Categories
Practice

RioPACT: Transforming Student Success at Rio Salado College

Each year, the goal of the WCET Awards Program is to highlight and showcase promising practices in higher education digital learning and to honor those who have dedicated their time and energies to our field.

It is an absolute honor for me to coordinate this program each year. One of my favorite aspects of this program is to work with the WCET Outstanding Work – WOW – Award winners.

From the beginning of our “awards season,” where we receive nominations and work with our amazing volunteer judges, I am always in awe of the nominated projects and initiatives. It’s amazing to learn about the innovative work happening on in higher education. This year it’s exciting to feature our three WOW Award recipients, but I also want to thank each of the individuals and teams that submitted a nomination this year. You’re all doing inspirational and important work and it was hard to narrow the nominations down to these three!

As we’ve announced, WCET will be awarding three WOW awards at this year’s WCET Annual Meeting. All this month and leading up to the Annual Meeting, WCET Frontiers will feature posts from our three selected recipients:

  • Rio Salado College – RioPACT
  • Oklahoma State Regents for Higher Education – Online Consortium of Oklahoma
  • Sinclair Community College – Course Equity Rubric.

To kick off this year’s WOW Awardee series, we’re happy to welcome Zach Lewis and Dr. Fermin Ornelas from Rio Salado College to share about their award winning student success solution: RioPACT. Stay tuned for the rest of the month to learn about our other awardees. We’re looking forward to celebrating them at the Annual Meeting in New Orleans in just a few weeks!

Enjoy the read,

Lindsey Downs, WCET


The Challenge and the Goal

In the ever-evolving landscape of higher education, institutions are constantly seeking innovative ways to support student success.

To accomplish our student retention and success goals here at Rio Salado College, we needed a way to identify students in need of intervention before they withdrew or dropped out, and off-the-shelf analytics solutions did not meet the needs of our learners. To address this challenge, we developed our own analytics tool that would empower our staff to assist and support our specific student population.

The Solution: RioPACT

This journey led to the creation of RioPACT (Persistence and Completion Tracking), a predictive analytics tool designed to assess a student’s likelihood of persisting and continuing their studies. The RioPACT model analyzes three key areas:

  1. student course engagement,
  2. academic success and momentum, and,
  3. select demographic characteristics.

RioPact is a tool that enables us to identify students in need of additional support. That information is provided to student-facing staff to intervene at the right moment to keep students on the path to degree or certification completion.

Helping Rio’s Students

Photo by Annie Spratt on Unsplash

While commitment to student success and innovation is not new for Rio Salado, requirements for this specific tool and our college’s student body necessitated a different approach.

The majority of Rio’s learners are nontraditional: over 80 percent of our students attend part-time, nearly half are first-generation college students, and 40 percent have previously attempted higher education without success. The average student age is above 25 and we know many of our students are carrying multiple responsibilities as providers, caregivers and workers. We were determined to create a solution to meet the needs of our students and were able to leverage data captured in our in-house systems and applications to build a model attuned to Rio’s specific learner dynamics.

When the data model was initially developed, early results were highly promising, with a predictive accuracy rate of nearly 75 percent. RioPACT’s value, however, went beyond just the statistical significance and our early pilot underscored the potential for the tool. We first worked with the Office of Disability Resources and Services (DRS) last fall to further understand how to put the RioPACT to use. The 73 students who were identified as at higher risk for stop-out by RioPACT received interventions and additional support from DRS. When we reviewed student outcomes in the spring semester, over 52 percent of students who received treatment in the pilot persisted compared to 44 percent of students who did not receive any intervention. This was just a small sample of what could be achieved, but provided promising evidence that we were creating something that could have a much larger impact on our students.

What’s Next

As we move forward, we’re refining RioPACT and optimizing data capture to provide even better insights and just-in-time services to our students.

Textbox: The RioPACT project isn't just about improving student success at Rio Salado College; it's about making a lasting impact on the broader higher education community.

We’re scaling with a broader pilot this fall with the Office of Academic Advisement, not only to provide timely interventions to more students, but collect more data to evaluate, refine, and extend the tool. Furthermore, we have been awarded two research fellowships by the Strategic Data Project (SDP). The objective is to further enrich our skill set in data analytics and research methods as well as benefit from the expertise of the SDP alumni researchers. 

The RioPACT project isn’t just about improving student success at Rio Salado College; it’s about making a lasting impact on the broader higher education community. We’re excited to share our findings and publish our work, knowing that it has the potential to benefit students and institutions far beyond our own.

In the end, RioPACT represents the power of innovation, dedication, and a commitment to student success. It’s a reflection of Rio Salado College’s mission to redefine the educational experience by anticipating the needs of our students.

Thank you!

Receiving the 2023 WOW Award from WCET for RioPACT is a remarkable honor. It signifies that WCET values the ability of community colleges like ours to generate valuable, homegrown solutions. This recognition encourages us to continue taking the lead in shaping our educational landscape.


Categories
Policy Practice

WCET Survey of Institutional Digital Learning Definitions – Preliminary Report on Key Themes, Insights, and Challenges

Introduction

Online learning, hybrid learning, hyflex learning, blended learning, and distance education. What are the differences between these terms that necessitate the creation of novel words for variations of modality?

text box reads - WCET surveyed digital learning professionals on institutional practices in defining:
distance learning,
online learning, 
fully online learning, 
hybrid/blended learning, 
hyflex learning.

What goes into the institutional decisions on defining these terms? WCET – the WICHE Cooperative for Educational Technologies, gathered information relating to institutional definitions, policies, and procedures relating to digital learning definitions (such as distance, online, hyflex, hybrid, etc.) and how those terms are communicated to students. Administered earlier this year, the survey consisted of 23 open-ended and multiple-choice questions. This post provides preliminary findings with the full report and methodology to be published in the coming months.

This survey and analysis builds upon previous work of WCET to develop an understanding of the institutional practices relating to digital learning definitions and the challenges that institutions face in:

  • defining terms,
  • maintaining compliance, and,
  • achieving clarity and transparency with faculty and students.

Previous WCET work in the area of digital learning definitions analyzed the extent to which faculty and administrators agree with specific provided definitions of select terms (see Defining Different Modes of Learning: Resolving Confusion and Contention Through Consensus). This work also highlighted the variety of definitions of distance education used in policy by federal, state, and accreditation agencies plus the challenges said variety presents to institutional compliance (see Defining “Distance Education” in Policy: Differences Among Federal, State, and Accreditation Agencies). Click here to access an accessible PDF with the data from the tables below.

