoma are data-centric in their approach to continuous improvement of criminal checks on applicants by developing data collection and reporting capacity. This is part of the broader reforms they are initiating.

Although diverging programs and plans are adopted by individual states, there is still a general idea that is commonplace for all: the balance of supportive formerly incarcerated individuals and public safety concerns (Smith, 2020). For example, the Massachusetts ban using five-year or older convictions for workplace decisions, while also having safety measures in place in cases involving crimes likely to be detrimental to public peace.

By comparing each of these five states, we can see thatpeople with criminal pasts get the same opportunities as others, but will have different routes and hurdles to overcome when trying to complete their education and receive occupational licensing. Other states can draw inspiration from the fundamental matter of interest that all of these states hold, to ensure a smooth reintegration process for those living in their state who have served their sentences. In addition, these states can give concrete power to implement restrictions and regulations based on the nature and seriousness of the crime so that public security is safeguarded. The government uses different approaches and engagements to construct a support platform for releasing the prisons, with the essential well-being of the general society as the top priority simultaneously.

Next Steps from SAN

Licensure issues are complex, and we know it is important to support all students effectively in pursuing their career goals. Although this post did not address the new professional licensure regulations and amended notifications that will become effective in a few weeks (July 1, 2024!), SAN wants to remind you that we’ve got your back.

On our website, you will find a complete index of links to SAN compliance resources for professional licensure: SAN Compliance Resources to Address Federal Regulations for Programs Leading to a License (2024). Also, look for the 2nd Edition of the SAN Professional Licensure Handbook to be released soon!

Related to the analysis offered today, in the next year, SAN intends to offer a follow-up post here on WCET Frontiers that will consider the ethical responsibilities of institutions to provide public disclosures to inform undocumented students enrolling in programs that lead to a license or certification addressing state barriers to a license or employment. Additionally, SAN will provide more on the state prohibitions to employment for formerly incarcerated individuals. The Department’s regulation addressing eligible prison education programs is an initial model for disclosures. Effective July 1, 2023, in addition to other disclosure requirements required in federal regulations, 34 CR 668.43(a)(5)(vi) directs that an institution must provide a disclosure if the prison education program leads to a license or certification when there is a prohibition on the licensure or employment of the formerly incarcerated individuals in any other state. We plan to communicate with and share example processes from institutions that provide public disclosures to inform prospective and enrolled students of barriers and prohibitions.

Thank you to the SAN interns! Great job! More coming in 2025!

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Practice

Leveraging Emerging Technologies for Student Wellness in Distance Learning

Post author By Lindsey Downs
Post date June 25, 2024

I have tremendous respect for the innovative technologies and dedicated educators who tirelessly work to help their students achieve their educational goals. Today, I’m thrilled to welcome Julie Delich, who will share her insights on supporting virtual students. Julie will discuss practical steps that instructors and staff can implement, and she’ll also highlight important considerations for using emerging technologies, such as AI, in the classroom. Thank you, Julie, for these valuable ideas and strategies to help distance education students succeed!

Enjoy the read,

Lindsey Downs, WCET

While distance learning offers unique opportunities for institutions and students alike, it also presents challenges that require strategic solutions to ensure student wellness and success. As educators, we must harness emerging technologies to provide scalable, 24/7 support systems for our students.

By leveraging emerging technologies like AI, we can effectively guide students to create a culture of help-seeking behaviors and systems that support students staying on track throughout their educational journey.

Looking Ahead with Practical Steps

To address the multifaceted needs of students in distance learning, institutions can adopt several practical strategies:

  1. Increase the Capacity of Advising Staff – Balancing the student-to-advisor ratio ensures that students receive the personalized attention they need, and technology offers a path to increased advisor capacity.
  2. Offer Online Counseling – Providing accessible online counseling services allows students to seek help regardless of their location.
  3. Leverage Emerging Technology – Utilizing AI for conversations through chat or text can significantly enhance the students’ sense of connection to the institution.

Considerations For Emerging Tech

When integrating emerging technologies into student support frameworks, it’s important to consider the following:

  • Focus on the conversation, not just the tech. Tools should connect humans and accelerate conversations, not deflect them. For example, texting students can provide institutional leaders with rapid insights into student sentiment and well-being, covering areas like belonging, self-efficacy, and engagement.
  • Use Informal Insights to Constantly Improve. Continuous feedback mechanisms should be in place to capture informal insights from students. This enables institutions to make informed decisions and respond to emerging needs.
  • Build Systems for Crisis Intervention. Integrate systems that can identify and respond to crises promptly, ensuring students receive immediate support during critical times.

Ideas for AI Supported Student Support

Effective Text Nudging

Effective nudging involves building trust and fostering relationships between students and AI tools. Here are key strategies:

  • Establish trust to enable a relationship with AI. Establishing a parasocial relationship where students feel comfortable and trusting towards AI can enhance engagement.
  • Proactivity. Proactive outreach helps prevent issues before they arise, guiding students to take necessary actions in advance. Students don’t know what they don’t know.
  • Teach Emotional Literacy. Educating them on emotional literacy allows them to recognize situations where seeking help is beneficial. This includes teaching them to label and manage their emotions effectively.

Human Centered, AI Enhanced Coaching

Some institutions have begun embedding emotional intelligence into their proactive outreach.

For instance, research from The Partnership for Education Advancement, Norfolk State University, The Yale Center for Emotional Intelligence, and Mainstay demonstrates that “how you say it matters.”

This highlights the importance of using emotionally intelligent and culturally relevant language in increasing student engagement. This approach led to over 7,000 additional students actively engaging with AI coaching.

AI technology solutions like Mainstay offer AI success coaching and pulse checks, guiding students and understanding their evolving needs to help them persist throughout the student lifecycle. By integrating human centered design with AI capabilities, these tools create a supportive and responsive educational environment.

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Practice

Juneteenth, Higher Education, and Advancing Educational Equity

Post author By Lindsey Downs
Post date June 18, 2024
Silhouette of a person with the text: Do you know what Juneteenth is? it's the celebration of the end of slavery in the United States, marking the day when the last enslaved African Americans were free.

Juneteenth, celebrated annually on June 19th, marks a pivotal moment in American history—the day in 1865 when enslaved African Americans in Galveston, Texas, were informed of their freedom, years after the Emancipation Proclamation was signed. This day symbolizes the end of slavery in the United States and is a profound reminder of the resilience and enduring spirit of African Americans.

For educators, this day can inspire curriculum development, community engagement, and reflection on policies to ensure a commitment to equity and inclusion.

As we observe Juneteenth this week, I hope we can embrace the chance to educate ourselves and others about this important day. In line with that vision, WCET and Every Learner Everywhere present the following article on recognizing Juneteenth and offer ideas on how to integrate this important day into higher education settings.

Enjoy the read,
Lindsey Downs, WCET

Juneteenth is a pivotal moment in American history that commemorates the end of slavery and the ongoing pursuit of freedom and equality for all.

In the context of higher education, recognizing Juneteenth holds profound significance for advancing educational equity and ensuring every learner has access to transformative learning opportunities.

The Significance of Juneteenth in Higher Education

Juneteenth serves as a powerful reminder of the systemic barriers and injustices that have historically denied educational opportunities to Black Americans and other marginalized communities. It underscores the need for higher education institutions to actively dismantle these barriers and create inclusive learning environments that empower all students to thrive.

