I asked some of the WCET leadership and friends to share takeaways and topics that threaded through the entire event (especially those that will impact higher education and digital learning next year).
I appreciate everyone who shared their thoughts for this post! We also included some anonymous comments from the after event survey, thank you for the kind and supportive feedback on this year’s Annual Meeting.
Here are some takeaways I had from the comments I received:
Artificial Intelligence isn’t going anywhere and it will remain an important topic (in higher ed and life in general) for 2024 (and beyond).
Enrollment in higher ed has changed, and we will continue to see shifts in who enrolls in a college or university and how they want to enroll. 2024 seems like a good year to focus on how higher ed can adapt to these changes.
Practitioners need additional guidance, resources, and training surrounding newly released requirements for interstate distance education (and those looking for it were happy to learn from our experts at our sessions!).
This year’s sessions were excellent, New Orleans was a fun backdrop for the event, and, above all, it was a pleasure to interact in-person again with the exceptional members of our community.
I continue to learn from our institutional members about the post-COVID impact on the shifts to digital learning. Rather than “going back to normal,” faculty are teaching more online and hybrid courses and more students are enrolling in them.
This enrollment shift has surprised many and there are many practical implications including: more need for faculty development and instructional design, clearer communication on what the student experience will be in a course is needed, resources (technology, software, support staff) are stretched, online student services need to expand, and policies (institutional distance ed fees and federal regulations) are stretched or violated. I heard about one institution where they are re-configuring their online unit. At another, their campus Wi-Fi is overtaxed, even though there are fewer faculty and students on campus. And what do we do with those empty classrooms? Addressing these many issues will occupy many institutional leaders in 2024.
Van Davis, WCET
As always, I came away from WCET’s Annual Meeting with lots to think about.
Going into the meeting, AI (especially generative AI), was top of mind for me. I left the Annual Meeting impressed with the depth of thinking that digital learning leaders are doing around AI and was particularly struck by the observation that while we as faculty and staff are working with the most sophisticated technology we have ever experienced, our students are working with the least sophisticated technology they will experience in their lifetimes.
Judith Sebesta, Sebesta Education Consulting LLC and part of the Annual Meeting opening panel
Photo of opening session at Annual Meeting 2023
Two highlights for me of the recent WCET Annual Meeting were the pre-conference workshop on Artificial Intelligence as well as the Awards Lunch.
At the workshop, I was so impressed with the inquisitive and knowledgeable minds gathered together in the room to explore effective AI practices and policies.
It gave me hope that we can successfully harness AI to benefit our campuses and students!
And learning about the work of this year’s recipients of the WCET Individual, WOW, and SANsational Awards was so inspiring, pushing me to strive for excellence in the work that I do to support innovation and online learning in higher education.
Cheryl Dowd, WCET
The WCET Annual Meeting and the SAN Coordinator Meeting are valuable opportunities to learn and share important goals and challenges when serving students using digital technologies, especially through interstate distance education.
In addition to many notable discussions about AI, this year, I was very focused on learning from others about their concerns about implementing nuanced requirements released by the U.S. Department of Education.
My biggest takeaway is that institutions desire more clarity and training to understand complicated requirements. The institutions’ staff members expressed that they need a road map to share this information and to implement these requirements collaboratively among various stakeholders at institutions. Additionally, the institution’s staff members expressed that they wish direction to gain the support of senior leaders when a change or modification of the institution’s processes becomes necessary. Because interstate distance education opportunities will continue to grow, the institutions will need to develop mechanisms to anticipate and support the needs of their interstate students and comply with additional state and federal requirements.
Feedback from Attendees
We had a lovely time last week presenting at and being a part of @wcet_info's 35th Annual Meeting! It was wonderful getting to meet so many passionate educational leaders across the country. #WCET2023 Thank you to those who attended our workshops and stopped by our booth! pic.twitter.com/Cc17dVKzvP
It was great that presenters could quickly pivot with the latest US ED regulations coming out and address the potential considerations and impact.
(The best part of the conference) EVERYTHING! It is a great community to be a part of and it was so nice to put people with faces and names. I really appreciated the policy sessions with experts like Cheryl, Russ and Aaron who were able to digest and explain the new regulations very quickly!
Special shout out to the Student Panel facilitated by Every Learner Everywhere. It was great hearing directly from students what works and what doesn’t work for them. Definitely, we need more sessions like this in academic conferences.
For me, one of the highlights of the Annual Meeting was getting all of these great leaders and practitioners from across the US in the same space. It was definitely rewarding to exchange ideas with people with different roles and from different types of institution.
The highlight for me was the insightful sessions on AI. It was honestly nice to know that no one has the “answer” for incorporating AI into the learning experience, but the journey to discovery was fun and helpful.
I expected to make some connections as we do at any conference, but something was special about this one. I’ve never attended a “women in tech” conference before. The connections I’ve made here are priceless. – ASWE attendee.
Thank you again for the feedback on our event. Our team members do review the results from the survey and read every comment. It’s important to us to understand what went well and what we can do better each year.
I thought I’d end today’s post with reflections from Megan and Kim, the WCET team members who spent so much time making this event as extraordinary as it was. Cheers to you both!
Megan Raymond, WCET
The 2023 Annual Meeting stood out to me as one of the best WCET conferences I’ve participated in in 17 years. There are many aspects of the event that stand out to me. Being in New Orleans in the historic arts and warehouse district, the location meant numerous restaurants, shops, and walking paths were nearby. The event size of 350 attendees cultivated a collegial atmosphere; it was easy to find friends and make new ones. Lastly, I loved the addition of the Annual Summit of Women in eLearning to the Annual Meeting. This was a wonderful way to connect with women through sharing, mentoring, collaboration, and dancing at the Pajamarama. Throughout the entire Annual Meeting, there was a sense that people were really happy to connect post-pandemic and missed being in person.
Kim Nawrocki, WCET
I want to extend a heartfelt thanks to our speakers and staff who made this a spectacular Annual Meeting. Attendees seemed especially inspired to share challenges and aspirations to evolve higher ed together, gaining insights to bring back to their campuses. It was wonderful to engage with our community in person—and it’s hard to beat the lively environment, historic neighborhoods, and amazing food one finds in New Orleans.
About last night! We had a wonderful welcome reception with all our #WCET2023 attendees. Our signature cocktail, the MIXed Bliss was 🔥. The name was “shaken up” by #chatgpt. pic.twitter.com/pw0NUeVxaJ
As my plane took off from the airport in New Orleans, LA a few weeks ago, I had a smile on my face. That smile was due to the wonderful experience of this year’s WCET Annual Meeting. This year I attended several meetings and sessions that brought up fresh topics to learn about, networked with our community, met some incredible people, and visited a town I’d never been to before! The group dinners at local restaurants were a huge highlight for me! This was an outstanding year – it was not only the 35th anniversary of the Annual Meeting but it was also the first year that WCET hosted the Annual Summit for Women in eLearning (ASWE).
If you attended the conference, today’s post will recap and remind you of the event. If you couldn’t attend, I hope to highlight some of the big topics and big moments. I also have some details to share about next year’s Annual Meeting, and I hope you’ll join our team there!
By the way, ChatGPT wrote the title for this blog post and bravo.
Who’s Who
The attendees each year at the Annual Meeting have great questions, helpful resource suggestions, and thoughtful support and guidance. I appreciate the opportunity to meet and talk with such a variety of individuals brought together to continue to learn from each other and discuss how we can make higher education and digital learning better. I was very excited to see that we had a few students join us this year as well; some attended for professional development and some as panelists for a session.
The WCET Annual Meeting and ASWE Summit was attended by individuals in a variety of roles:
Attendees hailed from all over the country, here are the top ten states represented at the meeting:
In the Beginning…
The Annual Meeting this year started with pre-conference sessions and meetings. The State Authorization Network (SAN) held a coordinator meeting, and the WCET Steering Committee and Executive Council met to examine the past year and brainstorm on topics WCET should address for next year.
The pre-conference workshops included:
Accessibility Should Be the Default, Not an Option: Embedding It Across the Institution, and
Developing Effective Practices and Policies to Harness Artificial Intelligence.
From what I heard and experienced, the topics of the pre-conference sessions definitely foreshadowed two of the big overarching themes threaded through the entire event.
The WCET Annual Meeting officially opened with the general session: AI in Higher Education – Exploring the Promise and Perils. During this session, moderated by the incomparable and gracious Gloria Niles, Director of Online Learning with the University of Hawai’i System, panelists discussed the perils and promises of AI in higher education. My big takeaway was that we definitely MUST be working on this topic (oh good, we are) and that work must be focused on the inclusiveness, adaptability, and dynamic engagement of any learning environment that is informed or assisted by AI. Our experts recommended reviewing and consistently updating your AI and Academic Integrity policies, as they will likely need updates as this technology continues to progress (I also most used the word evolve here, but it would undoubtedly bring up too many movie references).
Awarding and Showcasing Promising Practice and Dedicated Service
As stated during the Awards Luncheon and Program, I am so lucky to work on the Awards program for WCET. It’s an honor to learn about the innovative work taking place in our field and finding exciting ways to showcase that work.
During our Awards program, we honored two practitioners with individual awards from WCET, three institutions with WOW Awards, and reviewed three institutions who received awards from the State Authorization Network (SAN).
WCET Individual Awards
The Dick Jonsen Mollie McGill Award
WCET’s top honor is given each year to an individual who has made a significant contribution to the digital learning community and to WCET. This person is selected by WCET leadership and staff. This year’s recipient was Shannon Riggs, Associate Vice Provost of Educational Programs and Learning Innovation, Oregon State University. WCET Steering Committee Past Chair, WCET Executive Council. Shannon is an excellent example of exactly what we hope to honor with this award. Her commitment to providing high-quality, inclusive digital learning and the time she has devoted to WCET are truly commendable and so appreciated. Thank you, Shannon, for all you have done for the entire WCET community!
Sally M. Johnstone Award
If you know Sally Johnstone, then you know our goal with an award named after her is to showcase outstanding leadership capabilities and excellence in practice.