Highlights of Preliminary Survey Analysis

We have made a number of interesting observations based upon our review of the survey data received. During future institutional interviews, we will further explore a number of nuances, but today we will highlight several meaningful observations.

How “Online Intensive” Were the Institutions Surveyed?

In the survey, we asked institutions to identify their number of graduates who completed their program primarily online or at a distance in the most recent academic year.

Table 1. The percentage of graduates completing programs primarily online. See accessible version of this data.

Table 1 - In the most recent academic year, roughly what percentage of your institution's graduates completed their programs primarily (75%+) online or at a distance with few requirements to come to campus or go to a specific location?

0-25% of graduates - 62%
26-50% - 20%
51-75% 10%
76-100% - 8%

The bulk of institutional personnel responding to the survey represented institutions for which a quarter or less of their students graduated in a program that is primarily online. Less than 20% of respondents hailed from institutions which had more than half of their graduates complete programs primarily online. These data provide a good context for understanding other responses, as the responding institutions still have a preponderance of in-person students. The institutions are also likely to offer multiple course delivery modalities.

Does Your Institution Have an Institution-Wide Definition for Each Digital Learning Modality?

In the survey, we asked five questions to determine whether the institution defined a given digital learning term. Specifically, we had one question that focused on how the institution handles each of the following five modalities:

  • distance learning,
  • online learning,
  • fully online learning,
  • hybrid or blended learning, and,
  • hyflex learning.

For each question, institutions could select one of the following five choices for each modality:

  • We have an institution-wide definition,
  • We have definitions that vary by college or department within the institution,
  • We are actively working on creating or updating this definition,
  • We have no definition and there is no current work to create one,
  • Other (please explain).

Few Institutions Reported Definitions That Vary by College Or Department

We were surprised to see that the least chosen response (with the exception of the “Other” response), across all terms, was that definitions vary by college or department within the institution. Not only was that the least chosen response across all terms, but the percentage of responses was much lower than the others, with the highest being 6.57% for hybrid or blended learning. See Table 3 below for the overview of responses to whether institutions define these digital learning terms.

Table 2. Institutional Status of Defining Digital Learning Modality Terms. See accessible version of this data.

Our initial thought was that there would be more variation within each individual institution but that was not borne out by the results. It is important to note that, due to the fact institutions could only choose one response here, the number of responses may have been different had institutions been able to choose all that apply. For example, we now observe that, especially in the case of the “definitions vary” and “actively working on this definition,” both responses could be true and institutions may have chosen the response that felt more appropriate in the moment. Especially in this case, we hypothesize that one reason that there may be work on creating an official definition is the need to harmonize various definitions used throughout the institution. It will be interesting to explore this in more depth in follow-up interviews.

But, Institution-Wide Digital Definitions Are Often Still Not The Norm

Even with the lack of definitions varying by colleges and the growing maturity of digital learning, there are many institutions lacking comprehensive definitions. Only “distance learning” and “hybrid or blended learning” report more than 50% of respondents with an institution-wide definition. “Online learning” had only 40% with a definition.

The picture might be brighter than that as about 20% of institutions use “distance” or “online” synonymously. They might not see the need for both or use them interchangeably. Having nearly 60% of institutions reporting a standard understanding of “hybrid or blended learning” shows strength for that modality.

It is concerning that for all of the definitions offered at least 10% of the institutions neither have a definition nor have current work to create one. Given that our mailing lists favor those in digital learning, this is probably a bit more worrisome.

Notably, there’s also a variety of definitions for “fully online” despite what seems like a self-explanatory term, which was surprising to us. In some cases, online and fully online are considered synonymous and are not distinguished from one another. In other cases, a certain percentage of instructional time, or a limited number of in-person instructional time, is permitted within the institutional definition of fully online. In our review of the definition of distance education, we did not note definitions of fully online in policy (federal, state, or accreditor) but the survey responses clearly indicated that policy influences institutional variations of the term fully online, especially policies at the state level.

What makes a program fully online? This issue is examined briefly in the recently-released white paper on labeling modalities written by Nicole Johnson (CDLRA) and sponsored by WCET. In that paper we cite an instance where a university system cites “full online” as having no in-person requirements, but then links to a program that has in-person requirements. Whatever the case in how “fully” is defined locally, the institution should be clear in communicating their online vs. in-person expectations with students. We look forward to exploring this more with our follow-up interviews.

What Factors Influence Your Digital Learning Definitions?

Additionally, in one of our survey questions, we asked institutions to indicate what factors influenced the institution’s definitions relating to digital learning where respondents could choose all that apply. Not surprisingly, the top three influences were accreditor (63%), federal (57%), and state (48%) definitions.

One surprise that emerged in the responses to this question was an additional potential source of definitions that we had not yet considered that could bind institutions to certain definitions and interpretations, which are union contracts or collective bargaining agreements with institutional faculty and instructors. Notably, the influence of faculty and instructors on institutional definitions was the fourth highest choice at 47%, although it is not clear whether that is due to binding contracts with faculty, faculty expertise on course content and delivery, or a mix of both (likely a mix of both).

Table 3. Factors influencing digital learning related definitions. See accessible version of this data.

Table 3 - What factors influenced your institutional, college, or department’s definitions relating to digital learning? (choose all that apply)

What Obstacles or Challenges Did You Face in Creating Digital Learning Definitions?

Lastly, in one of our open-ended questions, we asked institutions to describe some of the obstacles or challenges that they have experienced relevant to digital learning definitions. A commonly listed challenge related to faculty adherence to the modality assigned to the course. To illustrate this commonality, here are some of the responses we received related to this challenge:

  • Not all faculty abide by the definitions; in some cases, faculty will list a course as one modality, but deliver it in a different way.
  • Sometimes the faculty will teach a hybrid class but teach it all online.
  • Faculty using their own interpretation of a modality.
  • Faculty following the definitions.
  • Instructors sticking to mode of teaching: e.g., says synchronous, but is asynchronous. Or hybrid, but all synchronous.
  • Overcoming some historical practices and making sure faculty practice the expectations of the guidelines for distance learning.
  • While the institution has definitions, faculty have a great deal of flexibility in how they are implemented.