Celebrating Juneteenth on college campuses is an opportunity to:

  1. Acknowledge the Legacy of Oppression: By recognizing Juneteenth, institutions can confront the painful history of slavery and its enduring impact on access to education for Black communities. This acknowledgment is crucial for fostering understanding, healing, and progress.
  2. Promote Inclusive Curricula: Juneteenth encourages the integration of diverse perspectives and experiences into academic curricula, ensuring that the contributions and struggles of Black Americans are accurately represented and celebrated.
  3. Foster Dialogue and Understanding: Observing Juneteenth can facilitate open and honest conversations about race, equity, and social justice, fostering a deeper understanding among students, faculty, and staff.
  4. Inspire Ongoing Commitment to Equity: Juneteenth serves as a catalyst for higher education institutions to evaluate their policies, practices, and campus climate, and to take meaningful steps towards creating truly equitable and inclusive learning environments.

Juneteenth and Educational Freedom

The pursuit of educational freedom is inextricably linked to the broader struggle for civil rights and social justice. Juneteenth represents a pivotal moment in this ongoing journey, reminding us that true freedom cannot be achieved without equal access to quality education.

By recognizing Juneteenth, higher education institutions can:

  1. Increase Access and Affordability: Institutions can prioritize initiatives that remove financial barriers and provide support systems for underrepresented and marginalized students, ensuring that education is accessible to all.
  2. Foster Inclusive Campus Climates: Creating welcoming and supportive environments for diverse students, faculty, and staff is essential for promoting educational freedom and empowering individuals to reach their full potential.
  3. Amplify Diverse Voices and Perspectives: Celebrating Juneteenth encourages institutions to elevate the voices and experiences of Black scholars, educators, and students, enriching the academic discourse and promoting a more comprehensive understanding of freedom and equity.
  4. Inspire Civic Engagement and Leadership: By engaging with the principles of Juneteenth, institutions can empower students to become agents of change, equipped with the knowledge and skills to advocate for social justice and educational equity in their communities.

Supporting Students on Juneteenth

Institutions of higher education can better support minoritized student populations on Juneteenth in the following ways:

  1. Acknowledge the Historical Significance: Recognize Juneteenth as a pivotal moment in the ongoing struggle for freedom, civil rights, and educational equity for Black Americans. Host events, discussions, or exhibits that educate the campus community about the history and significance of Juneteenth.
  2. Amplify Black Voices and Experiences: Provide platforms for Black students, faculty, and staff to share their stories, perspectives, and experiences. Invite Black scholars, activists, or community leaders to speak about the importance of Juneteenth and its relevance to educational equity.
  3. Evaluate Institutional Policies and Practices: Conduct an honest assessment of institutional policies, practices, and campus climate to identify barriers and areas for improvement in supporting minoritized students, particularly Black students. Develop actionable plans to address systemic inequities and create more inclusive learning environments.
  4. Increase Representation and Support: Prioritize efforts to recruit and retain more Black faculty, staff, and administrators who can serve as mentors and role models for Black students. Provide comprehensive support services, such as academic advising, tutoring, and mental health resources, tailored to the unique needs of minoritized student populations.
  5. Foster Dialogue and Understanding: Facilitate open and honest conversations about race, equity, and social justice within the campus community. Encourage students, faculty, and staff to engage in difficult but necessary dialogues that promote understanding and foster a more inclusive campus culture.
  6. Collaborate with Community Partners: Establish partnerships with local organizations, community leaders, and advocacy groups working to advance educational equity for minoritized populations. Collaborate on initiatives, programs, and resources that support the success of these students.
  7. Commit to Ongoing Action: Treat Juneteenth not as a one-day event but as a catalyst for sustained efforts to dismantle systemic barriers and promote educational freedom for all students. Develop long-term strategies, allocate resources, and hold the institution accountable for creating equitable and inclusive learning environments.

By taking these steps, institutions of higher education can honor the spirit of Juneteenth and demonstrate a genuine commitment to supporting minoritized student populations, particularly Black students, in their pursuit of educational excellence and personal growth.

Integrating Juneteenth Into Curriculum

Institutions of higher education can integrate Juneteenth into their curriculum to enhance educational equity in the following ways:

  1. Incorporate Juneteenth into General Education Courses: Include discussions, readings, and assignments related to Juneteenth in relevant general education courses, such as American history, African American studies, sociology, and political science. This exposure can help all students understand the significance of Juneteenth and its connection to the ongoing struggle for racial justice and educational equity.
  2. Develop Juneteenth-Focused Courses: Offer dedicated courses that explore the historical context, cultural significance, and contemporary relevance of Juneteenth. These courses can delve into topics such as the legacy of slavery, the Civil Rights Movement, and the ongoing fight for racial equality in education and other spheres of society.
  3. Integrate Juneteenth into Disciplinary Curricula: Examine how Juneteenth and its themes intersect with various academic disciplines, such as literature, art, music, law, and public policy. This interdisciplinary approach can provide a more comprehensive understanding of Juneteenth’s impact and its connections to educational equity.
  4. Encourage Research and Scholarship: Support faculty and student research projects that investigate the historical, social, and educational implications of Juneteenth. This can contribute to a deeper understanding of the barriers faced by marginalized communities and inform strategies for promoting educational equity.
  5. Connect with Community Partners: Partner with local organizations, museums, and community leaders to develop co-curricular activities, events, and service-learning opportunities related to Juneteenth. This can foster stronger connections between the institution and the community, while providing students with hands-on learning experiences.
  6. Promote Inclusive Pedagogy: Encourage faculty to adopt inclusive teaching practices that incorporate diverse perspectives, experiences, and narratives related to Juneteenth and its significance. This can create a more inclusive and equitable learning environment for all students.
  7. Provide Professional Development: Offer professional development opportunities for faculty and staff to enhance their understanding of Juneteenth, its historical context, and its relevance to educational equity. This can equip educators with the knowledge and skills necessary to effectively integrate Juneteenth into the curriculum and campus culture.

By integrating Juneteenth into the curriculum and campus life, institutions of higher education can raise awareness, foster dialogue, and promote a deeper understanding of the ongoing struggle for educational equity and racial justice. This approach can empower students to become agents of change and contribute to the creation of more inclusive and equitable learning environments.

Recognizing Juneteenth in higher education is not merely a symbolic gesture; it is a commitment to actively dismantling systemic barriers, promoting inclusive excellence, and ensuring that every learner has the opportunity to pursue their educational aspirations freely and equitably.

Learn more about Juneteenth and Advancing Educational Equity:

Juneteenth: Freedom and Educational Equity

This blog was generated by Perplexity and modified by Every Learner Everywhere and WCET.

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Practice

Authenticity Inside and Outside the Classroom | Equipping and Training Business Students for The Real World

Post author By Lindsey Downs
Post date June 13, 2024

Here at WCET, we are thrilled when we have an opportunity delve deeper into the real-world impact of AI on higher education. To that end, we welcome Meg Barnes from the University of Mississippi’s School of Business, who joins as today to discuss the various ways (including with the help of AI) that their students learn and practice some of the most important workplace skills today. Thank you Meg for sharing about these excellent practices.

Enjoy the read,

Lindsey Downs, WCET

How the University of Mississippi’s School of Business exposes, trains, and equips students in authenticity.

Image Source: Ali Hensley

In a world where individuals are often overwhelmed by digital messaging or synthetic media or disengaged from the tangible world, how can educators guide students in honing, seeking, and delivering authenticity in the real world?