This year’s recipient, Dr. Felicity Cruz Grandjean, Associate Dean of E-learning Quality, Office of E-learning, Dallas College, more than fulfilled the award criteria. Nominated by Shani Suber, also from Dallas College, Felicity has shown dedication to inclusiveness, accessibility, quality standards, and more, and has brought that dedication to many programs and initiatives such as accessibility and quality checklists and frameworks for staff and instructors and participation and leadership campus wide online learning user groups. Shani mentioned that her leadership in the online teaching and learning industry has been inspirational. Congratulations Dr. Grandjean, we look forward to supporting you as you continue to lead the way.
2023 WCET Outstanding Work (WOW) Award
The WCET Outstanding Work (WOW) Awards recognize outstanding efforts by member organizations and individuals in applying innovative solutions to a challenging educational need.
First of all, thank you to everyone who submitted a nomination for a WOW award this year. Our awards committee spent a lot of time reviewing your submissions and discussing the impactful and wonderful projects, programs, and initiatives we learned about. The work that is happening in our community is truly remarkable.
We were able to narrow down to this year’s WOW Awardees:
Oklahoma State Regents for Higher Education – Online Consortium of Oklahoma,
Rio Salado College – RioPACT,
Sinclair Community College – Course Equity Rubric.
Thank you to each of these individuals and institutions for their amazing work making higher education digital learning more successful. Congratulations! Check out the blog posts from our WOW winners and stay tuned for Frontiers podcast episodes featuring this year’s recipients. Read more about the 2023 WOW Award winners.
SAN – SANsational Awards
The SANsational Awards recognize outstanding efforts by SAN member institutions and organizations in developing a high-quality, comprehensive solution to a challenging state authorization issue.
Congratulations to the 2023 SANsational Award Winners:
Awarded: Licensure Programs – Notifications and disclosures for professional licensure program status in each state.
Post University (CT)
Personalized Licensure Advising and Disclosure
The Chicago School (CA)
The Licensure Story; When Obstacles & Challenges Lead to Wins
Awarded: Location – Identifying student location for regulatory compliance and reporting requirements.
Sinclair Community College (OH)
Professional Licensure Disclosures (location of students)
The Chicago School (CA)
Embracing Purposeful Engagement for a California Institution
Awarded: Compliance Innovations – Institution policy, tools, compliance teams or other inventive or novel compliance management process.
University of Louisville (KY)
Elevating the Importance of Academic Compliance: A Paired Approach to Change
While we didn’t specifically honor the SANsational winners during the awards program, we did highlight those institutions. SAN team members went on tour to present the SANsational awards to the recipients in-person, on their campus! Read more about each of this year’s SANsational award winners.
Empowering Insights
The WCET Closing Keynote also served as the Opening Keynote for the ASWE Summit! ASWE became part of WCET last year, and this year the Summit event was held in tandem with the Annual Meeting. During this session, Nia Haydel, Vice President for Alliance Engagement & Institutional Transformation with Complete College America, provided us with a powerful discussion of keeping our purpose at the forefront of our work. Nia invited us to consider how we can truly support students in meaningful ways in digital learning environments. We need to ask about the policy barriers, attitudes, and practices that maintain inequitable experiences and outcomes. What a great way to conclude WCET and to kick-off ASWE!
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Thank you to all of you who attended WCET 2023! Our entire team enjoyed seeing everyone and learning with you.
2024 – WCET Annual Meeting Heads to California
Save the date for the 2024 WCET Annual Meeting! We’ll be in Long Beach, CA October 8 – 10, 2024! The Call for Proposals will open in March 2024.
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I hope you enjoyed this virtual walk down memory lane as much as I have. Did you learn something new that surprised or inspired you? Do you have feedback on our custom cocktail name that came from ChatGPT (“the MIXed Bliss”)? Share your favorite moments and takeaways with us on X @wcet_info with #WCET2023!
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But wait, there’s more! I love reminiscing about great travel and learning experiences, and that’s why we’ll be back with part two of this post with some final thoughts from WCET staff and leadership on the Annual Meeting and the ASWE Summit, topics that reigned supreme in our discussions and questions, and what they took back to their institution or organization.
WCET would like to take this opportunity to acknowledge and show appreciation for our veterans and military affiliated families. Thank you to those who currently serve and have served in the U.S. Armed Services. WCET Frontiers would like to honor our veterans by sharing about the history of Veterans Day and also share some updates on federal policy issues for institutions to watch that affect the process and delivery of Veterans benefits.
Historical View of Veterans Day
The traditions of Veterans Day in the United States originated with Armistice Day marking the end of World War I hostilities with Germany and their allies on the 11th day of the 11th month, November 11, 1918. Events in the United States, England, and France were held for the initial observance of Armistice Day. “Armistice” is generally defined as an agreement to maintain a truce. It was hoped that World War I was “the war to end all wars.” However, after the onset of World War II, England and other Commonwealth nations adopted Remembrance Day and the United States adopted Veterans Day.
In the United States, the first celebration of Veterans Day occurred in 1947 in Birmingham, Alabama. An event was organized by a World War II veteran, Raymond Weeks. A bill was proposed in Congress in 1953, signed by President Dwight D. Eisenhower proclaiming November 11 as Veterans Day. In November 1982, Raymond Weeks was honored by President Ronald Reagan with the Presidential Citizens Medal.
Among the traditions of Veterans Day and Remembrance Day are parades, moments of silence, laying of wreaths, and wearing a remembrance poppy, often sold by Veterans groups. The tradition of the poppy comes from the red flower that grew over the graves of fallen soldiers in Belgium during World War I. A Canadian soldier, Lieutenant Colonel John McCrae, was inspired to write a poem in 1915 after presiding over the funeral of a friend and fellow soldier. The poem, “In Flanders Fields,” refers to a location called Flanders Fields which is a common English reference to battlefields in Belgium and France. The poem gained popularity after World War I in the United States, Canada, and England. The poem was even set to music by several composers including an American, John Philip Sousa. A traditional reading of “In Flanders Fields” occurs at many Veterans Day and Remembrance Day ceremonies including at assemblies and observances for school children.
Veterans, we are grateful for your service and sacrifice!
Federal Policy Issues to Watch Affecting the Process and Delivery of Veterans Benefits
Seeking Parity for Monthly Housing Allowance for Students Participating in Programs Fully Online
Since 2017, WCET has sought to bring attention to the need to revise federal law for the monthly housing allowance for students eligible for Veterans Benefits who participate in programs fully online. Veterans using their G.I Bill education benefits receive a Monthly Housing Allowance (MHA) for the terms that they are enrolled. Veterans who take all of their courses online receive a reduced MHA that might be as low as 50% of what they would receive if they attended any or all classes on-campus.
In December 2010, Congress passed ThePost-9/11 Veterans Education Assistance Improvements Act of 2010. The Federal law addressed MHA by allowing a new but reduced MHA for online learners. Chapter 33 of the new Post 9/11 GI Bill indicates that if a student is enrolled full-time for the full length of the semester, and at least one on campus course (any course that does not have the Online section identifier) is to receive the full monthly housing allowance. A student who is full time, but taking classes fully online, is entitled to only half the national average MHA payment.
Congress responded quickly in Spring of 2020 to address emergency legislation when students were shifted to remote education due to the pandemic. This allowed students to receive full housing benefits despite participating in courses solely through distance education. This emergency flexibility was extended in via federal legislation to continue the benefit through June 1, 2022.
Today, MHA has returned to the previous structure – which means if the student is taking courses fully online then they are only entitled to half the national average MHA payment. The GI Bill Comparison Tool guides the veteran as to how much they are eligible for their location.
While we had hoped that Congress would take up this issue after the emergency flexibilities expired, that has not occurred. We have learned there are several barriers that must be addressed, including:
budget concerns,
quality of distance education, and,
determination of the appropriate address for the student for purposes of MHA calculation.
We are pleased to learn that this fall U.S. Representative Juan Ciscomani (AZ) introduced a bipartisan bill in the House: Expanded Access for Online Veteran Students Act. This bill would increase MHA for veterans taking online courses during the summer term to receive full MHA. Ciscomani Leads Bipartisan Push to Increase Benefits for Online Student Veterans. Representatives from the Student Veterans of America recently testified in support of this bill at the House Committee on Veterans Affairs. While this bill does not provide full parity for MHA regardless of the modality of instruction for all terms in an academic year, it does start the discussion and is an encouraging development.
Determining Similarities and Contrasting Requirements Between VA Regulations and New ED Regulations When Serving Students in Programs Leading to License or Certification.
The U.S. Department of Education (ED) recently released new and amended federal regulations that will be effective July 1, 2024 and that address institution responsibilities when serving students in programs leading to a license, tied to Title IV eligibility. Similarly, the U.S. Department of Veterans Affairs (VA) released new federal regulations in January 2023 that became effective just one month later in February 2023. The VA regulations address institution responsibilities when serving students in programs leading to a license but the responsibilities are tied to eligibility for Veterans Benefits.
New ED regulations require that the institution satisfy educational requirements where the institution is located and where the students enrolled by the institution in distance education or correspondence courses are located as determined at the initial time of enrollment. (34 CFR 668.14(b)(32)(ii)). Additionally, institutions must provide public and direct notifications regarding the curriculum meeting state educational requirements including where the student is located. (34 CFR 668.43(a)(5)(v) and (c)) More information on the new ED rules is available here: New Federal Regulations, Part 1: Addressing Programs Leading to a License or Certification.
Relatively new VA regulations that became effective in February 2023, require that state approving agencies (SAA) may approve a course designed to prepare an individual for licensure or certification in a state, if the course meets all instructional curriculum license or certification requirements of such state (38 CFR 21.4253(d)(9)(i)). Additionally, the VA regulations require public disclosures in a prominent manner of any conditions or additional requirements to obtain the license (38 CFR 21.4259(e)).
The VA and ED regulations appear to have the same goals of student consumer protection. However, the language used by the VA and ED is slightly different. Additionally, we are aware that the SAA has the authority to approve the programs in the state where the institution is domiciled. Therefore, we have asked questions about the VA regulations as to whether the VA regulations address institutions that serve students located in a different state than where the institution is domiciled. It would seem that for purposes of student consumer protection, there should be a process that an SAA would need to review the institution’s ability to meet all instructional curriculum requirements and provide public disclosures regarding the state where the student is located. The out-of-state student may be confused by the institutions only addressing the state where the institution is domiciled, and the public disclosures of additional conditions and requirements may not be applicable to that out-of-state student. The state in question is not clear if the student is located in a different state than the institution.