We can see how this situation can be challenging for institutions, especially in navigating how to emphasize the importance of adhering to course modality. This could have a great impact on the institution (i.e., financial aid, accreditation, etc.) as federal, state, and accreditation rules can differ by modality. For example, the need for regular and substantive interaction, adherence to accessibility requirements, and intellectual property rules all change when a course transitions into the digital realm. There are also increased faculty development and instructional design needs and requirements. And, most importantly, the student is not getting the course experience they expected at registration. This could have a great impact on learning outcomes and exacerbate inequities in serving students.

We look forward to exploring the strategies that institutions are using to address this challenge in institutional interviews. We know that institutions have a variety of innovative means of not only defining terms but also seeking to ensure compliance with definitions in policy.

Next Steps  

We look forward to delving more into the data, expanding on our analysis, and gaining more practical insights from institutions in our subsequent institutional interviews and the full report to come later this winter. Join us at the WCET Annual Meeting for the session “Digital Learning Definitions: Let’s Talk and Share” on the afternoon of October 26, for a brief background on this work and lots of time spent sharing on how you are handling definitions in your setting.

If you have any thoughts or experiences you would like to share, please feel free to contact Kathryn Kerensky (kkerensky@wiche.edu) and Russ Poulin (rpoulin@wiche.edu).

Categories
Practice

HBCUv – Reimagining Digital Learning for HBCUs

National HBCU Week, a White House initiative to gather HBCU representatives, federal agencies, and supporting organizations, kicked off this week in Arlington, Virginia. The theme this year is “Raising the Bar: Forging Excellence through Innovation & Leadership.” Prior to the amazing discussion I had that I’m going to share with you today, I misunderstood what this specific HBCU Week was about. While I am a bit disheartened with myself for not knowing more about this annual conference, it did seem like a good week to share this interview write up.

A few years ago, WCET staff collaborated to redefine the mission, vision, and values of WCET. When we started this effort, I had worked at WCET for around four years. I felt like I had a good grasp of my role and was excited about growth opportunities to continue to explore the how’s and what’s of quality digital learning.  

Of course, then the pandemic came along, and we all pivoted in a variety of different ways. Not only did the landscape of higher education change, but many of us changed jobs, homes, roles, and even our expectations for how our life worked on a day-to-day basis. My role has shifted a bit and is different than what I would have thought back in 2020. And while our stated goals here at WCET are not substantially different from what this Cooperative has endeavored toward throughout its history, I do feel that the focus and scope of those goals have narrowed in exciting ways.


A Turning Point

Both due to the spotlight the pandemic set upon the digital divide and our work through Every Learner Everywhere, the entire WCET staff improved the mission, vision, and values of WCET to be more centered around equity. From 2020 on we engaged in educational, professional, and personal development on diversity and equity. This included reviewing resources and materials, working with other educators, and having some hard but exceptional discussions between team members.

This year, when our team met for our annual in-person staff meeting (did you know more than half of WCET staff now work remotely from ALL OVER the U.S.?) we all said the same thing – we’ve learned a lot and it’s been great, but now it’s time to do something about what we’ve learned.

So, we are. We have been re-tooling our resources, papers, articles, reports, projects, etc., to ensure equity and accessibility are at the core of everything we do. We want (and have started) to reach out to minority-serving institutions and organizations to make connections, engage them with our community, and, most excitingly, shine a light on the promising practices that make a difference for the students who need our help the most.

If this introduction was TLDR… we added equity to our mission and we’re following through.

One of my favorite aspects of my role is working with our guest authors and staff to write content for WCET Frontiers, especially when the posts highlight the work going on in the higher education and digital learning communities. When we thought about “who is doing equity in digital learning well” we thought specifically about minority serving institutions such as Tribal Colleges and Universities (TCUs), Historically Black Colleges and Universities (HBCUs), and Hispanic Serving Institutions (HSIs). We wondered: how do these institutions support their specific students, faculty, staff, and community in ways that make them all more successful? And can we work with those institutions, learn from them, and help other institutions serve minoritized students in similar ways?

Connecting with UNCF

UNCF (the United Negro College Fund) is a nonprofit connecting and supporting Historically Black Colleges and Universities – or HBCUs – through advocacy, funding, and professional development. UNCF provides a substantial amount of scholarship funds to Black students every year and even has a program for helping students facing emergency situations that might disrupt their degree program. The 79-year-old organization ensures HBCUs and their students have the resources to thrive. UNCF seemed to be the ideal organization to connect with to begin our journey to learn more about successful digital learning equity initiatives. Once connected, I had the pleasure to interview Julian Thompson, Senior Director of Strategy Development for UNCF’s Institute for Capacity Building (ICB).

UNCF founded ICB in 2006 to, in Julian’s words, “work on strategies that help HBCUs achieve long-term resilience and sustainability.” A critical goal for ICB is to identify initiatives and strategies for HBCUs to partner and learn from each other. Julian wants to help these institutions “achieve more together than what any of them could possibly achieve on their own.” The transition to remote learning due to the pandemic was also a significant moment for HBCUs – when only around 25% of HBCUs had online degree programs, compared to 55% of other institutions. As they reviewed the challenges HBCUs face when it comes to digital learning, ICB realized that there was no technology that truly fit into the HBCU method of educating students. And that method contributes significantly to the extraordinary results for Black students, especially those who are first generation and lower income. ICB had an opportunity to build an online learning system by and for HBCUs.

Thriving with HBCUv

The result of that opportunity was HBCUv – “a virtual ecosystem where the entire HBCU community can flourish together.”

ICB hoped to create a system with involvement of HBCUs, including platform development, strategy sharing, course sharing, knowledge sharing, etc. One of the guiding tactics for the project was to help HBCUs acquire and own more assets – such as tools, practices, technologies, approaches, etc.

The project began to take shape in spring/summer 2020. An important element of any higher education project is leadership buy-in and support, and that wasn’t any different here. ICB recruited nice institutions to serve as steering committee members. The representatives from each institution met with ICB multiple times a week, engaged with design and technology companies, and helped establish the vision of HBCUv. The work also included over 3,300 hours of research including focus groups, surveys, ethnographic studies and other methods to uncover the question of digital solutions, student success, and technology use on HBCU campuses. The question – what formal and informal learning experiences help HBCU students stay engaged and successful?