Graphic looking like a dictionary entry for "real world," "noun," definition: “the realm of practical or actual experience, as opposed to the abstract, theoretical, or idealized sphere of the classroom, laboratory, etc” (Dictionary.com, 2024).

Educators have a call to action to integrate authenticity in the current technological and AI era through our lesson plans and curriculum. This case study offers emerging educational lessons and initial stages in infusing authenticity into our business communication course.

Authenticity may be generally described as being genuine about one’s business and real with others. Authenticity can be built and propelled by practical self-knowledge and self-awareness, relevance to the task, genuineness, context, and strategies regarding disclosures (Rosh & Offermann, 2013).

Seeking Authenticity and Honing Critical Thinking

Innovative responses to digital communication, AI, and technology in education, such as fostering critical thinking about information, are crucial. Teaching approaches include encouraging the evaluation of information and compelling students to reflect upon ethical implications (Woodring, 2023). Moreover, faculty play a pivotal role in this process, challenging students to question and doubt while searching for relevant and dependable information. 

There is an ever increasing expectation of launching job-ready candidates quickly post course/program/certificate completion. Therefore, there is also a focus on helping students reconcile their learning and transfer their knowledge, skills, and experiences to different contexts, such as a work setting. Billett (2015) has proposed the need for authentic experiences and instances integrated within the overall college curriculum; his educational research highlights the power of authentic experiences by students in both pedagogic and occupational practices.

At the University of Mississippi’s School of Business, we value experiences that help our students develop these important skills. Our university’s Quality Enhancement Plan (QEP) targets critical thinking. One tenet of this plan includes: “Gather pertinent facts or ideas to explore complex issues or problems,” and an associated learning outcome from the rubric includes “credible sources” (Think Forward, 2019, p. 94). 

As a fun and impactful activity in the business communication curriculum, students explore and ponder the question of a credible source – Who is an influencer, expert, or authority? We provide a sample video by a popular YouTuber. As a class, we explore the video, the individual’s LinkedIn profile. Then we consider the YouTuber’s disclaimer in their video and their disclosure statement: “One big disclaimer here. I’m not a financial advisor. I’m a guy on the internet; the ideas presented in this video are for entertainment purposes only. You (and only you) are responsible for the financial decisions that you make” (Nate O’Brien, 2023).

To explore credible sources further, our business librarian has created a specific video titled “Is this source legit? Verifying Author/Creator Authority.” 

“Finding credible sources can be challenging because so much information is readily available that appears legitimate on the surface. Students need to be skeptical of information not coming from vetted sources. You may find exactly what you’re looking for in Google search, but before you use it, you need to verify the authority and background of the author or entity. If you are unsure about a source’s credibility, contact your librarian.”

– Ashley Dees, University of Mississippi, Research & Instruction Librarian and Associate Professor

Informational Gathering – Gauging for Biases – Ethical Communication

In addition to the critical thinking experiences, students in our business communication course are introduced to ethical communication with decision-making and self-awareness. Micro-skills are targeted for developing strong and ethical questions, , reflective skepticism, gathering relevant information, challenging assumptions, fresh perspective building, mitigating biases, weighing evidence, and purposeful strategic steps (Saltzman, 2020). The course is infused with ethical principles, emphasizing practical and real-world applications of ethics, such as surfacing one’s biases and the importance of integrity (McCombs School of Business – The University of Texas at Austin, 2024).

As part of the course, students are given the opportunity to earn certificates through LinkedIn. The students are given a menu of choices and guided through the course and certification process, which helps them build the skills needed for the digital economy (LinkedIn, 2024); these relevant skills include generative AI and human skills, such as critical thinking and decision-making, communication and listening, writing, creativity, unconscious bias, and trust. The students in the course (or our Bcom course) take the PrinciplesYou assessment to discover and evaluate their interactional style, specific archetypes, and how they “prefer to think, engage with others, and apply yourself” (PrinciplesYou, 2024). Educators integrate videos, case studies, tech platforms, assessments, and common reads of Influence and Give & Take. The goal is to integrate real-life applications throughout the business communication course. These lesson plans aim to help students gain self-awareness, grow in authenticity and business acumen, and consider how to make sound decisions in real-life situations.

AI and Personalized Student Feedback

The use of Artificial Intelligence (AI) has increased exponentially over the last few years. AI is being used in so many contexts, especially in teaching and learning and work environments. As these tools will need to be used by our students when they step out into the workplace, it’s imperative that faculty and staff help prepare them during their educational journey.

To improve delivery and authenticity conveyed through the virtual world, individuals need to know the role and use of AI. One of the ways our faculty and instructors introduce students to AI is to help students learn how to use AI programs that give feedback on student presentation skills. Faculty can implement several strategies, such as showing examples of successful presentations by others, offering professional tips, giving constructive feedback, and the opportunity (Jaser et al., 2022) to test drive AI. Business communication courses allow low-stakes assessments to connect and engage with a virtual audience in preparation for higher stakes situations in the digital world as the students develop their career progression with future recruiters, managers, and team members.

The Big Interview platform is a job training tool for students to practice their interview and presentation skills. Its artificial intelligence evaluates a presenter’s delivery and content in areas such as relevance of an answer to a question, rate of speech, filler counter, sophisticated vocabulary, power words, pauses, eye contact, negative tone, length of response, authenticity, volume, and lighting.

“Big Interview has been an invaluable tool to help our students prepare for virtual interviews. One area that can be difficult to showcase in an online interview is your authentic self. Through both instructor and AI feedback, we can coach students to convey their true personality and unique strengths, ensuring they present a genuine and confident version of themselves during the interview.”

– Wesley Dickens, University of Mississippi, Associate Director of Experiential Learning & Partnerships and Business Communication Faculty
Source: MLB slide with Big Interview logo and criteria

Real-world simulations build toward authentic oral delivery by students

Big Interview is a popular simulation and traditional job training tool for interviews and a novel use application for presentation skills with smart scoring of self-presentation criteria. It helps students learn how to stand out from others by providing instant feedback, bot scoring, concrete advice, and a personalized action plan to improve responses (Big Interview, 2024). Big Interview is designed to boost confidence, impress bots and real-life reviewers, and equip students for communication in their future workplace. Powerful features include feedback regarding authenticity and behaviors associated with authentic gestures and delivery. These virtual asynchronous simulations are designed to prepare students for presentations. The practice and assignment sessions provide 360° feedback for students with instructor review, self-review, other-review, and AI scoring.

Insights from the University of Mississippi in practicing and delivering authentic communication

The resurgence of real-world authenticity in the digital communication landscape

The Ole Miss Business Communication undergraduate curriculum is a sophomore-level course, but the students include those in traditional sophomore status from the accumulation of campus course credits and, more recently, dual enrollment students with a sophomore status who may be taking courses on the campus for the first time. These students are in the early stages of learning about their communication, delivery, and engagement styles. From a snapshot of the aggregated data of students, the smart scorings for most of our business students were in the Silver tier, with Gold and Bronze following.

Source: MLB slide with Big Interview smart scoring tiers

From the Big Interview simulated sessions and gathering of comments from these students, the following impacts surfaced:

  • Bolstering of self-efficacy with business communication, a belief in one’s ability to achieve tasks and succeed with their goals,
  • Addressing anxiety when speaking and using tech platforms, and
  • Developing an understanding of self-presentation skills for “real life” applications or “workplace interactions.”