Upon release of the regulations in January 2023, the State Authorization Network (SAN) raised the question to Joeseph Garcia, Executive Director, Education Service, for the Veteran Benefits Administration, and to Dr. Joseph Wescott, National Legislative Liaison, National Association State Approving Agency (NASAA). SAN has recently sought guidance from NASAA President, Frank Myers. We understand from these communications that guidance is under consideration.
If you are tasked at your institution with managing compliance for programs leading to a license or certification, we urge you to communicate with your state’s SAA (NASAA State Contacts). You may wish to seek direction to implement the VA regulations to develop an efficient route to address both VA and ED regulations to serve students in programs leading to a license to receive Federal aid through Title IV programs and Veterans Benefits.
In Conclusion….
Again, a sincere thank you to our Veterans and their families. Additionally, please look for WCET and the State Authorization Network to continue following these issues and share information as it becomes available.
Today, WCET’s parent company, WICHE – the Western Interstate Commission for Higher Education, is holding its Commission Meeting in California. During this meeting, Commission members, higher education leaders from each of the WICHE states, and WICHE staff will meet to orient new Commissioners, discuss the work of WICHE and WICHE member states, hold committee meetings and roundtables regarding critical higher education topics.
California is a member state of WICHE and in connection with the meeting there, we wanted to help highlight an outstanding new campaign launching by the California Student Aid Commission to increase completion rates of FAFSA or CA Dream Act Applications. Thank you to our colleagues with WICHE, the state of California, and their partners at Mainstay for sharing the details of this launch with us!
Enjoy the read,
Lindsey Downs, WCET
All-In! Campaign Launch
Completion of the Free Application for Federal Student Aid (FAFSA) is one of the best predictors of whether a high school senior will enroll in college.
Students who complete a FAFSA or a CA Dream Act Application are 84% more likely to enroll in the immediate next college term and 127% more likely to enroll if they come from the lowest socio-economic quintile (National College Attainment Network). Students completing the California Dream Act Application behave similarly.
Yet, many students lack all the information they need regarding financial aid and do not have the assistance needed to complete these forms. Students can often feel overwhelmed by the complicated process or get bogged down by unfamiliar jargon and administrative hurdles. This confusion may cause students to avoid completing the application process and adds strain to counselors already struggling with staff shortages and packed caseloads.
That’s why the California Student Aid Commission (the Commission) has launched the All-In! Campaign to increase the number of high school seniors who complete their FAFSA or the CA Dream Act Application.
Technology Platform
To advance this work, the Commission has partnered with Mainstay, a company that has built a two-way student success platform geared toward improving financial aid application completions. The California platform, which we have named “Cali,” is a new, innovative AI text-messaging chatbot. The Commission is working with Mainstay to pilot the use of this AI chatbot to increase FAFSA/CA Dream Act Application completions among high school students, with the long-term goal of increasing access to college education. Cali will provide personalized guidance over text messages to students, especially those in underserved communities, across numerous school districts in the state. Cali is trained to respond to student questions about FAFSA and CADAA.
By sending coordinated messages proven to motivate action, the goal is to ensure more students — especially those from disadvantaged backgrounds — gain access to financial aid and higher education. This is a major new step taken by the Commission to help more students secure financial aid resources and improve equitable access to postsecondary education statewide.
Funded by a philanthropic investment through the Capital One Foundation, the three-year initiative will provide Mainstay’s personalized messaging free of charge to participating high schools. Schools will instruct parents on how to opt-in their students to receive relevant financial aid reminders, and provide support for applying other grants and scholarships, all money that does not have to be repaid.
Mainstay’s technology is built with a focus on supporting historically resilient populations. Through partnerships with leading researchers at the Yale Center for Emotional Intelligence, Partnership for Ed Advancement, Irrational Labs, and the National Institute for Student Success, we hope to help students take the next step at every stage of their college journey. In one study with Irrational Labs, they found that when messages about FAFSA are framed as part of the next step after graduation, students were three-times more likely to apply for aid than those who received texts without this specific messaging content.
This research-backed approach informs Mainstay’s AI chatbots, (like Cali!) and shows how the chatbots can provide personalized guidance and encouragement through each step of the financial aid process. The platform will use real-time data to offer personalized interventions to keep students on track. For example, seniors may receive reminders to apply for scholarships or timely nudges about approaching FAFSA deadlines.
Using the AI chatbot in California, the Commission will establish an important use case to showcase how other states can use such technology to improve access to financial aid and impact college success on a large scale. With many students nationwide failing to complete the FAFSA each year, targeted outreach represents a promising way to ensure more students make it to college.
The Model: Learning from Washington State
The California initiative takes inspiration from Mainstay’s collaboration with the Washington Student Achievement Council (WSAC) on a similar outreach program that helped students complete their financial aid forms. The results in Washington demonstrate the positive impact the use of this technology can have when working with key populations.
WSAC saw impressive outcomes: students enrolled in the state’s College Bound Scholarship program in 2022-23 who received Mainstay’s messages showed FAFSA completion rates of 59%, compared to only 46% for College Bound students who did not opt-in to the chatbot. Combined with WSAC’s ongoing efforts, in 2022, these messages helped Washington State to achieve the third-highest increase in rate of FAFSA completion among 51 US states and territories.
WSAC’s strategic messaging campaign reached students at each touchpoint of the process with helpful nudges. Mainstay’s conversational AI chatbot provided an easy way for students to get personalized answers to questions. The promising results in Washington State point to what’s possible in California. As the Commission launches its pilot messaging program, it aims to build off that success.
An Investment in Student Success — Today, Tomorrow, and Beyond
A recent census report estimates over 2 million jobs will go unfilled by 2030 due to a lack of skilled labor. Guiding students through the financial aid process can help bridge that gap by expanding access to the education and training beyond high school needed for today’s in-demand skills.
Yet, in 2021 alone, over 500 million dollars in federal financial aid that could have been used to help California residents pay for college was never claimed. The Commission’s goal is to change that by making it easier for more California students to successfully access financial aid to pursue four- and two-year degrees, trade and career technical education, and industry certifications that support a strong workforce and thriving economy.
Together with Mainstay, we can provide the outreach and support students need to complete this important first step. The Commission is proud to team up and invest in the future of California’s success.
This is the second of our two-part blog post series on the recently released U.S. Department of Education regulations. The first covered new rules regarding programs leading to professional licensure. This one is about institutions complying with closure requirements in each state in which it serves students. We, especially, analyze the impact on the more than 2,000 institutions that serve students through the State Authorization Reciprocity Agreement (SARA).
It is the Certification Procedures issue that we followed closely and reported on often during the three months of rulemaking committee meetings and summarized the outcome of the committee soon thereafter. Of utmost concern was that sub-issues of Professional Licensure and Closure/State Authorization that were not announced, but were inserted by negotiators within the Certification Procedures issue without the opportunity to nominate knowledgeable committee members to share invaluable and pertinent information for the committee’s discussions.
Note to the reader: This introduction is mostly repeated from the first post.
The Certification Procedures issue focuses on the agreement between postsecondary institutions and the Department that each institution certifies compliance with specific obligations in order to participate in Title IV HEA Programs. The agreement is called a Program Participation Agreement (PPA). The Department’s goal was to strengthen student protections within the PPA. The sub-issues for which we followed were among the new requirements being added to the PPA even though there are Federal regulations that direct institution requirements in these two areas.
You may recall that, when the proposed regulations were released in May 2023, we provided two separate WCET Frontiers posts to share our analysis. Our first post addressed the regulation subsection that appears to require that institutions comply with state consumer protection laws for closure, recruitment, and misrepresentation where the institution is located and where the student is located at time of initial enrollment. The second post addressed the institution’s responsibility to satisfy applicable educational prerequisites where the institution is located and where the student is located at the time of initial enrollment as well as an edit to the currently effective public notification requirements.
The final regulations released have been modified to some degree from the proposed regulations. We believe that the public comments that we all shared with the Department were heard and persuaded the Department to make some changes to the final language. However, we believe there appears to still be some misunderstanding by the Department about the variation of oversight for licensed professions by state and by the specific profession. Additionally, there are lingering questions about the applicability of state consumer protection laws upon institutions that participate in reciprocity.
Please consider sharing your questions with the Department on these areas, especially regarding the challenges of coordination of processes and information with state licensing boards. The Federal Register announcement includes the contact information for the Department staff member addressing this issue. For certification procedures: Vanessa Gomez. Telephone: (202) 987-0378. Email: Vanessa.Gomez@ed.gov.
In both posts we will ask the following questions:
What does the final regulation say?
What questions and comments did WCET and SAN share with the Department during rulemaking, public comment period, and the Office of Management & Budget final review (EO 12866 Meeting)?
How did the Department respond to WCET and SAN’s questions in the preamble of the final regulations?
What are the implications to the institution for implementation of the regulations?
*Please note that page numbers in the analysis will refer to the unofficial version of the rules released on October 24 as that document is larger print and easier to direct you to the language of the preamble and regulations.
Final Regulations Addressing State Consumer Protection Laws (Affects State Authorization and Reciprocity)
(32) In each State in which: the institution is located; 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…
(iii) Complies with all State laws related to closure, including record retention, teach-out plans or agreements, and tuition recovery funds or surety bonds…
What questions and comments did WCET and SAN share with the Department during rulemaking and the public comment period?
During rulemaking.
In the announcement for this rulemaking and the call for negotiators, there was no mention of consideration of rules related to state authorization. Just prior to the second session, we were surprised that a few negotiators proposed requirements for institutions regarding the assurance that they abide by all state “consumer protection” laws. While these proposed rules were not explicitly aimed at the State Authorization Reciprocity Agreement (SARA), it was clear by the proposers, the context, and the brief discussion that the intent was to implement regulations that would have a dramatic effect on SARA. During the second of three sessions in February 2022, the negotiator for the Department pushed back on the introduction of new issues to be considered. Typically, it is against rulemaking protocol to introduce new issues after the agenda is set in the first session. Although it was unclear if it would go forward, we wrote the blog post linked above and reached out to negotiators (including holding calls with some of them) about the possible impact of the proposed language. For the third session, the Department provided its own version of the proposed rule. Nobody liked it and it failed to reach consensus. After the meeting, we wrote about our reactions to the proposal.