The Virtual Yard

One of the most significant conclusions of the big research effort was the importance of “The Yard.”

This term refers to a space of convening and collaboration on an HBCU campus. Julian advised that if you think about it, most full-time students are only in a classroom about 2 – 3 hours a day. The rest of those hours are spent on campus, with friends, in residence halls or other housing.

And that time spent outside the classroom has an important impact on their learning experience. ICB had to think of a way to expose students to those meaningful learning experiences that happen outside the classroom, as well as the learning that takes place inside the classroom. The “little things that you can’t plan for or arrange.

Think about the time you ran into someone a few years ahead of you in your program and they became a bit of a role model for you. You are inspired by them. Just that one interaction or knowing that one person can significantly impact a student’s success.” HBCUv will replicate that experience with the “Virtual Yard.”

What’s Next for HBCUv?

At this point the team at ICB has identified the vendors that will create the technical side of HBCUv and a dual enrollment/transfer organization that will establish transferable coursework.

The platform will be finalized later this year and a pilot is launching in early 2024. They hope to have HBCUv fully up and running with the steering committee institutions by fall 2024, with other HBCUs to follow.

Julian, thank you for sharing HBCUv with WCET and we all wish you the best of luck with the pilot process! I’m hoping you and the team will join us again, after the pilot so we can check in on how it’s going!


Categories
Practice

Generative Artificial Intelligence at Colorado Technical University

Over the last several months, WCET has been researching and developing resources on Artificial Intelligence and the use of Generative AI technologies such as ChatGPT in higher education digital learning.

An important aspect of our work in this area is to highlight what our member institutions are doing out in the real academic world. Today we’re excited to present a post doing just that – from our member Colorado Technical University. A huge thank you to Lisa Corprew and Connie Johnson for sharing with us the considerations and actions CTU has taken as Generative AI continues to make a large impact in higher education.

Enjoy the read,

Lindsey Downs, WCET.


CTU’s mission statement includes using technology to educate students. As the University experienced the rapid-speed information that Generative AI (and ChatGPT in particular) can provide for public use and was embraced by students to assist with their assignments, CTU leaders and faculty engaged to understand the possibilities, implications, and cautions related to the use of ChatGPT.

As the conversations unfolded, it was clear that there were several areas potentially impacted by Generative AI. Also clear is that while Generative AI itself does not have emotion, opinions and discussions can become quite spirited and diverse when discussing the future of and possibilities of AI in higher education.

As part of this process, the University reviewed several of the areas listed below:

Question 1: How would Generative AI affect academic work at CTU?

Faculty experience and feedback with Generative AI was mixed; faculty were equally concerned, baffled, and excited. Regardless of their feelings, they were seeking and deserved university direction. Fortunately, our exploration using a new AI “detector tool” led us to valuable direction rather quickly. The AI “detector tool” was extremely fallible. We stepped back from the common academic concern about plagiarism and got back to the heart of CTU’s Academic Honesty and Integrity policy: “original work.” As Generative AI does not replicate work, it does not create the risk of plagiarism. It does, of course, create the risk that students can submit work that is not “original.”

To manage this risk, faculty began to view student work differently. In many classes at CTU, faculty encourage students to use Generative AI to answer content questions and then use their own research and sources to validate those answers. English and coding classes were the earliest adopters of this type of use. Evaluating the sources of information allows students to reflect on the content, analyze the value of various sources, and separate fact from fiction. As Generative AI is not perfect and is known to “hallucinate” or integrate incorrect information, this analysis is not only a valuable academic exercise, but also a necessary one. This analysis supports the leveled objectives found in Bloom’s Taxonomy, providing an excellent scaffolding tool for learning. The faculty evaluation of the student’s process of investigation, along with the outcomes of the analysis, provides an excellent assessment of learning in partnership with Generative AI.

Question 2: Can Generative AI be used as a tutoring tool?

This question was of particular interest to CTU leadership. General education faculty created videos for students demonstrating the use, comparatively, of Google Bard and ChatGPT as a reviewer for the grammar, punctuation, and sentence structure of an English essay. Computer science faculty ask students to create and run programming codes through a Generative AI platform to identify errors. The collaboration between the Generative AI platform and a human partner provides insight and ideas, and provides students an opportunity to use their critical thinking and problem-solving skills to demonstrate their knowledge and learning. On a larger scale, CTU is exploring the possibility of implementing a tutoring tool similar to adaptive learning that can be used in all courses that generates tutoring content specific to a student’s need.

Question 3: What about policies addressing Generative AI?

CTU faculty expressed concerns regarding how students can use Generative AI by but also understand and uphold the critical standards of Academic Integrity and the requirement for “original work” by students, as noted in CTU’s academic honesty policy. Faculty have a direct link in the virtual gradebook to submit any Academic Integrity concern for review. With this submission, they create a direct connection with a review team to help evaluate the student submission, the tools used, and previous review requests for the particular student’s work. That collaborative review allows faculty to understand the “big picture” for each student and provide extensive, detailed feedback to help the student re-evaluate either their work or protocols related to Academic Integrity. The plan to redirect and help students learn on the first offense, along with the collaborative uses of Generative AI, will help CTU meet the goal of using Generative AI tools for a learning advantage.

Question 4: How can leadership use Artificial Intelligence tools?

CTU previously launched an AI BOT to address student’s basic questions in the areas of admissions and financial aid. There is currently not a plan to Increase usage of BOT’s to engage with students in the areas of faculty and advising.

However, there is an appetite to explore how AI might assist student-ticketing systems (used to monitor student issues in the classroom and with faculty) and basic work questions, tasks and inquiries in departments including admissions, financial aid, and marketing.

CTU embraces the use of technology to improve student outcomes and student experiences and will continue to explore Generative AI with a focus on the time, resources, and people needed as AI continues to influence education everywhere.


Categories
Policy Practice

What To Do When A Modality of A Learning Experience is Unclear? –  New WCET Paper

WCET members spend countless hours in committee meetings trying to finesse definitions for digital learning modalities. Help is on the way!!! Nicole Johnson’s new WCET-sponsored paper addresses the basic question: “What to do when a modality of a learning experience is unclear?”

Nicole Johnson is the Executive Director of the Canadian Digital Learning Research Association (CDLRA). In the paper, she provides “guidelines for creating multidimensional learning experiences.” It should help when you need to answer questions about how to label a course, whether a new modality definition is needed, or what to do in the grey space in between those, and all the other related inquiries.