Students Comments

The most interesting part about this business communications course would probably be the virtual experiences and the interviews. Those both stood out to me because I took the most away from them. 

The most interesting aspect of the material was the AI feedback. I realized the importance of maintaining eye contact during interviews and focusing on the end goal.

I will remember the Big Interview interactions. These really helped me understand how to act and present myself in a real-life interview through the mock-interview type questions and video replies.

Public and professional speaking is already something that makes me nervous and having to answer a certain way and get graded was very nerve racking. I think videoing myself and having to make eye contact with the camera was a big reason it was challenging…I had to avoid eye contact with myself on the screen because I would lose my concentration.

I will remember the knowledge I gained about interviews through Big Interview. Big Interview taught me a lot about the importance of preparing for an interview. The importance of answering questions honestly, selling yourself, maintaining eye contact are all useful tools in being successful in pursuing a job you want.

I think my biggest improvement was eye contact during presentations. I have always been a good speaker, but for online/video presentations, my eye contact has always been a weakness.

The “Big Interview” section (in) this business communication course (is the) most exhilarating, influential, and impactful component. “Big Interview” instructs students how to arrive at interviews, speak with clarity and sophistication (about) important interview and workplace interactions, dress accordingly, and respectfully relate to superiors and subordinates.

I believe that the Big Interview program is something that I will remember for the rest of my life. The tips that were shared with me throughout that process are something I will use throughout my entire career.

This Big Interview data, comments, and themes from Ole Miss Business School mirrored the positive results found in a study conducted by Western Carolina University. The researchers in this study noted the benefits for students from these virtual simulations included:

  • Communication skill development,
  • Critical thinking,
  • Self-awareness,
  • Personalized action plan from bot scoring to improve and craft one’s responses and delivery (Fulk et al., 2022; WCU.edu, 2023).

Real World, This Way – Integrating the Authentic Experience into Course Design

With the increasing exposure and use of artificial intelligence, the demands of digital communication, and the accelerated pace of our work and home lives, an expected resurgence and appreciation of authenticity is likely. Educators have an opportunity to guide and build confidence with students through this emerging era. It is exciting to see the opportunities offered by innovations such as AI.

We can venture beyond the confines of a more controlled and traditional academic method; it’s time to consider creative approaches, innovative resources, and diverse pathways to train and point students toward their future.

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Policy

In Defense of Distance Education – A Joint Letter to the Department of Education & Call to Action

Post author By Lindsey Downs
Post date June 4, 2024
ACT NOW! Waiting until the official comment period for these proposed regulations will be too late.

On June 4, several leading higher education organizations jointly submitted a letter to the Department of Education outlining concerns and support for recent regulatory proposals.

The letter focuses on proposals discussed during the Department’s Program Integrity and Institutional Quality negotiated rulemaking sessions. It addresses suggested new compliance requirements for postsecondary distance education courses and programs. The organizations, including WCET, jointly detailed concerns about those proposals and state support for other recommendations discussed in rulemaking.

Higher education organizations jointly suggest alternatives to recent rulemaking proposals for distance education courses and programs and voice support for other proposals.

Our main concerns focus on proposals to:

  • require attendance-taking for all distance education courses, and,
  • disallow asynchronous courses in clock-hour programs.

We understand the Department’s goals to protect students as consumers and to safeguard Title IV financial aid expenditures.

For our areas of concern, we suggest alternative pathways to reach the Department’s objectives.

This letter is the second of two letters sent to the Department on behalf of these partners. The May 1, 2024 letter addressed proposals regarding reciprocity agreements for state authorization that were discussed during this same rulemaking.

The Partners in the Letter

WCET and the State Authorization Network (SAN) partnered with OLC, Quality Matters, and UPCEA to highlight concerns that our members have raised. We are also pleased to be supported by the Distance Education Accrediting Commission (DEAC) and the American Association of Community Colleges (AACC).

The Issues Where We Raised Concerns

The letter focuses on issues that concern the institutions that are our WCET and SAN members. There is also considerable attention to the impact the proposals will have on our students. The two concerns from the rulemaking proposals are:

  • Require Attendance-taking for All Distance Education Courses –
    • Proposed During Rulemaking: Currently, institutions are to determine the “last date of attendance” for a student who withdraws from an institution without notice. For distance education courses, logins do not count. The institution is required to provide evidence of the student’s last date of “academic engagement” (e.g., taking a test, submitting a paper, participating in an online discussion about course content). The Department is concerned that some institutions are not calculating the “last date of attendance” properly or are gaming the calculation for institutional financial gain. 
    • Concerns: Although requested by negotiators, almost no data on the extent of non-compliance instances was presented. The Department posited that this would “simplify” the calculations. With the exception of institutions that are fully online or already are attendance-taking institutions, everyone we contacted has indicated this would be far more work to obtain the same proof of academic engagement as most institutions already successfully provide. Also, the requirement to document a student’s withdrawal after 14 days of no academic engagement has been cited as adding more work and not being friendly to non-traditional students.
  • Disallow Asynchronous Courses in Clock Hour Programs –
    • Proposed During Rulemaking: For institutions using the clock-hour method of financial aid distribution, the Department is concerned that many institutions were not properly tracking the time spent by students in asynchronous instructional activities. The Department proposed disallowing asynchronous courses in clock-hour programs. This would NOT have any impact on asynchronous courses in credit hour institutions.
    • Concerns: The Department noted that some institutions have spent considerable time and money to comply. Punishing them for the non-compliance of others seems unwise.

The Issues We Support, With Some Caveats

Our letter expresses our support for some of the proposals discussed during rulemaking:

  • Redefining the accreditation thresholds for “substantive change” reviews for distance education programs. A caveat is that the review for institutions that enroll 50% or more of their students at a distance (as they define it) will probably include the great majority of institutions.
  • Defining a distance education course. This is a good first step to cleaning up the confusing multiplicity of distance education definitions used by the Department.
  • Categorizing distance education programs into a “virtual location.” This will mainly help the Department collect data about distance education, but our caveat is our concern about how the Department will interpret that data.

A Call to Action

As advocated in a previous WCET Frontiers blog post, we urged distance education institutions to take action. That blog post includes links to four issue papers that you can use for additional information.

If you have opinions on the proposals highlighted in this letter or our previous one, we urge you to act now.

In a recent webcast, Department personnel asked for stories on the impact of these proposals. They need your real-world insights about the impact the proposals (if implemented) will have on your institution, your programs, and your students. You should:

  • Review current processes to determine what changes might need to be made should the proposed language be finalized as regulations.
  • Work with your government relations department to contact your federal and state elected officials.
  • Tell a story about how a proposal might affect your institution and your students. What is the impact of curtailing reciprocity? Will taking roll in online courses “simplify” your lives? If you are a clock-hour institution, who will be hurt by disallowing asynchronous courses?

Emails or Letters can be sent to:

Miguel Cardona
Secretary of Education
Miguel.Cardona@ed.gov

James Kvaal
Under Secretary of Education
James.kvaal@ed.gov

U.S. Department of Education
400 Maryland Ave. SW
Washington, DC 20202

Waiting for the official comment period will be too late. Let the Department know and inform your elected Representatives and Senators.