Public Comment.
When it released its proposed rules for comment in May 2023, the Department tried to limit the impact of the “state consumer protection laws” to only those laws related to closure, recruitment, and misrepresentations. As a result, institutions participating in reciprocity would also need to comply with those rules in each state. Unfortunately, those terms were not defined.
Withdraw the Proposal and Rely on the Department’s Upcoming Negotiated Rulemaking. Since the issue was discussed only briefly, we believe that this “complex topic “deserves full consideration with a more complete slate of negotiators knowledgeable of the issues and impact of proposed actions.
Support a Process to Protect ALL Students. The proposal would result in changes in only a few states. Why not work with SARA to protect all students?
As a Last Resort: Narrow and Sharply Define the Language. “If the Department moves forward, we recommend changing the wording to focus on a limited set of narrowly targeted and well-defined consumer protections.”
We provide a detailed review of the Department’s analysis in our public comment, and included a major concern that the Department was usurping the will of 49 states, the District of Columbia, Puerto Rico, and the Virgin Islands in joining the State Authorization Reciprocity Agreement (SARA). Additionally, we were quite concerned at the late introduction of the topic, the lack of experienced negotiators, and the lack of analysis on the problem to be solved and the impact of the proposed regulations.
Four clarifying questions were posed to the Department related to the proposed language of 34 CFR 668.14(b)(32)(iii):
If the PPA indicates that for purposes of program eligibility the institution’s responsibility is specified “at the time of initial enrollment,” what are the responsibilities if the student changes location?
How does the Department intend to reconcile the inconsistencies in proposed language with the current regulations defining a state authorization reciprocity agreement?
How does the Department intend to be aware of, train, and enforce compliance with meeting varied state consumer protection laws related to closure, recruitment, and misrepresentation?
What is considered evidence of compliance that the institution has Determined that it Complies with these state consumer protection laws?
Office of Management & Budget (OMB) final review (EO 12866 Meeting).
WCET & SAN provided testimony to the OMB/OIRA meeting, which is the final review prior to the Department’s release of final regulations. We shared our concerns related to federalism as we believe that the Department is creating barriers that overstep the state’s rights to create regulations and decisions to how students are served in their states.
Although we had heard that the review panel rarely asks questions, we were pleasantly surprised that the panel asked many questions and remarked upon the specificity of the issues of concern that we raised.
How did the Department respond to WCET and SAN’s questions in the preamble of the final regulations?
First, a general comment: In its overall response, the Department consistently confused SARA (the State Authorization Reciprocity Agreement) with NC-SARA (the National Council that runs SARA in partnership with the four regional higher education compacts). This is a very important distinction and goes well beyond a nuance. SARA is an interstate agreement with policies regarding how states and institutions will act within that agreement. NC-SARA is an office with great people facilitating collaboration among the compacts to implement reciprocity among member states. SARA critics will often cite NC-SARA as a method to discredit reciprocity as an entity imposing oversight as an effort done “to” states and not an effort conducted “by” states.
Regarding the lack of state authorization expertise on the panel and that this issue should have been postponed to the announced future rulemaking (pages 26-27). The Department made this important statement (underlining added):
“The provisions in question are not a negotiation around the regulatory sections that include State authorization or distance education. We did not regulate the conditions, structure, or other elements of State reciprocity agreements or the organizations that operate them, nor did we set requirements that States must follow to oversee institutions enrolling students in a State where they have no physical presence.”
Regarding their new closure requirements, they made this important statement: “The extent to which States have these laws, what they require, and to whom they apply them to is up to the States.”
On future rulemaking, they promised:
“The Department will consider broader issues related to distance education and State authorization in future rulemaking efforts, during which we will consider the need for representation such as what the commenters requested.”
Relatedly, to a response from another commenter who sought to put more requirements on reciprocity agreements (p. 403): “Many of the issues raised by the commenter get at broader questions of State authorization and reciprocity, which we think are better addressed in a future regulatory package.”
Regarding the lack of authorization experience of negotiators, the flawed process of introducing the proposal during rulemaking, and the extremely limited time set aside for discussing it (pages 371-374). The Department disagreed, saying that the negotiators had the proper qualifications and disagreed that the issue was not discussed.
Regarding the previously proposed language to require institutions to comply with all state misrepresentation laws (pages 403-404). We were among the commenters who said that “State attorneys general are already authorized to act upon misrepresentation claims that institutions have against them.” The Department was persuaded and removed misrepresentation from the final language.
Regarding the ambiguity of the previously proposed language regarding “closure, recruitment, and misrepresentation (pages 404-406). In our comment, we asked who would define these terms (the Department, states, other?) and that there will be different interpretations. We suggested that the “requirements should be as common as possible across all states to assure consistent protections regardless of the location of the student. For example, “state consumer protection” laws for “closure” could include tuition recovery funds, surety bonds, catastrophic event plans, teach-out processes, records retention, and more.”
The Department agreed, saying: “We have revised § 668.14(b)(32)(iii) to read “Complies with all State laws related to closure, including record retention, teach-out plans or agreements, and tuition recovery funds or surety bonds.” While others had similar comments, we noted the final product closely tracked with our proposal.
Regarding whether institutions participating in reciprocity have to follow the closure requirements of each state. From another commenter, they recommended that the Department “clarify that institutions that are authorized to operate in multiple States pursuant to a reciprocity agreement must follow all generally applicable State laws and those education-specific State laws that relate to closure, recruitment, and misrepresentations.” Remember they were commenting when the Department had all three of those provisions and had not, yet, limited it to just closure. The Department responded (underlining added): “Institutions can and should be subject to laws beyond the specific types that institutions are certifying to us. That includes generally applicable State laws and what other laws specific to postsecondary education that apply for institutions that do or do not participate in a reciprocity agreement.” We are not sure that clarified the issue.
Regarding the rules negating the benefits of interstate reciprocity (pages 409-412). “Many commenters asserted that the requirement to observe individual States’ consumer protection laws pertaining to closure, recruitment, and misrepresentations, including both generally applicable State laws and those specific to educational institutions, will eliminate most or all of the advantage that derives from subscribing to NC-SARA (sic).”
In response, the Department disagreed (underlining added): “Institutions will still have the many benefits that such agreements offer, including reduced burden and fees. States are a key part of the regulatory triad of postsecondary education. We believe that if States wish to create laws to protect their students from closure, they should be able to do so. This language preserves State flexibility on how they wish to write their laws.”
Regarding the increased burden on state regulatory agencies (412-413). In reply, the Department said: “The Department believes limiting this provision to only closure and spelling out specific areas underneath it addresses the concerns of commenters. Moreover, the extent to which these closure provisions apply to out-of-State schools will depend on underlying State law.”
Regarding the fact that states joined SARA voluntarily and that SARA’s policies were not “imposed” on them as asserted in a letter from Attorneys General and comments from other critics of reciprocity (pages 416-417). Our comment was cited as saying “that State attorneys general are only one entity” within state government. The commenter further noted that “all States except California have chosen to enter NC-SARA, which in most cases involved a bill passed by State legislature and signed by the governor voluntarily.” The Department gave this somewhat off-the-mark response, that it “is not telling States how to structure their laws related to closure. We are requiring institutions to certify to us that they are complying with all laws related to closure in the States where they operate. This is critical because we are concerned about the disruptions and costs associated with closure.”
Regarding our suggestion that the Department work more closely with states, regional compacts, and consumer groups on reciprocity (pages 418-419). The Department says: “We will continue to identify opportunities to improve joint oversight of institutions of higher education.”
Regarding our request that the Department harmonize their proposed language with the definition of a “state authorization reciprocity agreement (page 419). The Department disagreed saying: “This regulation concerns what institutions will certify to the Department.”
Regarding if this regulation applies to institutions participating in reciprocity (page 420). One commenter wanted “to know if the Department means to say that if a State’s consumer protection laws explicitly state that they apply only to institutions operating with a physical presence in the State, an institution operating under a reciprocity agreement without a physical presence should not be required to comply with a law from which it is exempt.”
The Department’s response (underlining added): “Institutions would have to affirm they are complying with those applicable and relevant State laws. For instance, if a State’s tuition recovery fund law exempts out-of-State institutions, those institution (sic) would not have to abide by it.”
Regarding another question about whether this applies to institutions participating in reciprocity (pages 422-424). The Department’s response (underlining added): “…this language specifically requires that institutions certify that they comply with relevant State laws related to the closure of institutions of higher education…Institutions would have to provide this certification regardless of whether they participate in a reciprocity agreement.”
What are the implications to the institution for implementation of the regulations?
In short, this is unclear.
That is even after the Department tried to answer the question multiple times in their response. See items 5, 11, and 12 above.
Before getting to the details, we thank the Department for the important instances when they considered our recommendations and commented on them. Limiting their new regulation only to the four sets of state laws related to institutional closure (record retention, teach-out plans or agreements, tuition recovery funds, and surety bonds) makes sense. SARA leadership should consider adding these elements into their student protections.
On the other hand, the Department sometimes dismissed real concerns out-of-hand. Their unwillingness to learn about the operations of state regulatory agencies is a bit worrisome.
The big question remains, will institutions need to meet each state’s closure requirements even if they participate in reciprocity? To be clear, ALL institutions are subject to this new rule whether they participate in reciprocity or not. This all hinges on whether the Department finds that the reciprocity agreement’s provisions, as agreed to by each member state, meet the new requirement.
On the “Yes, institutions WILL need to meet each state’s closure requirements separately even if they participate in reciprocity” side…
The original proposed language submitted prior to rulemaking session #2 in 2022 was much broader and specifically targeted reciprocity agreements. As proposed, the only remaining benefits for reciprocity would be “to submit an application to state authorizing agencies or pay a fee to a state authorizing agency.”
In items 12 in the previous section, note that the Department said (underlining added): “Institutions would have to provide this certification regardless of whether they participate in a reciprocity agreement.”