No guidelines are perfect. But, this will help.

About Dr. Nicole Johnson

Way back when, I had a small part in creating the CDLRA as Canada has no national counterpart to the U.S. Department of Education to collect data on distance education enrollments or most anything else. The CDLRA surveys have proven valuable in gauging progress and potholes in digital learning across the country and in some specific provinces. Not being a federal agency has also given it the freedom to ask much more interesting questions.

Not long after Nicole assumed her leadership role, someone told her to give me a call. As you can imagine, we joyfully geeked out on the nuances of digital learning data. We especially focused on the emerging mess of digital learning modality definitions. Those were murky and bad before the pandemic, and they are seemingly much worse now. It was a joy to talk to her and it is a joy to work with her.

Check out the CDLRA website to see the results of surveys they have performed on several different instructional technology issues in Canada.

What We Have Done on Definitions So Far

an individual using a laptop computer

The WCET Steering Committee set modality definitions as one of the top priorities for our staff focus over recent years. As a result, we have conducted research and created several resources for WCET Members and the higher education community at large. All of these are available on the WCET website:

  • Conducted a broad WCET-sponsored survey (with CDLRA and Bay View Consulting) in which we learned that there is much less disagreement on the basic definitions than we imagined.
  • With the help of Rob Griffith’s team at The Ohio State University, we held a student focus group that reminded us that students do not care what we call the modality, they just need to know at the time of enrollment:
    • Do students need to be somewhere in-person anytime, anywhere during the course?
    • Do students need to be present for virtual synchronous sessions?
    • What technologies and software will be used?
  • Kathryn Kerensky (State Authorization Network and WCET) conducted a review of federal, state, and accreditation definitions of one term: “distance education.” Spoiler alert: They are all over the map and the U.S. Department of Education has four on their own.
  • Watch for the results of a follow-up survey on institutional modality definitions practices to be released later this year.

What’s In the New Paper?

It’s a quick read, so I don’t want to spoil it and Nicole is more eloquent than I am. She uses some different “cases” to illustrate broad, similar situations in addressing the difficulties and possible solutions when applying modality definitions. Some of the main points are highlighted below.

Modality Usage (and Thus Definitions) Are Now a Continuum

Nicole builds on a chart that she first created for the initial report resulting from the survey on agreement of digital learning definitions. It is now difficult to find courses that make NO USE of digital technologies.

A chart showing the range of technology related courses from offline distance learning, online learning, hybride lenmon

Additionally, faculty have, rightfully, made countless choices on what technologies to use, when to meet in-person, and when to meet synchronously. The forced “emergency remote” migration accelerated this trend. The reason that it is difficult to classify modalities into discrete buckets is that the buckets are not discrete.

Don’t Create New Categories Just to Create New Categories

While the paper doesn’t go too deeply into this issue, it is a important problem. Kathryn Kerensky (State Authorization Network), Nicole, and I have mused over Zoom about some institutional definitions. One institution seems to completely violate the basic tenets of how one definition is used when compared to everywhere else in the world. We have also seen a few papers on another supposed modality, which confused us. If we do not know what they mean (and we asked Van Davis, too), pity the poor student who does not study the nuances of modalities for a living.

Please note that I chose not to implicate the guilty in this post, but you can ask me if you want.

Communicate with Students

We are doubling down on what we learned from the student focus groups. Students need to know what the academic experience will be like. Do they need to be somewhere in person? Do they need to meet at a time appointed virtually? What technology and software are needed and what does it cost?

Enjoy the Paper

Finally, we hope that you enjoy the paper.

We would love to hear your feedback on what worked for you, what did not work for you, and additional ideas for future research or papers on digital learning definitions.

Categories
Practice

How Your College Can Attract More Adult Learners to Enroll

While the benefits of attaining a post-secondary credentials are numerous, it is not a given that learners will have the necessary support and resources to successfully complete said credentials. Community colleges provide more flexibility and support to students in order to help them achieve their education goals, and the additional support is especially important for adult learners. Today we’re happy to welcome Mayla Sanchez from BibliU to discuss the ways community colleges empower learners toward success. Thank you Mayla for this great post!

Enjoy the read,

Lindsey Downs, WCET


Community colleges are in a unique position to empower adult learners to earn a degree and improve their social mobility. Here are some ways to do it.

The role of community colleges in US higher education has never been more important. In addition to workforce development, community colleges help narrow income gaps and provide educational opportunities to demographics that would otherwise not be able to access a degree, including–and especially–adult learners.

Education attainment today

About 28% of adults in America do not possess any post-secondary credential. That’s a staggering 64 million adults whose highest educational attainment is a high school diploma or equivalent. This has serious implications in a lot of areas, such as quality of life and social mobility as employment rate increases with educational attainment. And with it, earning potential.

Data released by the US Bureau of Labor Statistics show that Associate’s Degree holders earn at least $1,000 per month more than those without a post-secondary degree. Throughout their lifetime, they will earn $400,000 more. Additionally, top-earning Associate’s Degree holders cross the six-figure threshold at $105,000 per year while their high school diploma-holder counterparts earn $14,000 less per year.

An increase in earning potential can lead to greater financial stability and improved quality of life for adult learners and their families. Throughout their careers, adult learners may find it easier to qualify for promotions or new job opportunities with a degree. They benefit from skill development, access to specialized training, and to a professional network from their time earning a degree. It also demonstrates their commitment to continuous learning and development, which employers value.

So, what’s stopping adult learners from going to college?

In 2021, the Council for Adult and Experiential Learning (CAEL) surveyed more than 2,000 adult learners and found the following as the most common barriers:

  • Financial factors are central to their enrollment decisions. 78% of non-applicants said they would have been more likely to apply to a program if it had been cheaper. This is a significant factor, especially for adult learners, many of whom are sources of income for their own families.
  • Lack of time is another barrier for adults who have never enrolled in college. Almost three-quarters of community college students work to support their families. It’s hard to fit education into schedules that are already packed with caregiving and working. It also takes time to finish certain programs; the longer the program, the longer they have to wait to see its returns.
  • Difficulty getting the right information. Adult learners rely primarily on online sources for information as they research their enrollment options. But they often feel lost or overwhelmed–or both–after weeks of researching and may abandon the idea of going to college.

Where do community colleges fit in this puzzle?