– Cheryl Dowd, Russ Poulin, and Van Davis

Additional Resources on the 2024 Department of Education Rulemaking

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Event

Join the Conversation: Register Now for “Distance Ed at a Crossroads”

Post author By Lindsey Downs
Post date May 29, 2024
Distance Ed at a Crossroads graphic

In the ever-evolving education landscape, staying informed about the latest trends, challenges, and opportunities is crucial for educators, administrators, and policymakers. We support the Department of Education’s goals in protecting students and financial aid expenditures. Some proposed changes are right on the mark while others may cause more harm than good.

If you’re passionate about distance education and eager to navigate the changing regulatory landscape, then WCET and SAN’s upcoming meeting – Distance Ed at a Crossroads: The Changing Landscape of New Regulations – is an event you won’t want to miss.

What is this? Why should I attend?

This face-to-face event, hosted by WCET (the WICHE Cooperative for Educational Technologies) and SAN (the State Authorization Network), brings together experts and thought leaders to explore possible changes to the regulations shaping the future of distance education.

Group of people watching a presentation

Topics will include consideration of the proposed regulations, including:

  • Requiring attendance taking for ALL distance education courses.
  • For institutions participating in a distance education reciprocity agreement:
    • Limit of 500 students enrolled by the institution in a state for two consecutive years for the institution to maintain state authorization through reciprocity.
    • Requiring that the institution comply with any state-specific closure laws in the state where the student is located such as paying a surety bond, paying into a tuition recovery fund, or meeting the state records retention requirements or teach-out plans.
  • Creating a “virtual location” and other requirements to assist the Department in collecting more data about distance education programs and students.
  • Disallowing the use of Title IV financial aid for asynchronous courses in programs that use the clock hour method.
  • Changing the thresholds for accreditation “substantive change” approvals for distance education programs.
  • Limiting the ability for institutions to include books, materials, or supplies in tuition and fees. Only incarcerated students or students who opt into such programs will have those charges included in tuition and fees if the costs of those materials are at or below market value.

Some questions to spark your interest:

1. Are you up to date on the latest proposed regulatory changes affecting distance education?

2. How can we ensure equitable access to high-quality online education while maintaining regulatory compliance?

3. What are the possible implications of the Department’s proposals for online students and programs?

4. Are you prepared to navigate possible changes to state authorization reciprocity for interstate distance education?

5. How do you communicate these proposals and their possible impact to colleagues and leaders at your institution?

6. How might these changes benefit your students…and your institution?

At this one-and-a-half-day event, we will:

  • Empower you and your institution with a more comprehensive understanding of the current regulatory landscape.
  • Explore innovative approaches to address student access challenges and promote inclusivity in online learning environments.
  • Consider how to align institutional practices with accreditation requirements.
  • Discover best practices for ensuring compliance with state regulations and fostering interstate collaboration in online education.
  • As a community, identify proactive measures to protect student data and explore emerging trends that will equip us with the tools necessary to uphold regulatory standards.

Join “Distance Ed at a Crossroads” to gain insights on online learning regulatory compliance from experts and peers. Register now to save your seat!

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Policy

Ready or Not, Here It Comes! New Regulations When Offering Programs Leading to a License Effective July 1!

Post author By Lindsey Downs
Post date May 16, 2024

There is no more hiding from the eventuality of the effective date for new Federal regulations affecting the institutions serving students in programs leading to a license or certification. Institutions and the U.S. Department of Education (Department) have a common goal to support a student participating in an educational program leading to a state license to complete the state educational requirements to pursue their goal of becoming employed in the occupation for which they were trained and educated.

However, there has been some confusion about the new rules developed for student protection that were designed without input from the professional licensing community. In this post, we will attempt to unpack the rules and suggest implementation strategies while we continue waiting for the topical FAQ as promised by the Department.

In a nutshell, the institution must now do more than provide notifications as required by Federal regulations effective July 1, 2020, for students enrolled in licensed programs.

For a program leading to a license or certification to be eligible for Title IV – the institution must satisfy state educational requirements: Where the institution is located. Where the student enrolled in distance education; On or after July 1, 2024, Is located at the initial time of enrollment. OR Where the student attests that they intend to seek employment.

The new and amended regulations, developed from the Winter 2022 negotiated rulemaking and released as final on October 31, 2023, elevate the responsibility of the institution to certify as provided below for the Program Participation Agreement (PPA) in addition to providing notifications. The additional requirement in the PPA is as follows:

On April 9, 2024, the Department released (GE-24-03) Updates on New Regulatory Provisions Related to Certification Procedures and Ability-to-Benefit. This announcement directs that, before the July 1, 2024, effective date of the regulation, the institution should document any specific barrier to compliance beyond the institution’s control. The Department, in the event of a review or audit, will consider the reason for not complying to determine if any consequences are warranted. This is a limited circumstance compliance extension as the Department expects full compliance related to the documented difficulty by January 1, 2025.

We provided an analysis of the rule when it was released: New Federal Regulations, Part 1: Addressing Programs Leading to a License or Certification.

History of the Rules

visual of timeline of regulations. see link in end of this section to download full text.

Our readers may recall that the development of a federal regulation to address programs leading to a license was first discussed in the 2014 Negotiated Rulemaking when the committee addressed state authorization. That committee did not reach consensus. However, the Department wrote and released a proposed rule in July 2016, then released the final rule in December 2016, which missed the master calendar deadline. This postponed the effective date until July 1, 2018. The administration changed and the Department sought to delay the state authorization-related rules on the eve of the effective date in 2018. The Department maintained that the reason for the delay was to hold another rulemaking to address flawed terms that needed to be revised. Court drama ensued and the delay was vacated by the U.S. District Court, and the flawed regulations became effective for about thirteen months from late May 2019 until July 1, 2020.

Before the previously delayed flawed rules became effective, the 2019 Negotiated Rulemaking concluded with a new set of state authorization rules by negotiated rulemaking committee consensus to replace the flawed rules. Among the state authorization rules were new professional licensure notification regulations that became effective July 1, 2020.

A year later, the 2021- 2022 rulemaking announcement included the issue: Certification Procedures. The sub-issue of programs leading to a license had not been announced but was included in the Certification Procedures week one issue paper released for initial negotiator discussions. Despite no consensus, the Department moved forward with primarily the same language a little more than a year later in the May 2023 proposed regulations. These were to add institutional responsibilities to the Program Participation Agreement and slightly amend the notification regulation. When the final regulations were released on October 31, 2023, there was a revision to allow for student attestation.

Throughout this history of the rules, the various members of the professional licensing community, including the various state boards, were not advised or included in the discussions to develop a regulation to support and protect future practitioners.

Download the text for the visual timeline.

Elements of the New and Amended Requirements

New Certification Procedures Regulation to Satisfy State Educational Requirements

Through new regulations, the Department intended to increase the rigor of procedures for the institution’s certification to participate in federal aid programs.The Program Participation Agreement (PPA) is the agreement between the institution and the Department that specifies the conditions of the institution’s participation upon compliance with the provisions of the agreement. Consequences for failure to comply could include an impact on future participation in Title IV programs, fines, and repayment of misspent funds.

The new regulation addressing programs leading to a license or certification is among the new provisions of the PPA. Because the Code of Federal Regulations does not update to include a searchable weblink until the regulations are effective (July 1, 2024), the regulation is provided here with some language in bold for emphasis pertaining to professional licensure programs.