Since the release of the final regulation, one of the negotiators who made that proposal during rulemaking wrote a blog post saying that: “The amendments to the Certification Procedures rule require institutions that operate in multiple states pursuant to a reciprocity agreement to determine that each program complies with state consumer protection laws related to closure in each state where the program is offered.”
On the “No, institutions WILL NOT need to meet each state’s closure requirements if they participate in reciprocity, as participating in reciprocity includes an explicit list of requirements used by that state on out-of-state institutions” side…
In item #1 above, the Department said: “We did not regulate the conditions, structure, or other elements of State reciprocity agreements or the organizations that operate them, nor did we set requirements that States must follow to oversee institutions enrolling students in a State where they have no physical presence.”In fact, all mention of reciprocity is removed from the final language.In responding to a query about whether this requirement applies to institutions participating in reciprocity, the Department said (underlining added): “…if a State’s tuition recovery fund law exempts out-of-State institutions, those institution (sic) would not have to abide by it.” Most states participating in SARA have specific carve-outs in their legislation or enabling language that provides this exemption for out-of-state institutions authorized by a member SARA state.
In addition to limited authority over SARA participating institutions, many states limit their authority over out-of-state institutions without physical presence, noting that in some states authority is sector specific.
Ok. So that’s confusing.
The bottom line is that, among the two camps, we lean toward the “No” argument. The Department tripped over itself in being clear that it was not regulating reciprocity, it was relying on state laws, and that the terms of reciprocity are to be negotiated in the rulemaking that is tentatively planned for early next year.
Do we agree with the SARA critics that improvements are needed in protections for interstate distance education students? We do, but we think it can be best accomplished through SARA to improve protections nationally in the 52 states and territories not just in states that have applicable rules. Additionally, we do not agree with all the suggestions of SARA critics. The SARA community needs to do more in the coming year and addressing closure requirements is a good start.
Please remember that this is our early analysis of the new final regulations addressing the new closure requirements and the impact on state reciprocity agreements. For institutions, addressing closure requirements appears to have a lesser impact on their additional work than was found for the professional licensure requirements.
All institutions will be subject to this new requirement, regardless of if they participate in reciprocity or not. As previously suggested in the post for programs leading professional licensure, institutions should review and revise their institution process to determine the location of the student at the time of initial enrollment as has been required since July 1, 2020.
The question remains as to “will institutions need to meet each state’s closure requirements even if they participate in reciprocity?” Either way, we expect pushback:
If the answer is “Yes” – there are likely to be lawsuits and pushback from states. The National Council of State Legislatures opines on issues only if three-quarters of the states agree. They opposed this regulation, which means both red and blue states agreed.
If the answer is “No” – the SARA critics and supporters of the Department of Education will be upset. They will push for much stricter regulation of reciprocity in upcoming rulemaking. There may be individual states that might try to take their own actions. We will be watching and sharing on the SAN website when/if individual states determine their authority to impose specific state closure laws on institutions participating in reciprocity through SARA.
In any case, there are only a few states that have closure requirements for out-of-state institutions. Watch for more updates from us on this issue. Meanwhile, a “quick chart” on state-by-state rules can be found on the State Authorization Network (SAN) website. Watch for applicable closure laws to be added to the chart soon.
Remember that ALL institutions are subject to this new rule. For institutions:
If your institution is not participating in reciprocity, you should make sure that you are meeting the closure requirements in each state in which you are enrolling students who will obtain Title IV financial aid.
If your institution is participating in reciprocity, you should:
Check the State Authorization Network “quick chart” on its website and watch for updated state-by-state analyses of requirements in the few states that have them. Check your enrollment in those states.
Until we receive clarification from the Department, judge your sense of the answer to the question regarding if reciprocity meets the requirement and the risk you wish to take. We believe SARA’s provisions meet the Department’s intent, but we are not the official word. We cannot give you legal advice.
Next Steps
These conclusions come from our early analysis. We still have questions and we’re sure you do too. SAN and WCET will be seeking your input to learn your lingering questions. We maintain that by working together we will develop implementation strategies. SAN is already in process the of reaching out to national associations for licensing boards to inform them of the final regulations. We will also collaborate with NASASPS and the SARA Community to ensure that applicable information is shared. Additionally, we urge you to follow the Federal Register announcement direction to seek more information from the Department staff member addressing this issue. For certification procedures: Vanessa Gomez. Telephone: (202) 987-0378. Email: Vanessa.Gomez@ed.gov .
Look to SAN and WCET for more on these issues in the coming weeks!
This is the first of our two-part blog post series on the recently released U.S. Department of Education (the Department) regulations.
This post covers new regulations regarding programs leading to professional licensure. The second post is about institutions complying with closure requirements in each state in which it serves students.
We have made the Federal Regulations Groundhog Day joke before, but here we go again! The U.S. Department of Education formally announced the new federal regulations that impact institutions serving students in programs leading to a license or certification and state authorization.
It is the Certification Procedures issue that we followed closely, reported on often during the three months of rulemaking committee meetings, and summarized the outcome of the committee soon thereafter. Of utmost concern was the sub-issues of Professional Licensure and Closure/State Authorization that were not announced, but were inserted by the Department and negotiators within the Certification Procedures issue without the opportunity to nominate knowledgeable committee members to share invaluable and pertinent information for the committee’s discussions.
The Certification Procedures issue focuses on the agreement between postsecondary institutions and the Department that each institution certifies compliance with specific obligations in order to participate in Title IV HEA Programs. The agreement is called a Program Participation Agreement (PPA). The Department’s goal was to strengthen student protections within the PPA. The sub-issues for which we followed were among the new requirements being added to the PPA, even though there are federal regulations that direct institution requirements in these two areas.
You may recall that, when the proposed regulations were released in May 2023, we provided two separate WCET Frontiers posts to share our analysis. Our first post addressed the regulation subsection that appears to require that institutions comply with state consumer protection laws for closure, recruitment, and misrepresentation where the institution is located and where the student is located at time of initial enrollment. The second post addressed the institution’s responsibility to satisfy applicable educational prerequisites where the institution is located and where the student is located at the time of initial enrollment as well as an edit to the currently effective public notification requirements.
The final regulations released have been modified to some degree from the proposed regulations. We believe that the public comments that we all shared with the Department were heard and persuaded the Department to make some changes to the final language. However, we believe there appears to still be some misunderstanding by the Department about the variation of oversight for licensed professions by state and by the specific profession. Additionally, there are lingering questions about the applicability of state consumer protection laws upon institutions that participate in reciprocity.
Please consider sharing your questions with the Department on these areas, especially regarding the challenges of coordination of processes and information with state licensing boards. The Federal Register announcement includes the contact information for the Department staff member addressing this issue. For certification procedures: Vanessa Gomez. Telephone: (202) 987-0378. Email: Vanessa.Gomez@ed.gov.
In both posts we will ask the following questions:
What does the final regulation say?
What questions and comments did WCET and SAN share with the Department during rulemaking, public comment period, and the Office of Management & Budget final review (EO 12866 Meeting)?
How did the Department respond to WCET and SAN’s questions in the preamble of the final regulations?
What are the implications to the institution for implementation of the regulations?
*Please note that page numbers in the analysis will refer to the unofficial version of the rules released on October 24 as that document is larger print and easier to direct you to the language of the preamble and regulations.
Final Regulations Addressing Programs Leading to a License or Certification: Certification Procedures – 34 CFR 668.14(b)(32)(ii)
*Language that is in the final release but was changed from the Department’s proposed regulation is in bold.
32) In each State in which: the institution is located; 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…
(ii) 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;…
What questions and comments did WCET and SAN share with the Department during rulemaking, public comment period, and the Office of Management & Budget final review (EO 12866 Meeting)?
During rulemaking.
From the very start of the rulemaking, WCET and SAN were concerned that the rulemaking committee lacked important input from the professional licensing regulating community. During week one of the rulemaking in January 2022, WCET and SAN provided public testimony asking the Department several questions:
Had the Department communicated with the licensing community to know the variations of oversight of the many professions and states?
Had the Department considered any exceptions to this rule to include active military students and military-affiliated students, and others who are temporarily in a location and do not intend to seek licensing in the state where they are located while participating in the program?
How does the Department reconcile barring a student from participation in a program that may only have minimal state educational prerequisite differences and the profession provides a pathway to a state license to reconcile those differences after completion of the program?
Public Comment.
In the WCET and SAN public comment that was focused specifically on programs leading to a license or certification, we first recommended to the Department that they withdraw the proposed language in favor of continued implementation and enforcement of existing notification regulations that became effective July 1, 2020. In the alternative, we recommended that the Department provide for an exception through the form of a Written Acknowledgment from the student to indicate that the student knowingly is enrolling in the program and providing their reason despite the applicable education prerequisites not being met in the state where they are located at time of initial enrollment.
A detailed review of the Department’s analysis was provided in our public comment to include the lack of data and evidence leading to the proposed regulations. Additionally, we shared that minimal analysis of the issue was provided which was made more minimal by the fact that the Department incorrectly provided analysis in two places in the proposed regulation announcement for a separate subsection of the regulation while citing this subsection.
Five clarifying questions were posed to the Department related to the proposed language of 34 CFR 668.14(b)(32)(ii):
If the PPA indicates that for purposes of program eligibility the institution’s responsibility is specified at “time of initial enrollment,” does the program remain eligible for Title IV if the student moves to a state where the program does not meet prerequisites?
If the PPA indicates that for purposes of program eligibility the institution’s responsibility is specified at “time of initial enrollment,” if this proposed regulation becomes final and effective, would the requirement only address incoming students or would the institution be obligated to apply the requirement retroactively to students who are already admitted to the program before the regulation became effective?
What is the Department’s recommendation if there is the impossibility of the institution obtaining affirmation or some sort of a process to determine that the program meets state educational prerequisites in a state?
How does the Department reconcile the limitation on institutions and ultimately students from meeting state educational prerequisites for Teacher Preparation Programs that often include only a course or two in the program addressing state specific history or culture, even though there is a pathway to licensure through NASDTEC state reciprocal agreements and the new Teacher Education Compact for license mobility?
If the language in the PPA proposes that program eligibility is contingent upon the institution’s program meeting state educational prerequisites where the student is located, why is there a need for notifications?
Office of Management & Budget (OMB) final review (EO 12866 Meeting).