Community colleges are well-positioned to attract adult learners to enroll in college.

  • Lowest cost. For one, community colleges offer the lowest annual tuition and fees among all sectors of higher education. The American Association of Community Colleges (AACC) reports that the average annual tuition at a community college is 65% lower than in an in-state public four-year institution. The lower tuition fees and shorter time to earn a degree enable them to balance education with their existing responsibilities without incurring excessive debt.
  • Flexibility. Community colleges offer a wide range of class schedules and modalities of instruction–including evening, weekend, online and asynchronous courses. This flexibility accommodates the busy lives of adult learners and enables them to fulfill their responsibilities while also attending school.
  • Open admission policies. Many community colleges have open admission policies, which means they accept more students than a four-year institution would. This inclusivity is encouraging for adult learners who may otherwise be hesitant to invest time and money in applying for college.
  • Practical career training. Community colleges provide a variety of programs that cater to the diverse interests and career goals of adult learners. These programs often focus on practical and job-oriented education, aligning their programs with the needs of local industries. The emphasis on workforce training can help adult learners acquire relevant skills for immediate employment or career advancement.

Empowering adult learners

Here are four key areas where community colleges can focus on to encourage adult learners to enroll in college.

  • Increase affordability. Community colleges can attract adult learners by lowering the cost barriers through scholarships and grants. Essential non-tuition-related costs such as transportation, housing, and textbooks make up 80% of a community college student’s expenses. Therefore, promoting methods for reducing those costs will increase affordability.
  • Increase flexibility: Adult learners are not all on the same schedule as they balance multiple responsibilities. Offer a variety of schedules and modalities that will allow them to progress through their program at their pace. It’s also important to extend support outside the hours of instruction by ensuring that they can access their course materials whenever, and from wherever.
  • Improve communication. Put critical information front and center on your program websites, so they are quick and easy for prospective adult learners to access. Critical information includes tuition and non-tuition costs, time commitment, and other requirements to enroll in and complete the program. Where possible, help them manage their budget by setting predictable costs for both tuition and non-tuition expenses.
  • Partner up. Partners in serving the adult learner community can be an invaluable resource. Often, these are private companies, local businesses, industry associations, and community-based organizations, who share the mission of ensuring equity in education.

One such partner is BibliU. With BibliU’s Universal Learning, a digital-first, day one access for course materials, colleges can increase their competitive advantage in attracting adult learners to enroll by:

  • Reducing the cost of attendance by lowering the cost of textbooks by as much as 50%,
  • Helping adult learners manage their budget with a low, flat fee for their textbooks,
  • Ensuring all students have access to their textbooks, anytime, anywhere,
  • Promoting student success and persistence as demonstrated by Jackson College in Michigan.

Learn more about BibliU Universal Learning.


Categories
Practice

So, What is Culturally Responsive Digital Learning?

This month (September 2023) WCET is focusing on Culturally Responsive Digital Learning. While I, personally, had heard of this pedagogical framework, I didn’t have a lot of experience in this space. And, as a proponent of owning up to our own knowledge deficiencies and taking control of my own development on topics surrounding equity, I took this opportunity not only to introduce the theme to our members and readers, but to make sure that I also have a solid understanding of this topic.

Defining Culturally Responsive Teaching

Scabble tiles spelling out "equity"
Image by WOKANDAPIX from Pixabay

“Culturally responsive teaching incorporates and centers unique student experiences and identities, supporting educators to build learning partnerships that result in increased student engagement and ownership of learning” (National Equity Project, 2023).

Gloria Ladson-Billings, whose research conclusions led to the development of the culturally relevant pedagogy framework, created a way of teaching that “not only addresses student achievement but also helps students to accept and affirm their cultural identity while developing critical perspectives that challenge inequities that schools (and other institutions) perpetuate” (Ladson-Billings, 1995). The term was further defined by Geneva Gay: “when academic knowledge and skills are situated within the lived experiences and frames of reference for students, they are more personally meaningful, have higher interest appeal, and are learned more easily and thoroughly” (2000).

When I was a student, I found my coursework more meaningful and memorable when I was able to connect with the content, either through an active interest or because the topic related to me somehow. I also know that when I taught college classes, students showed more engagement and success when our class content and activities were chosen by them, related to them somehow, honored something in their experience or history, or even just related to current events. I understand that this framework grew out of a need to better support minoritized students, in Ladson-Billings case, she was researching how to better support black students.

As Zaretta Hammond says in her work Culturally Responsive Teaching and the Brain, we have to understand how students process information so we can help them be successful learners who remember what we’ve tried to teach them. By actively engaging with content and in information processing, all students will be more successful. But it is important for teachers and learners to understand that this active information processing is more important for students of color so they can “leverage their home cultures ways of learning and processing information” (Hammond, 2012).

Implementing The Framework

There are four main components for culturally responsive pedagogy:

  1. Affirmation
  2. Validation
  3. Cognition
  4. Processing

These strategies help create a classroom setting that supports culturally responsive pedagogy:

  1. Create a welcoming and affirming environment,
  2. Hold high expectations and maintain rigorous instruction,
  3. Use inclusive curriculum and assessment,
  4. Participate in ongoing professional learning and support (New York State Education Department (NYSED, n.d.).

Instructors and/or course designers can use cultural course content, or materials, resources, and activities that “reflect the diversity of the students in class and the diversity of the contributors in the field of study or discipline” (Singhal & Gulati, 2020). Each student (and therefore, each instructor and staff member too, right?) comes to the classroom with their own behaviors, beliefs, and characteristics, plus their values and their language. This framework helps instructors and students “embrace culture in the classroom” (Singhal & Gulati, 2020).

Making it Digital

Graphic of a person holding a smart phone with images of various technology icons showing off the screen

Technology can help make the classroom and teaching and learning strategies more culturally responsive. Here are some important elements of culturally responsive digital learning:

  • Accessibility

Creating accessible digital materials, websites, and other media not only ensures that students with disabilities can fully participate in a course, and can help ensure that your class and class resources are fully usable by all students, of all ages, of all backgrounds, and of all abilities. Ensuring your content is accessible benefits the entire community.