34 CFR 668.14(b)(32)

(32) In each State in which: the institution is located; for students enrolled by the institution in distance education or correspondence courses are located, as determined at the time of initial enrollment in accordance with 34 CFR 600.9(c)(2); or for the purposes of paragraphs (b)(32)(i) and (ii) of this section, each student who enrolls in a program on or after July 1, 2024, and attests that they intend to seek employment, the institution must determine that each program eligible for title IV, HEA program funds—

  • Is programmatically accredited if the State or a Federal agency requires such accreditation, including as a condition for employment in the occupation for which the program prepares the student, or is programmatically pre-accredited when programmatic pre-accreditation is sufficient according to the State or Federal agency;
  • Satisfies the applicable educational requirements for professional licensure or certification requirements in the State so that a student who enrolls in the program, and seeks employment in that State after completing the program, qualifies to take any licensure or certification exam that is needed for the student to practice or find employment in an occupation that the program prepares students to enter; And
  • Complies with all State laws related to closure, including record retention, teach-out plans or agreements, and tuition recovery funds or surety bonds;

These regulations are intended to address all modalities but will have the largest impact on institutions serving students through interstate distance education.

Institutions will no longer be able to serve students in states where the institution does not satisfy state educational requirements except under limited circumstances. This is worth repeating. Although institutions have been serving students across state lines by providing notifications and subject to any state approvals, of course, the institution must now only serve students in states where the institution does, in fact, satisfy the state educational requirements in the state where the student is located.

There are nuances to the statements provided above.

  1. The new rule is not retroactive as it applies to students enrolled on or after July 1, 2024. This is important as it means that there are no new barriers for the student currently enrolled to continue their program.
  2. The rule is narrowly focused on a very specific point in time – “the time of initial enrollment.” The institution’s obligation to satisfy state educational requirements is tied to the time of initial enrollment.
    • The responsibility of the institution to know the location at the time of initial enrollment should correspond to the structure of the institution’s process for determination of location as has been required by 34 CFR 600.9 (c)(2) since July 1, 2020.
    • In the preamble of the final rules, the Department indicated that they recognize that laws change, and students move. Therefore, although the institution satisfied state educational requirements at the time of initial enrollment, if there is a change of law or change of location, the institution may continue to serve the student. The institution must provide the required notifications as indicated below.
  3. The attestation option provided in the regulation directs that a student may be served even if the institution cannot satisfy state educational requirements where they are located IF the student attests that they intend to seek employment in another state and the institution can satisfy state educational requirements in that state. PROCEED WITH CAUTION!
a medical professional helping a patient

The Department has identified triggers for distance education to satisfy state educational requirements. The State Authorization Network (SAN) and many of its members have communicated directly with the Department designated contact for Certification Procedures, who has been very responsive.

We have learned through these communications that the Department maintains that if the student is participating in even ONE course by distance education at the time of initial enrollment, the institution is responsible for satisfying state educational requirements of the state where the student is located. This becomes complicated, especially for institutions that sit near a state line. The institution may have students crossing a state line to participate in the professional licensure program face-to-face on campus but take one online course that could even be a general education course or an elective.

Consider this scenario:

  • A student is enrolled in a healthcare-related program that leads to a license for which all related courses are offered only on campus at George Washington University in Washington, D.C.
  • However, the student lives across the Potomac River in Arlington, Virginia, and commutes across the river and state line to class each day. (Commuting to DC from Virginia is not unusual)
  • The student is also enrolled in one online course in let’s say History of Rome for a general education course at the time of initial enrollment (in the first term).
  • The Department considers the location for the distance education course to be Virginia and therefore triggers the institution to be responsible for satisfying state educational requirements in Virginia.
  • Read that again if you need to.
  • If that same student enrolled in ALL courses only on campus at George Washington University in the first term and saves the online course in History of Rome until the next term, there would be no trigger to satisfy state educational requirements in Virginia because the next term would be after the initial time of enrollment.
  • Do not confuse this fact pattern with the situation where an out-of-state student moves to the state where the institution is located to be fully located in the same state or in this case, District of Columbia, to be a resident student. There is no trigger in this case.

The moral of the story, the regulation to satisfy state educational requirements for the PPA is focused on a very specific point in time. Institutions near a state line may want to consider how to address this point in time for its commuter students.

Attestation

As mentioned above, the regulation includes an option for institutions to serve a student where the institution does not satisfy requirements IF the student attests that they intend to seek employment in a different state and the institution can satisfy state educational requirements in that state. Please note that this is an option and may not be applicable for all students.

The Department indicated in the preamble that they addressed public comments regarding situations where a student is located temporarily in a state and intends to seek employment elsewhere. The Department indicated that they were not inclined for the student to simply provide an acknowledgment that they understand the institution does not satisfy state educational requirements where the student is located. However, the Department did accept that at the time of initial enrollment an attestation that the student indicates a specific state that they intend to seek employment, and the institution can satisfy state educational requirements of that state. There are caveats and nuances presented in the preamble.

Caveats & Nuances:

  1. The goal is sufficient proof from the students themselves of their plans.
  2. Need more than the mere presence of such an attestation alone.
  3. The Department is very focused on how the information was conveyed such that it must be clear that the student understands this attestation.
  4. No new attestation is required if the student moves or changes their mind about future employment location.

We urge institutions to proceed with caution and document well with the attestation option. The attestation is intended to be an option that is a legal acknowledgment of the STUDENT’S location choice for employment and a verification that proper process was followed. We have heard that there are some institutions offering students the choice of where the institution satisfies state educational requirements and encouraging the student to choose from that list and then attest to one of those states. Our opinion is that institutional direction is not the objective of this option in regulation, and we encourage institutions to focus on the voluntariness of the student’s intention of location to seek employment.

Licensing Compacts and Multi-State Agreements

In preamble guidance, the Department indicated that they consider licensing compacts and multi-state agreements/reciprocity to all be forms of licensure. Therefore, it is unnecessary to capture this concept in the regulation. This creates an option in guidance to satisfy the requirements of the regulation. BIG CAUTION FLAG!

First, please note that we are not talking about reciprocity for institutional approval which we know as SARA. This type of reciprocity/agreement/compact addresses programs.

Second, the Department indicated that their policy concerns are addressed if the student can obtain a license through reciprocity that allows them to work in the state where the student is located (as covered by the requirements of the regulation). The Department also indicated that this could be through a full license or a provisional license. The main point is the ability to obtain employment without having to complete any additional requirements or go through a waiting period before being able to be employed.

Third, institutions should carefully review and understand the compact or multi-state agreement privileges and requirements particular to each license, so that the student’s ability to obtain the license in one state corresponds to the ability to be employed or transfer the license to another state. Just because the states are members of the agreement or compact does not necessarily mean that the particular license is transferable. Institutions must complete the research on the compact or agreement and document the implementation well.

Notifications Still Required

The related notifications for educational programs leading to a license or certification have been slightly amended. Institutions must continue to provide public notifications and direct or individualized notifications. The only substantive change is that public notifications are now only required for states where the institution has determined that the institution meets or does not meet state educational requirements. The institution does not need to address all states and territories and is not required to publicly list states for which the institution has not made a determination on whether the institution meets state educational requirements.

The Department provided in the preamble that the notification:

“applies to the States where institutions are enrolling students and where they are either living at the time of initial enrollment or where they attest that they wish to live. If an institution is not enrolling students from a given State, it is not obligated to determine anything regarding that State; it just cannot offer the program to anyone in that State.”