WCET & SAN provided testimony to the OMB/OIRA meeting which is the final review prior to the Department’s release of final regulations. We shared our concerns related to federalism as we believe that the Department is creating barriers that overstep the state’s rights to create regulations and decisions to how students are served in their states. Additionally, we shared our concerns of economic impact and state burden as we believe that the Department is burdening state licensing boards to create oversight responsibilities as well as disregarding states choices to participate in other pathways of reciprocity and professional compacts to address state license transfers despite state licensing variations. Finally, we shared our concern that the regulations conflict with Biden Administration goals considering the July 2021 Executive Order 14036 to address unnecessary licensing restrictions that impede worker mobility.
Although we had heard that the review panel rarely asks questions, we were pleasantly surprised that the panel asked many questions and remarked upon the specificity of the issues of concern that we raised.
How did the Department respond to WCET and SAN’s questions in the preamble of the final regulations?
1. Regarding “time of initial enrollment” (pages 366-377). The Department points to existing regulation 34 CFR 600.9(c)(2)(iii) that indicates that an institution is to have a policy to make a determination of where the student is located at time of initial enrollment and upon formal receipt of information that the student has changed location to another state. The Department believes this gives the institution flexibility to determine how to structure such a policy.
The Department shares that they recognize that the institution cannot predict if a student moves, and they do not think it is reasonable to apply this criterion in a way that covers students after they move.
The Department addresses the related issue of changes in requirements for existing students on page 484 to say that they do not expect institutions to immediately discontinue programs for existing students when requirements change but do expect the institution to come into compliance with new requirements in “short order” or cease enrolling new students in that program.
2. Regarding retroactive application to students admitted to programs before the regulation became effective (page 367). The Department indicated that its goal is not to have this regulation apply retroactively. The regulations cover new program entrants on or after the effective date of these regulations (July 1, 2024).
3.Regarding the impossibility of determining that the program meets state educational prerequisites (pages 383-383). The Department is very clear in its concern that students who use Title IV funds for their programs do not end up incurring debt because they were not able to meet requirements in the occupations for which they are being prepared. They are very focused on the economic return that could be diminished if the program does not meet applicable educational requirements.
To that end, the Department indicates if educational requirements exist, an institution must follow them with respect to the students attending from those states. The Department further clarifies that, if the institution cannot determine if the program meets the education requirements for licensure or certification, then it cannot offer the program to future students in the state.
4. Regarding state professional reciprocal agreements and professional compacts (Page 398). The Department indicated that they are persuaded by the commenters that the way to meet the state educational requirements can take different forms. The Department expresses its understanding that a student can obtain a license in a different state but allow them to use the license elsewhere. The Department indicates that it believes these situations address the Department’s policy concerns. However, the Department cautions that this option is to provide the ability for the student who obtains the license through an interstate professional licensure reciprocity agreement (and we add a compact) would allow them to work in the State covered by the requirements of the new regulation, 34 CFR 668.14(b)(32)(ii). The Department continues by indicating that this could mean not only a full license, but also a provisional license. This explanation is not captured in a regulatory change because the Department indicates that these pathways are all forms of licensure.
5. Regarding new final language about the attestation option (page 378 and on page 391-392). The Department indicated that they were persuaded by arguments from commenters that students may be living in one state but have plans to seek employment in another state. Therefore, they added a provision that in the alternative of meeting state educational requirements where the student is located at time of initial enrollment, if the student provides an attestation about the specific state for which they intend to move and the program satisfies educational requirements in that state, the requirement of this regulation is fulfilled.
Additionally, the Department indicated that it will be looking for information about how the information about eligibility was conveyed to the student to demonstrate that the student understood their attestation.
What are the implications to the institution for implementation of the regulations?
The Department has fully expressed its belief that a student who pursues a program leading to a license that is necessary for employment, relies upon the institution to inform and protect the student from barriers to employment due to the inability to meet educational requirements where the student is located while participating in the institution’s program. The final regulations and the guidance provided in the announcement of the regulations indicate that the Department has considered that there could be a few pathways to achieve the goals of informing and protecting the student. However, we see in this announcement that the Department does not believe that they themselves have a responsibility to inform and collaborate with the professional licensing community that does not typically operate and focus within higher education on educational requirements and processes.
Institutions will need to certify a path to licensure in each state it enrolls students.
This new regulation will require the institution to do more than is currently required in providing notifications. In order for the program to be approved for federal financial aid, the institution must certify that the distance education program or correspondence course meets designated certifying events in order to serve that student in the program.
Satisfy state educational requirements where the institution is located; and
2a Satisfy state educational requirements where the student is located at the initial time of enrollment; or
2b Satisfy educational requirements in the state where the student has provided an attestation that they intend to seek employment.
As previously explained, the Department is very clear that the currently effective notifications, while important, are not wholly sufficient to protect students in these programs. The additional responsibility to satisfy educational requirements is now placed upon the institution in order to serve students in other states.
Students can supply an attestation that they are in a state where they will not seek employment. The Department has recognized that temporary circumstances could cause a student to be located in a state for which they do not intend to seek employment. This alternative to satisfying educational requirements where the student is located is provided within the final regulation. Implementation of this alternative will require additional documentation and interaction with the prospective student. The institution must develop a process to explain the circumstances and seek an attestation from the student designating the state they intend to seek employment if different from where the student is located. It is important to note that this alternative is placed within the language of the regulation which should be contrasted with the guidance about professional licensure reciprocity and compacts addressing portability of a license.
Interstate professional licensure reciprocity agreements or compacts are recognized.
Within the announcement, the Department recognized that some professions participate in licensing reciprocity and licensing compacts by referencing a public comment pointing to Teacher Preparation that maintains an interstate agreement/reciprocity-like structure through the National Association of State Directors of Teacher Education and Certification (NASDTEC) as well as the new Interstate Teacher Mobility Compact. Through guidance, which is not legally binding, the Department indicated these options would provide a means to obtain a license in other member states and therefore would be sufficient to satisfy applicable educational requirements. The Department indicated that this pathway to employment is not captured in the regulatory change because the Department indicates that these pathways are all forms of licensure.
In practice, this pathway would allow the student to first obtain the license from the state where the institution is located and then, if applicable, pursue the state license in the other state through state agreements or state compact if the states are members of these agreements. This option to consider post-licensure portability opens opportunities for students in more states.
However, it is important to recognize that not all professions/occupations have a licensing compact. For example, an interstate compact exists for Cosmetology, but a compact has not been developed for Athletic Training. Additionally, not all states are members of the compacts that do exist. For example, only 10 states are currently members of the Interstate Teacher Mobility compact. Institutions should be very cautious, research thoroughly, and document these opportunities to rely upon state agreements and compacts as the pathway to indicate satisfying education requirements in order to serve students in other states.
In summary…
The bottom line is that this new regulation underscores the current responsibility for the institutions found in the state authorization of distance education regulation and indicates that those institutions must:
ensure that the institution has a clear process to identify the student at the initial time of enrollment,
create a clear process to inform and document the use of the alternative attestation by students,
complete necessary research to know which professions and which states an institution may utilize alternate pathways, such as state license agreements and licensing compacts. State-specific research and documentation remains very important when serving students in programs leading to a license.
Institutional Information (Public Notifications) – 34 CFR 668.43(a)(5)(v)
What do the final regulations say?
(v) If an educational program is designed to meet educational requirements for a specific professional license or certification that is required for employment in an occupation, or is advertised as meeting such requirements, a list of all States where the institution has determined, including as part of the institution’s obligation under § 668.14(b)(32), that the program does and does not meet such requirements; and
This subsection was not included in the proposed regulations, but some changes were made to the currently effective regulations in order to harmonize with the previous subsection.
(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.
What questions and comments did WCET and SAN share with the Department during rulemaking, public comment period, and the Office of Management & Budget final review (EO 12866 Meeting)?
During Rulemaking.
As previously indicated in the public testimony, we shared concerns that the licensing community had not been included in these discussions. We pointed to the currently effective federal regulations that became effective July 1, 2020. We shared that at the time of the testimony the regulations had only been effective for a little more than 18 months and were made effective during the pandemic. We also pointed out that little time had been given to ascertain if the effective regulations were sufficient for student consumer protection.
Public Comment.
We shared with the Department that absolutely no analysis was provided in the proposed regulation announcement addressing the language amending the public notifications in 34 CFR 668.43(a)(5)(v). Neither did we find any new proposed language nor analysis to consider the harmonization of current individualized notifications in 34 CFR 668.43(c).
Two clarifying questions were posed specifically to address the proposed language amending the notification regulations:
Does the proposed language indicating an amendment to language for public notifications to be lists of all states where the institution “is aware” mean that the institution may not be ultimately addressing each state as is currently required in federal regulation 34 CFR 668.43(a)(5)(v)?
How does the Department intend to harmonize the proposed new language in the PPA identifying program eligibility to be “at initial time of enrollment” to the language in 34 CFR 668.43(c) indicating notifications to prospective students “prior to enrollment in the program” which could include prospective face-to-face students who will ultimately be located at the institution where the program meets state educational pre-requisites at time of initial enrollment?
Office of Management & Budget (OMB) final review (EO 12866 Meeting).
Specific to the notifications, we shared with the panel that notification regulations already exist as guardrails to protect students having become effective July 1, 2020. Additionally, neither the Department nor members of the negotiating committee offered any data that the current regulations were not sufficient to protect students in programs leading to a license or certification.
How did the Department respond to WCET and SAN’s questions in the preamble of the final regulations?
Regarding the term “is aware” of meeting or not meeting state educational requirements (pages 395-396). The Department agrees that the term “aware” was confusing and conflicts with language in the PPA. Therefore, the Department changed the term to “has determined.” Additionally, on page 389, the Department indicated if an institution is not enrolling students from a given state, it is not obligated to determine anything regarding that state. Further, it cannot only offer the program to students in that state.
Regarding harmonization of notification language with new PPA language (pages 395-396). The Department believes that the new PPA certification language complements the notification requirements but is making some alterations to the notification language to address areas of confusion.
What are the implications to the institution for implementation of the regulations?