  • Translation

We have seen some increases in the diversity of college campuses across the U.S. More women are earning degrees and the share of Americans who do complete a bachelor’s degree has increased for all races and ethnicities (Schaeffer, 2022). This means, though not where we need and want it to be, there has been an increase in the diversity of the college classroom. With that comes the need to overcome language barriers.  Technology tools such as Google Translate can help students who do not speak English, or need assistance with some translation, especially when delving into more advanced topics.

  • Multidimensional media opportunities

Through some of my reading, I learned the importance of encouraging family and community engagement throughout the course. Consider the different media options that can help bring family, friends, and community members into the classroom to share their experiences or to highlight and showcase learner experiences and accomplishments. Livestreaming platforms such as YouTube Live, online meeting platforms like Zoom, or audio and video recording can provide meaningful moments of cultural engagement.

Three students work together on a computer.
Image by makhtoom from Pixabay
  • Collaboration

I know, we have all heard student complaints about the dreaded group project (or have voiced such complaints ourselves). But we also know that collaboration between students on classroom activities, assignments, projects, etc., can be great teaching techniques. Collaboration tools not only connect students to students for completing group work, but also connect students to experts around the world to learn about different topics, locales, and cultures.

Learn with Us This Month!

I’ve just scratched the surface of what I know is waiting for me to learn about culturally responsive digital learning. I’m so excited to continue learning this month with my colleagues at WCET and our members. We hope you’ll join us on this journey. Here are some of the upcoming opportunities and events focused on this theme:


Categories
Practice

The Promise and Challenges of AI in Higher Ed

The biggest topic in higher education right now, at least in my opinion, is artificial intelligence. There are various stories in higher education news about what impact AI will have on students, instructors, and the education field at large. This week, we welcome Marc Watkins, Academic Innovation Fellow from the University of Mississippi. Marc joins us to discuss the potential of AI in digital learning and to highlight the amazing work happening at his institution to prepare faculty and students for a future that includes working with AI. I really enjoyed learning about these initiatives and student reflections on AI in higher education.

Enjoy the read,

Lindsey Downs, WCET


Preparing Faculty to work with AI

The University of Mississippi is pioneering new approaches to prepare faculty for emerging technologies, like generative AI, in the classroom. A year ago, in August 2022, several UM faculty within the Department of Writing and Rhetoric began piloting AI-powered assistants in first-year writing courses. Doing so helped us develop the capacity needed to train others in generative AI literacy.

Graphic of a silhouette of a human head, with lights indicating technology around the skull to give the impression of artificial intelligence.

This summer, we hosted an innovative cross-disciplinary AI Institute for Teachers. Participants were generously funded by the Institute of Data Science and nearly two dozen faculty members received stipends to attend an immersive two-day workshop in early June, where they explored how to responsibly integrate generative AI tools in support of student learning.

The goal of this training was to help prepare faculty for the fall semester. Participants returned to their departments with enhanced capacity in AI literacy to teach students AI fundamentals, evaluate AI-generated content, and develop educational applications and policies that explored proactive approaches to generative AI. The AI Institute for Teachers demonstrates the University of Mississippi’s commitment to equipping educators with leading-edge capabilities to enrich their pedagogy and serve the needs of their students in this new technological era.

Feedback from participants was overwhelmingly positive. The hands-on agenda encouraged active experimentation with tools like ChatGPT to imagine curricular integration in disciplines from sciences to humanities. Colleagues appreciated the practical insights tailored to higher ed contexts, noting that this training filled an important gap in institutional preparedness. UM remains committed to spearheading such initiatives to position our educators at the forefront of AI innovation in service of student learning.

With rapid AI advances, we anticipate the need for training educators about generative AI to grow. In July, I developed an online asynchronous training course for all University of Mississippi faculty. Faculty at dozens of other institutions have been granted access to the course through course licenses and scholarships. I’ve released assignments from this course under a CC-BY SA 4.0, so any educator can use and remix them for teaching: Generative AI in Education Assignments.

Our Ethos—Explore, Don’t Panic

Quote: As Stephen Monroe noted, “Our early pilots indicate the panicked presumptions about student adoption/abuse seen in the media were not accurate.” We observed tentative and responsible exploration from our students during these first semesters, leading us to believe that many maturing writers may not always be eager adopters of AI tools.

We developed this capacity through forward-thinking approaches to technology and teaching, with campus-wide leadership and support from UM Provost Noel Wilkin.

Stephen Monroe, the Chair of the Department of Writing and Rhetoric, recognized the impact generative AI technology would have on writing in the spring of 2022 and his approach was to “explore, don’t panic.”

Our department developed an AI Working Group to explore what affordance GPT-3 powered writing assistants, research assistants, and reading assistants, could offer students. Together, we built assignments that asked students to engage generative technologies at different points in their writing process.

We partnered with Dr. Robert Cummings, the Executive Director of the Academic Innovation Group, who helped frame this process. Eventually, we defined our teaching approaches by the acronym DEER:

  • D           Clearly define the stages of the project, and enumerate each stage’s purpose in achieving student learning outcomes;
  • E           For each stage, evaluate a specific AI technology to pair with the learning activity;
  • E           Encourage students to explore that specific AI technology for that stage;
  • R           Provide students with space for reflection.

The Introduction to AI-Powered Assistants video provides an overview of the tools we adopted using the DEER framework. Drawing on student and faculty feedback, including more than 80,000 words of student reflections, allowed us to explore the pedagogical affordances and limitations of generative AI in the writing classroom. As Stephen Monroe noted, “Our early pilots indicate the panicked presumptions about student adoption/abuse seen in the media were not accurate.” We observed tentative and responsible exploration from our students during these first semesters, leading us to believe that many maturing writers may not always be eager adopters of AI tools.

Some Key Takeaways Based on Student Reflections

  • Students liked writing with their own voices and weren’t eager to fully offload their writing process to an algorithm.
  • Ideation, brainstorming, and editing assistance were all widely praised features of the AI tools we used.
  • AI reading assistants, like Explainpaper and SciSpace, were the most popular tools and the ones least likely to be associated with academic dishonesty.
  • Students needed sustained interaction with the technology through structured assignments followed by space to reflect on specific tools in order to explore generative AI assistance.
  • Many students struggled with prompt engineering and needed clear guidance on how to use it effectively, preferring to use AI-powered writing assistants like Wordtune instead of ChatGPT.
  • The majority of students became hesitant and cautious about using generative AI when they were shown how easily the technology could make up or hallucinate material.