To determine the educational programs which are subject to the notification requirements, the Department directed by email from the Department contact that the structure provided in the regulation applicable for notifications is also applicable for the programs that must be assessed for the PPA. The regulation found in 34 CFR 668.43(a)(5)(v) reads like a checklist that an institution can review to determine whether the program is applicable. This is especially important for programs that have optional licenses or have post-graduation requirements to obtain a license or certification.

We believe it is important to review each of your programs to determine if this regulation applies. We have added bullets and bolded terms in the language of the regulation below to show the checklist structure to determine the responsibility to provide notifications and programs subject to the new PPA requirements. The Federal Register announcement links are provided below for the language that will be put in the Code of Federal Regulations on July 1, 2024.

34CFR 668.43(a)(5)(v) as amended for July 1, 2024:

“If an educational program is

  1. designed to meet educational requirements
  2. for a specific professional license or certification that is
  3. required for employment in an occupation,
  4. or is advertised as meeting such requirements,
  5. a list of all States where the institution has determined,
  6. including as part of the institution’s obligation under § 668.14(b)(32),
  7. that the program does and does not meet such requirements;”

Additionally, direct, or individualized notifications are still required for prospective and currently enrolled students with no substantive change.

34 CFR 668.43 (c) as amended for July 1, 2024:

“(c)(1) If the institution has made a determination under paragraph (a)(5)(v) of this section that the program’s curriculum does not meet the State educational requirements for licensure or certification in the State in which a prospective student is located, or if the institution has not made a determination regarding whether the program’s curriculum meets the State educational requirements for licensure or certification, the institution must provide notice to that effect to the student prior to the student’s enrollment in the institution in accordance with § 668.14(b)(32).

(2) If the institution makes a determination under paragraph (a)(5)(v) of this section that a program’s curriculum does not meet the State educational requirements for licensure or certification in a State in which a student who is currently enrolled in such program is located, the institution must provide notice to that effect to the student within 14 calendar days of making such determination.”

Department Guidance

On February 13, 2024, during a NASDTEC webinar, Department representatives indicated that an FAQ would be released based on the many questions posed to the Department on these regulations. On April 9, 2024, another Department representative at the NASASPS conference confirmed that an FAQ is still forthcoming. As of this writing, a Department representative has indicated that FAQ will be released in May. Therefore, our analysis is based on a review of the preamble and communications with the Department representative.

On April 9, 2024, the Department released an electronic announcement (GE-24-03) Updates on New Regulatory Provisions Related to Certification Procedures and Ability-to-Benefit. The morning of the release, the Department representative at the NASASPS conference indicated that this electronic announcement would soon be released and shared that it expressed the discretion of the Department when reviewing a set of new regulations that included the new requirements for programs to satisfy state educational requirements for the PPA. The flexibility offered was simply that an institution should document prior to the July 1, 2024, effective date the particular barrier to compliance that has been encountered that is outside of the institution’s control. Upon a review or audit, the Department could then consider whether this was acceptable reasoning to not comply by July 1, 2024. The Department added that these barriers should be overcome by January 1, 2025.

 It should be noted that the announcement tended to refer to the institution obtaining approvals from state boards and difficulties obtaining approvals. We wonder if the Department understands that not all professions and states have approval processes to affirm that the institution satisfies state educational requirements to ensure with any legal certainty what the institution is required to certify for the PPA. We will note again that no input from licensing boards or communications was sought by the Department in the development of these rules. The Department shared in the preamble their opinion that the interactions with the professional licensing community were not warranted “… the Department has determined that the institutions should be the ones to work with States to determine if their programs have the necessary requirements for licensure or certification since they know their content and curricula. In making this regulatory change, the Department sought comment from all interested public stakeholders, and received and considered over 7,500 comments on these final regulations.”

Since the release of the final regulations, we have presented to many organizations, including the National Council State Boards of Nursing (NCSBN), National Association of State Directors of Teacher Education and Certification (NASDTEC), Council of State Governments National Center for Interstate Compacts, Council on Licensure, Enforcement and Regulation (CLEAR) and Association for Counselor Education & Supervision (ACES), and most were largely unaware of the development of these regulations. Just last week in conversation with one of these organizations, they thanked us for sharing the contact information for the Department. The organization intended to request a conference call with the Department to explain the state board processes and have a frank conversation regarding that state boards are not in a position to respond to requests for approvals or reviews of curricula for out-of-state institutions to address satisfaction of state educational requirements in the various states. Conversations of this type with a variety of professional boards would have been helpful before or during negotiated rulemaking committee meetings.

What Should Institutions Do?

We encourage institutions to continue the research processes that they were doing to develop notifications and consider the following additional steps.

  1. Revise or develop your institution’s location policy (required in federal regulation since July 1, 2020).
  2. Research state educational requirements where students are served by the institution.
  3. Compare & determine if the curriculum satisfies the educational requirements.
  4. Carefully consider the use of attestation (as this option is not for everyone and documentation is necessary).
  5. Continue to follow a process to provide public and direct notifications relative to the states where students are served.
  6. Communicate with senior administrators and general counsel to consider business decisions about institutional priorities to serve certain states and certain professions.

One last thought, we wonder if institutions should consider sharing these requirements with their various academic departments who may, in turn, share with state licensing boards in the home state of the institution. This could create grassroots opportunities for collaboration and more communication of requirements. Additionally, it would be helpful if institutions could connect and communicate more with their programmatic accreditors about these requirements.

Additional Resources

Please make note of the following resources for institutions! The State Authorization Network (SAN) maintains a landing page on the SAN website dedicated to compliance requirements for programs leading to a license.  Additionally, SAN has developed public-facing and member-only resources housed on the SAN website that address the complexities and help institutions develop compliance strategies. The SAN Professional Licensure Special Interest Team has recently updated the FAQ initially based on questions from the November 2023 SAN and WCET Webinar. SAN is developing a second edition for its Professional Licensure Handbook which is on hold until the Department shares its forthcoming FAQ. For research support, institutions may wish to consider a research license with the Higher Education Licensure Pros.

Finally, if you have additional questions about the regulations, we urge you to communicate directly with the Department’s designated contact, Vanessa Gomez: Telephone: (202) 987-0378. Email: Vanessa.Gomez@ed.gov.

When the Department’s FAQ is released, we will update all SAN and WCET members plus we will update the Professional Licensure Handbook which will be publicly available. Stay tuned!

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Categories
Practice

Using AI to Empower Learning

Post author By Lindsey Downs
Post date May 9, 2024

Journalists are currently facing an unprecedented challenge. The relentless 24/7 news cycle, coupled with layoffs, an uncertain business model, and a growing public distrust of media, is putting immense pressure on us. This comes at a time when the world is becoming increasingly complex, and journalists need to contextualize fast-paced news and help a divided audience understand the bigger picture, from the roots of conflicts to the future of humanity.

Setting the Stage

It is no small task, particularly as newsroom budgets are shrinking. Venerable news outlets such as the LA Times, the Washington Post, and CBS News have offered buyouts or eliminated positions in the last year. By one estimate, 528 news layoffs happened in January 2024 alone and could reach 10,000 for the year.

Artificial Intelligence in Practice: Journalism

At the same time, artificial intelligence gives those of us in media both consternation and hope. The damaging impact of deep fakes and fake news is very real. News consumers often don’t know if what they see and read is real. Bad-behaving politicians, business leaders, and other public figures now have a plausible response to unfortunate hot mic incidents or leaked videos: that wasn’t me when it truly was.