The Department maintained the core structure of the notification regulations with some modifications from the currently effective regulations. Most obviously missing is the option to indicate no determination for the public notifications. The Department is focused on sharing information where the institution has determined that the program “does and does not meet such requirements.” This public notification is to address the institution’s obligation in the PPA as we previously discussed. If the institution cannot affirmatively meet state educational requirements, the institution cannot offer the program to the students in that state. This requirement remains essentially the same but eliminates the requirement to list the states for which the institution has not made a determination.
While the direct notifications were not part of the proposed regulations released last May, the Department was reminded through public comments that direct notifications needed to be harmonized with any changes to the public notifications.
To prospective students prior to enrollment in the program if the program does not meet or no determination has been made as to whether the curriculum meets state educational requirements where the student is located.
To the enrolled students where they are located if the curriculum does not meet state educational requirements. The notification must be provided within 14 calendar days of the institution making such a determination.
Notifications limited to distance education and correspondence students, not on-campus enrollees.
These direct notifications point specifically to obligations under the PPA addressing distance education programs by indicating in accordance with the PPA certification regulation. The requirements are essentially the same as those currently required, but seem to indicate that the notifications are only for distance education programs and correspondence courses. This appears to be a change: under currently effective regulations there is no reference to a specific modality. Absent a specific reference to a certain modality, there is a responsibility to notify all prospective students who intend to come to an institution, including those attending a face-to-face program. The obligation to notify a prospective student from another state planning to come to the campus to pursue the program face-to-face appears to be removed.
Notify student about where meet/not meet licensure requirements in their stateThe notification structure is primarily the same responsibility as the currently effective regulations to identify the programs and determine the states where the institution meets or does not meet state educational requirements. Depending on these determinations, there may be an obligation to provide a direct notification to a prospective or enrolled student. Again, the institution’s responsibility is to develop and implement a clear process to determine the location of the students, to continue pursuing state-specific research, and to provide documentation are the key elements when serving students in programs leading to a license.
Conclusions: What Institutions Should Do
Our early analysis of the new final regulations addressing programs leading to a license and state authorization leads to the following conclusions:
Certification by the institution to determine that the institution satisfies state educational requirements for programs leading to a license and related notifications, will be the work for the institution, and must include:
Review and revision of the institution process to determine the location of the student at time of initial enrollment as has been required since July 1, 2020.
Research of state educational requirements for a license as well as interactions with state licensing boards must continue.
Consideration, implementation, and documentation that the option to seek an attestation from students of their intention to pursue employment in a state that the institution must satisfy state educational requirements.
Research, analysis, and documentation to implement the Department’s view that state licensing agreements/reciprocity and licensing compacts may be considered as meeting state educational requirements if the states are members to these agreements or compacts.
Continuation of the institution’s process to implement public and direct notifications, and,
Finally, communication with senior administration and general counsel may be necessary to make business decisions about institution priorities to serve certain states and certain professions.
Next Steps
These conclusions come from our early analysis. We still have questions, and as we’re sure you still have some questions, SAN and WCET will be seeking your input on what we cover next. We maintain that in working together we will develop implementation strategies. SAN is already in process of reaching out to national associations for licensing boards to inform them of the final regulations. We will also collaborate with NASASPS and the SARA Community to ensure that applicable information is shared. Additionally, we urge you to follow the Federal Register announcement direction to seek more information from the Department staff member addressing this issue. For certification procedures: Vanessa Gomez. Telephone: (202) 987-0378. Email: Vanessa.Gomez@ed.gov .
Today we welcome several staff from the eLearning Department at Sinclair Community College, who are here to share about a new tool they use for designing and evaluating digital courses.
Sinclair Community College prioritizes transformative teaching and learning reflecting the Dayton region’s goal of holistic diversity. The college’s mission reflects the historic words of its founder, David A. Sinclair, himself a Scottish immigrant: “Find the need and endeavor to meet it.” With the institutional mission and priorities in mind, the college’s eLearning Division set the goal to close the equity gap for marginalized groups of people by expanding digital equity and inclusion for all learners.
Enjoy the read and enjoy your day,
Lindsey Downs, WCET
The work began through a partnership between the eLearning Division, the Provost Office, and the Diversity Office. This collaboration identified challenges to students attending class online, that is any eLearning course which includes asynchronous and synchronous online, blended/hybrid, and competency-based courses. We found that there were several barriers for students, such as access to technology, and we saw a clear digital divide. The eLearning Division formed the Digital Equity Committee, a group of faculty and staff, with the intention to examine eLearning course design processes to close the identified equity gaps
Intentional inclusive course design strategies that reflect and celebrate student diversity and foster a sense of belonging have been found to have a positive impact on student achievement. Heeding this principle and realizing solutions to stated barriers exist, the Digital Equity Committee created the Equity Rubric inspired by Peralta Community College to create a systemized process of digital equity and inclusion into the course design practice.
Process and Implementation
Institutional leadership embraced the efforts to increase digital equity and inclusion. Eventually, these goals and values were welcomed across the campus, fostering a system of cross-departmental collaboration. Having identified the necessary changes to eLearning courses to increase equity and inclusion, gathering an engaged team of supportive faculty and staff became far less challenging. The Digital Equity Committee recruited student input and feedback through institutional end-of-course surveys and participatory focus groups to help guide the creation of the rubric. Sinclair’s Chief Diversity Officer provided vital oversight and counsel to the development of the Equity Rubric. Finally, the sanctioning of the rubric led to its implementation into the course design process of the eLearning Division’s Instructional Design team.
The rubric serves the Sinclair population at many levels by helping faculty and course designers build course material that welcomes learners to an inclusive and friendly environment. Sinclair staff, faculty, and students have come to hold the rubric in high regard for its value added to our courses. The Instructional Design team regularly references the evaluation tool when assisting faculty with course design and revision to support thoughtful and inclusive material. Since the implementation of the Equity Rubric into the course design process, 212 eLearning courses have been evaluated and designed using the Equity Rubric recommendations.
The Equity Rubric
As an evaluative tool, the rubric is now leveraged by faculty and instructional designers as part of normal design or revision processes to evaluate course content, assessments, materials, and other items aimed to ensure they support the goals of digital equity and inclusion. The rubric contains three targeted criteria:
Addressing Human Bias – affords faculty a chance to acknowledge their own biases, include statements demonstrating the commitment in the course to creating an environment of comfort and participation, and the verbalization of self-reflection both in an instructor introduction and throughout the course.
Content Meaning – emphasizes content reflective of student diversity through connection to student socio-cultural backgrounds (based on institutional demographic data), courses include examples from non-dominant cultures, and at least one topic outcome for multiple topics is directly connected to non-dominant cultures and diverse perspectives.
Connection and Belonging – the course requires consistent interactions and works on fostering connections among students and with the instructor, the design of interaction is intended to strengthen connections based on diverse experiences and perspectives, and the inclusion of a statement of how the course provides an open, welcoming space for learners.
Each criterion contains qualifications based on four levels – Exemplary, Aligned, Minimally Complete, and Incomplete.
Expansion of the Equity Work
After the implementation of the Equity Rubric, the eLearning Division saw an opportunity to further increase the diversity, equity, and inclusion focus in eLearning coursework. In order to expand this focus, the division applied for and was awarded the ECMC Grant. With the funds from the grant, the eLearning Division hired an Equity Success Coach and an Equity Instructional Designer, who were tasked to carry out the work of the Equity Rubric and expand it throughout the college.
The ECMC Team implemented diversity, equity, and inclusion (DEI) touchpoints into multiple systems across campus. To help faculty relate to the Equity Rubric, the ECMC Team integrated DEI modules into existing required faculty training, which must be completed before teaching eLearning courses. The new modules are open to all faculty and discuss the significance of focusing on DEI in the classroom and how faculty can achieve that through assignments, setting a tone of acceptance and inclusion in welcoming statements, how to include an array of diverse voices and perspectives in course materials, and more.
The Equity Rubric continues to impact our campus through the eLearning’s Coach Collaboration project, where eLearning Coaches partner with faculty for one or two terms as an in-course resource. The partnership between faculty and coach aims to improve student and eLearning course outcomes by using research-based best practices and holistic support of students. Faculty benefit from course delivery suggestions that include best practices for assignment feedback, employment of student surveys, monitoring student grades and engagement, support in developing a communication plan, and providing DEI-designed student support tools and resources. Our faculty and students say the courses have been positively impacted through this partnership program. This, and the other projects discussed above, will continue to support the mission of closing equity gaps in eLearning courses.
The classroom is perhaps the most important frontier by which equity strategies and efforts are tested, and the steady growth in eLearning courses before and after the COVID-19 pandemic provided the exploratory space needed for the work. As online learning expands, grows, and transforms the eLearning Division at Sinclair Community College will continue to prioritize diversity, equity, and inclusion.
This week, we’re joined by Brad Griffith, Associate Vice Chancellor of Innovation with the Oklahoma State Regents for Higher Education. Brad outlines the history of the Online Consortium of Oklahoma and how this group collaborates within the state to impact student success. Thank you Brad for today’s great post!
Enjoy the read,
Lindsey Downs, WCET
The role of online learning in postsecondary education has never been more crucial. For our state, the Online Consortium of Oklahoma (OCO) has evolved from a grassroots initiative to a model of what can be achieved when institutions come together to address the challenges and opportunities of digital education. We are excited to dive into the key strategies and initiatives that have made OCO a success story, offering insights that could benefit other state systems of higher education or similar member-driven consortia.
OCO’s Grassroots
Founded in 2018, OCO was established to foster collaboration and innovation in online learning across Oklahoma. The consortium now collaborates with 26 member institutions, each contributing its unique strengths to create a robust and diverse body of resources and expertise. The collective aim is to enable all member institutions to provide high-quality, accessible, and flexible educational opportunities for students across the state.
Key Initiatives and Innovations
Council for Online Learning Excellence (COLE) – COLE consists of over 125 volunteer members serving across seven subcommittees dedicated to fostering professional development, learning innovations, and pathways to student success. OCO works in collaboration with COLE to constantly serve those teaching and supporting online learners, including through regular awarding of grant funding for special projects upon request by committees.
Low-Cost and No-Cost Professional Development – OCO prioritizes the upskilling of faculty and staff through affordable professional development programs. This ensures that educators are well-equipped to deliver top-notch online instruction.