Some outlets have turned to AI to write stories (sometimes to cringe-worthy results); see that time when Gannett used AI to write high school sports stories. Yet, news companies have used machine-assisted programs for years to write data-driven stories such as weather and stats-heavy sports and stock market reports. New uses include transcribing documents written in other languages and creating a transcript of audio and video recordings, which saves a ton of time for reporters working on deadlines and on longer investigations.

Practical and creative generative AI programs open up many opportunities for journalists working under the gun to report and create content that can help the public understand this complex world. That is why I am (mostly) a fan.

AI in the Classroom

At the Walter Cronkite School of Journalism at Arizona State University, I have been at the forefront of integrating AI into coursework. I am a member of several provost-level committees working to figure out how our university should approach AI and learning. We agreed early on to be a mentor and not a cop when it comes to using AI in the classroom. Individual faculty members have the final say in whether to allow students to use AI in their work for a specfic class. The newsrooms at Cronkite are formulating a policy on when and how to use GenAI, as we are integrating an AI-powered production tool into the daily workflow.

At my innovation lab and other courses I teach, I allow the students to research and evaluate different GenAI programs. For example, in my Business and Future of Journalism course (which is mandatory for journalism undergraduate students), we discuss the rise of AI, the danger of deep fakes, and the efforts at detection. In my innovation lab we are using GenAI to create a series of interactive vignettes to tell the stories of the founding of the United States in 1776. The “semiquincentennial” will be celebrated in 2026, but communities, historians, and descendant groups have already begun commemorations. My students and I are creating content for Arizona PBS in connection to the Ken Burns six-part film on the American Revolution, set to air in Sept 2025.

GenAI has allowed my students to go from novices to interactive, gamified story creators in just a few short weeks. Students in each semester since the summer of 2023 have researched unsung participants to tell the rich stories of women, free and enslaved African Americans, poor whites, and the landed gentry who contributed to the revolutionary effort. With GenAI and real-time production tools, we can create a farm in North Carolina with a sky and background scenery created by Blockade Labs, interactions facilitated by Mixamo and Spatial.io, and artifacts brought to life using Lumalabs or Meshy. We research the accents of Colonial-era people and then create voices in Eleven Labs or Play.HT to bring to life their stories which are based on journals or historical documents. We use Transkribus to make Old English script and 250-year-old documents easier to read. We’ve created small animated videos in Pika to power a choice-based game to help younger people understand how dangerous it was to buck the crown in the mid-1770s. We use MetaTailor to help fit period clothes on basic models.

Keeping up with AI Innovation

I learn about new tools and innovative platforms by consuming everything I can, from YouTube videos by creators who showcase how they use the tools, to reviewing news articles about the impact of these new technologies. I’ve fallen asleep many nights watching a video on the latest announcement by OpenAI or Microsoft. Then I try my hand at replicating what I watched before teaching my students. Sometimes they bring new tools to me that they’ve discovered and we learn together. It can be overwhelming because the pace of change is fast, and I say that as someone on the founding team of the Washington Post’s first website after years in the Post newsroom. The evolution of GenAI makes those early, crazy experimental Web creation days seem leisurely.

At the end of the day, we are still all about the story, the history, and the reporting. GenAI has empowered me and my students to create the content that we can see in our minds but were limited in what we could do previously, especially without a big budget. We still happily hire artists with special skills in avatar creation and architectural reproduction but love the fact that GenAI allows us to build so much ourselves.

I know that GenAI will mean many jobs will be lost, others will be transformed, and others will be created, especially for those without years of experience. I know that maligned actors will use GenAI to fool a public already on edge. I believe in the efforts of people trying to create the light that will expose those misdeeds. The future of journalism is already here and I believe it is crucial for my students to be involved in shaping it.

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Categories
Policy

In Defense of Reciprocity – A Joint Letter to the Department of Education & Call to Action

Post author By Lindsey Downs
Post date May 2, 2024
Higher education organizations jointly suggest alternatives to recent rulemaking proposals to improve state authorization reciprocity.

On May 1, leading higher education organizations jointly submitted a letter to the Department of Education (the Department) detailing concerns about recently raised proposals regarding state authorization reciprocity agreements. Earlier this year, the Department’s negotiated rulemaking sessions included several recommendations to alter the operations of such state-to-state agreements.

The Department was clear that the proposals would cover any interstate agreement for authorization of institutions offering distance education.

However, it was apparent that many of the ideas presented targeted the current State Authorization Reciprocity Agreements (SARA), which encompasses all states except California.

If adopted, the impact of the proposals on SARA, states, institutions, and students will be significant.

The Partners in the Letter

WCET, along with the State Authorization Network (SAN), joined with UPCEA, OLC, and Quality Matters to highlight our members’ concerns. We are pleased to be joined by the National Association of College and University Business Officers (NACUBO) and the American Association of Community Colleges (AACC) in supporting our positions.

The Issues We Raise

The letter focuses on issues that concern the institutions and states that are our WCET and SAN members or with whom we partner. There is also considerable attention to the impact the proposals will have on our students. The two proposals highlighted in the letter are: 

  • Institutions With More Than 500 Students in Another State –
    • Proposed During Rulemaking:  Institutions enrolling more than 500 students in a state would need to seek direct authorization from that state.
    • Concerns:  While the proposal seeks to limit the risks to consumer protections and financial liabilities for states and students, there are better measures of risk. The proposal also raises more questions than it can answer. In specific cases, it will leave students with less protection than they now enjoy.
  • State Specific Laws Related to Closure –
    • Proposed During Rulemaking:  Regardless of whether it participates in a reciprocity agreement, an institution must comply with closure laws (e.g., record retention and tuition recovery funds or bonding) in the state where students are located.
    • Concerns:  As enforcement of state closure laws will vary from state to state, students will receive uneven protection based on state residency. For states to enforce state closure laws, many states would need to enact changes in legislation and state agency oversight capabilities. Alternatively, to ensure that all students receive closure protections, it would be prudent to collaborate with organizations facilitating a reciprocity agreement to develop policies that include closure protections.

In addition to the issues raised in the letter, WCET and SAN remain unconvinced about the Department’s authority to regulate an agreement among states. The states are asked to assume greater regulatory responsibility and are not direct recipients of the aid disbursed. We also worry about the over-specification of who can serve on accreditation or reciprocity agreement boards.

Finally, we urge the Department to forego any thoughts of returning to proposals to allow a state to “enforce” any law on an institution in a reciprocity agreement. Such an action would gut the benefits of reciprocity.

Call to Action and Watch for a Second Letter

As advocated in a previous WCET Frontiers blog post, we urge distance education institutions to take action.

If you support state authorization reciprocity, make your voice heard.

That blog post includes links to four issue papers that you can use. The letter announced in this post should also help you. We urge you to:

  • Review current processes to determine what changes might need to be made should the proposed language be finalized as regulations.
  • Work with your government relations department to contact your federal and state elected officials.
  • Be prepared to explain the impact on students that the proposed language would have.

Waiting for the official comment period will be too late. Your elected representatives may be able to pressure the Department into changing its position on these proposals. Those in Congress could ask questions of the Department of Education. Governors and legislators may be interested in Federal attempts to change laws that they passed.

What’s next? We are working on a joint letter regarding the proposals for distance education. Watch for that soon. Get involved.

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