Technology and Project Pilots – OCO has offered grant funds to its member institutions to pilot new and innovative learning technologies in addition to serving as the initial incubator for projects, including those focused on Open Educational Resources (OER), which have secured ongoing funding support from the State Regents.
Group Purchasing for Technology – By leveraging the collective bargaining power of its members, OCO has been able to secure cost-effective deals on essential educational technology, passing the savings onto students.
Collaborative User Groups – OCO facilitates the creation of user groups focused on common online learning platforms and student success initiatives. These groups serve as think tanks for sharing best practices and troubleshooting challenges.
Annual Summits – OCO supports our system’s annual OER Summit and Learning Innovations Summit hybrid events, which offer a platform for educators, administrators, and other stakeholders to share insights, discuss trends, and explore new opportunities in online education.
In September 2020, OCO, in collaboration with the Oklahoma State Regents for Higher Education, launched OCOlearnOK.org. This platform serves as a one-stop-shop for resources related to online education, including OER, digital accessibility guides, and an extensive library of on-demand webinars. It also features a calendar of upcoming professional development events and new digital credentialing opportunities.
The Role of Leadership
OCO’s membership dues enabled the State Regents to hire a full-time staff member to serve the consortium in October 2019. Support from the state level has been essential for the success of the Consortium, particularly in communication of the value of online learning to key stakeholders. In July 2023, OSRHE established a new Associate Vice Chancellor of Innovation position. In this role and with my team, we are responsible for helping the consortium set and achieve its goals. The vision and commitment of OCO’s members have accelerated the quality, capacity, and scope of online learning in Oklahoma.
Collaboration is Key – The power of collective effort cannot be overstated. Pooling resources and expertise, particularly among institutions of diverse sizes and student demographics, leads to more significant impact.
Stay Adaptable – The landscape of online education is constantly changing. Being flexible and open to new technologies and methodologies is essential.
Invest in Professional Development – Well-trained faculty and professional staff are the backbone of any successful online program. Develop expertise from within your own collaborative and support those new to their roles at institutions across your network.
Engage Stakeholders – Regular communication with all stakeholders, including regents, legislators, presidents, academic and technology officers, faculty, administrators, and students, ensures that everyone is aligned with the consortium’s goals and aware of its progress.
Conclusion
The Online Consortium of Oklahoma serves as an adaptable model of what can be achieved through collaborative effort and visionary leadership. As we continue to innovate and expand, we are deeply honored to have been recognized by the WCET community with the 2023 Outstanding Work Award. This accolade holds special significance for us, coming from a community that has been instrumental in supporting our journey toward achieving the outcomes described in this post. We extend our heartfelt gratitude to WCET and its members for this recognition and for their ongoing commitment to advancing the quality and reach of digital learning programs. Together, we continue to define new benchmarks and create transformative educational experiences for every learner.
This month, WCET selected Academic Integrity as our focus area theme. I always associate October with academic integrity because of the International Center for Academic Integrity’s (ICAI) International Day Against Contract Cheating – which, this year, is being re-framed as the International Day of Action for Academic Integrity. And the day sure has a great theme narrowing down how to be a champion for academic integrity in the age of artificial intelligence (AI).
There are all kinds of events happening today, October 18th. That’s why I’m so thrilled to welcome Camilla Roberts who serves as the President of the ICAI to discuss the inspiration for today’s event and how you can participate. Thank you Camilla for joining us and sharing all of the details for this important day. I hope you will get involved in anyway you can, we’ll be sharing our thoughts on our social media using #IDOA2023, #excelwithintegrity, and #myownwork.
Enjoy the read,
Lindsey Downs, WCET
We are currently in a world of change and education is not hidden from these changes. While technological advancements (including artificial intelligence (AI)) have opened new possibilities for students and educators, it has also given rise to challenges in upholding academic honesty.
The International Day of Action for Academic Integrity is an annual event celebrated worldwide, dedicated to promoting and preserving the fundamental values of academic integrity. The event encourages educators, students, and institutions to collaborate and champion academic integrity. This year’s event is co-chaired by Mary Davis from Oxford Brookes University, UK and Rachel Gorjup from University of Toronto, Mississauga, Canada with committee members from 7 countries.
One of the primary objectives of this year’s IDoA is to raise awareness about the importance of academic integrity in the digital age. The IDoA website provides a wealth of resources, ideas, and information on how to participate in this initiative, emphasizing the critical role that AI and technology play in maintaining academic integrity.
The day’s virtual events (running live with recordings available afterward from 3am-5pm EST on Oct. 18, 2023) will focus on the overarching theme of “Championing Academic Integrity in the Age of AI.” Within the 15 hours of sessions, attendees will have the opportunity to hear from 62 presenters (including expert speakers and seven sessions with student panels and contributors) from 15 different countries.
The goals for the day and beyond are to educate about the following:
Raising Awareness: The IDoA serves as a reminder that academic integrity is crucial, especially in the context of AI. It’s essential to educate students and faculty members about the implications of cheating and the importance of original work while understanding the role that AI can play in education.
Encouraging Ethical AI Use: Educational institutions and instructors must promote responsible AI use. This includes teaching students how to use AI tools for research assistance without compromising their academic honesty.
Strengthening Policies: Schools and universities should continually update and strengthen their academic integrity policies to address new challenges posed by AI. Clear guidelines on the use of technology and AI tools should be established.
Building a Supportive Environment: Creating an environment where students feel comfortable asking for help and resources can significantly reduce the temptation to cheat. By offering academic support, institutions can deter students from taking the dishonest path.
Developing Critical Thinking Skills: Education should focus on cultivating critical thinking skills, which are essential for distinguishing between legitimate research and AI-generated content.
Fostering a Culture of Integrity: Promoting a culture of academic integrity within institutions is crucial. This includes fostering a sense of trust and responsibility among students and faculty.
The International Center for Academic Integrity encourages all involved in education to take time to examine how they can champion academic integrity in the age of AI. By doing so and creating a culture of integrity, we can ensure that education remains a trustworthy environment for all learners and the degrees or certificates provided to our learners upon completion are valid and respected. The IDoA event gives us the opportunity to reflect on our roles in upholding these values and working collectively to maintain the highest standards of academic honesty in the digital age.
Upholding academic integrity goes beyond just one day though, so we also encourage you as an individual or as an institution to join the International Center for Academic Integrity (https://academicintegrity.org/about/member-benefits) to continue the conversation of building the culture of integrity at your own institution.
Today, we welcome the author of the paper, Sharyl Thompson, who offers us summarized insight into the very complicated and nuanced compliance road for state authorization of interstate distance education.
Sharyl is a long-time colleague and friend of SAN who not only witnessed but was an active participant in this evolution. In addition to the experience that Sharyl offers in her biography, which is shared at the end of the paper, Sharyl served as one of SAN’s Basics’ Workshop mentors for many years and has been a regular presenter and contributor to SAN. Sharyl was also among those on the initial team that worked on the reciprocity idea for state authorization of distance education that ultimately became SARA. You can read more about this initial team for reciprocity and the beginnings of SAN in our WCET Frontiers post celebrating the 10th Anniversary of SAN in 2021.
A big thank you to Sharyl for developing this thorough paper chronicling the evolution of state authorization of distance education and for sharing the following summary today on Frontiers.
In the early years of higher education, many states had no oversight over institutions – until diploma mills entered the marketplace and, in many situations, cheated students by taking their money and providing inadequate or no education to their “students.” Individual states passed legislation to oversee higher education institutions. Each state differed in the level of oversight, which activities from out-of-state institutions required some form of approval or review, and the costs for receiving the required state authorization. However, the early regulations did not address distance education, as, at that time, it didn’t exist.
The History of State Authorization of Distance Education paper was commissioned by the State Authorization Network (SAN). It is a chronological depiction of the evolution of state oversight of activities conducted by in-and-out-of-state institutions. The paper begins with background on state authorization – what it is and why oversight was needed. It addresses the importance of terminology and provides some detailed examples for two basic terms: “school” and “operating.” Other state-by-state differences addressed in the paper are the applications for authorization, the application processes, and the timeline for receiving a response from the state agencies to the institutions’ applications.
In 2010, the U.S. Department of Education (ED) published regulations that addressed distance education for the first time. Although state regulations had been in place for years, institutions were unaware that they should have been seeking and receiving permission from individual states to conduct certain academic activities. When the ED published these regulations, institutions all over the country began to be aware of the state and federal obligations concerning consumer protection. It is challenging to describe the chain of events chronologically at the federal level due to implementation delays overridden by newer regulations and their implementation. The paper goes into great detail on the evolution of federal regulations and their impacts. Even today, ED is in the process of creating more regulations for which institutions are to abide.
A major change in interstate oversight of distance education came about after 49 states and territories, all except California, voluntarily joined the State Authorization Reciprocity Agreements (SARA). Several efforts had been made in the past to create a way for institutions to receive reciprocity for state authorization. With the initial establishment of SARA in 2013, if authorized in the home state, the institution would be authorized to provide distance education-related activities subject to the agreement in the other states that are members of SARA. The paper provides a history of efforts made, as well as the creation, acceptance, and effects of SARA on states, institutions, and students.
I was excited to be invited to write this paper. I started working in state authorization while employed at a distance education for-profit institution back in 2001. At that time, the for-profit institutions were the only ones paying attention to state authorization. There was no information sharing between institutions, so I had to learn it on my own. Although very challenging, as time progressed, I grew to appreciate the years of experience I gained through learning state authorization from the ground up. As a result, I continue to have an interest in helping other institutions learn the ins and outs of state authorization, so they don’t have to go through some of the agony I experienced when no assistance was available. I am motivated by helping institutions succeed at this work.
After thirteen years of employment doing state authorization work at three different institutions, I decided to become an independent consultant, which affords me the opportunity to work with multiple institutions simultaneously. That was ten years ago. It has been and continues to be my pleasure to work with many institutions of all types to address state authorization and professional licensure issues.
State authorization work continues and will continue because of the rather frequent changes made to federal and state regulations. The newest proposed federal regulations may impact how SARA can be implemented and may require institutions to almost go back to the days when state authorization work must be handled on an individual state-by-state basis. Only time will tell . . .
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