It is clear that generative AI technologies will soon be implemented within virtually every web-based interface we interact with daily. This will pose challenges to authenticity and authorship that academia is currently struggling with in nearly every industry. AI detection is proving to be too unreliable, as evidenced by OpenAI shutting down their Text Classifier tool and universities turning off or opting out of Turnitin’s AI detection feature. It’s important to help students understand the pros and cons of working with this, and future, innovations. Instead of surveillance, we should foster a culture of trust with our students by modeling ethical usage of this technology, and such usage will only be possible if faculty and students become AI literate. Training all stakeholders in such literacy is our best pathway forward.

Further Valuable Resources about Generative AI


Categories
Policy

Proposed Federal Rules Affecting Programs Leading to a License & State Authorization Reciprocity Need a Delayed Effective Date

States and Institutions Need More Time

Textbox: In Brief –
The Department’s proposed regulations on state authorization reciprocity and programs leading to licensure were not among the issues identified for the 2021-2022 rulemaking, scant or no research and analysis was presented in the May Notice of Proposed Rulemaking, and the impact on mobile students was not considered.
We fear the Department will implement some form of it anyway.
States and institutions will be unprepared. Students will suffer.
To properly implement these regulations, we urge ED to delay the effective date of those portions of the final regulations until July 1, 2026.

We have had more time to consider the U.S. Department of Education’s proposed regulations on programs leading to professional licensure and state authorization reciprocity. The Department might release final rules that are close to what they proposed. This gave us a bit of déjà vu back to similar rules released in 2010 with a quick timeline. A delay in enforcement was needed then. We recommend a similar extended time will be needed for state agencies, SARA, and institutions to understand and implement new requirements.

This will not be easy. The bottom line: States and institutions will need more time. If not, students will get lost in the confusion.

While we wait to learn of the U.S. Department of Education’s (ED) plan for the Proposed Regulations that they released in May, stakeholders must start to consider what they need to change. If the Department releases the regulations as final by November 1, 2023, they will be eligible to become effective as early as July 1, 2024.

If the November 1 deadline is met, institutions that offer programs leading to a license and/or offer distance education-related activities across state lines will have new additional responsibilities. Institutions would be required to have processes in place to review and address widely varying state laws and regulations, that are overseen by state agencies and state licensing boards that were not sufficiently included in the rulemaking process. Many of those state agencies will not be prepared to quickly implement the new requirements.

We concur with ED that student consumer protection and protecting the integrity of Higher Education Act (HEA) Federal Financial Aid is extremely important. We also agree that improvements in those protections are needed.

Even with our agreement, we have great concern that the rush to address these specific issues, which arose within a subsection of a regulation, does not fully consider the impact on all stakeholders including students, state licensing boards, and state agencies. States will need time to contemplate their role, abilities, and processes to affirm and enforce institutional policies for institutions to properly comply with new Federal regulations.

Our request: If ED chooses to move forward on the regulations within the “Certification Procedures” issue affecting programs leading to a license and reciprocity, we strenuously urge ED to delay the effective date of that portion of final regulations until July 1, 2026.

Quick Review of Federal Rulemaking Process

Executive agencies and departments use the federal rulemaking process governed by the Administrative Procedure Act (APA) (5 U.S.C. Chapter 5) to develop regulations to implement federal law. The process was developed to ensure transparency through public notice and create the opportunity input through public comment. The rulemaking discussed in this post began with the May 26, 2021 Federal Register announcement of the notice of ED’s intention to establish negotiated rulemaking committees. The announcement indicated the 14 issues ED wished to develop and any current regulations it wished to amend. Certification Procedures was a listed issue, but there was no indication that state authorization, reciprocity, or programs leading to a license would be addressed in this rulemaking. Those issues were introduced after the agenda had been set and were barely discussed.

ED held two negotiated rulemaking committees splitting the various issues previously listed. Those committees met in Fall 2021 and Winter 2022. All but five of the issues have already moved from the proposed rule stage to being released as final regulations. The remaining five issues (including the ones that are the subject of this post) were released as proposed rules on May 19, 2023, with the public comment period closing on June 20, 2023. There were 7,583 public comments submitted for which ED must review and respond to prepare the final rules.

To bring specific focus to proposed regulations affecting state authorization, reciprocity, and programs leading to a license that was largely overlooked by the media, SAN and WCET submitted two public comments. The first public comment addressed the regulation subsection affecting programs leading to a license. The second public comment addressed the regulation subsection affecting state authorization and reciprocity.

By “Master Calendar” rules governing such actions, rules released by November 1 of one year become effective on July 1 of the following year. We have not heard that ED plans to do anything but meet that deadline. ED may release final regulations with some changes to the proposed language, but we anticipate that the essence of their recommendations will remain.

Our Recommendation to the U.S. Department of Education

If ED moves forward with these regulations to meet the November 1, 2023, deadline, we request a delay of the effective date until July 1, 2026, for 34 CFR 668.14(b)(32)(ii)(iii) & 34 CFR 668.43(a)(5)(v) and 34 CFR 668.43(c). The last regulation was included for ED to remember to harmonize the individualized notifications with the public notifications.

Because compliance with these regulations is so intrinsically intertwined with state oversight, we believe that it is imperative that states and institutions be given time to accomplish the following process steps and ED collaboration to address compliance requirements:

  • Give time to inform state licensing boards, preferably by ED, and allow them to determine how they will respond to institutions.
  • Give time for State institutional authorizing agencies to determine their requirements and make public their requirements for out-of-state institutions.
  • Give time for institutions to determine their processes after determination by states boards and agencies to address their response to the regulations.
  • Give time for institutions to complete research for professional licensure which is very complicated and time-consuming and cannot be completed in advance of accepting students for programs for FY25.
  • Give time so that students will be afforded with the best information about how the emerging state and federal rules will affect them.
Textbox: States need time to conduct their own adminstrative process for any new state rules resulting from ED's regulations.

Instiitutions need time to understand and implement those rules.

Therefore, we request a delay of the effective date of ED's new rules until July 1, 2026.

Given state administrative rules processes and the need for institutions to conduct additional research and inquiries with states, setting July 1, 2024 as a deadline would be unworkable.

When looking at history, ED may wish to consider that this situation looks very similar to the release of the Program Integrity Regulations that included State Authorization 34 CFR 600.9(a)&(b) that was ultimately delayed until July 1, 2015. You will recall that the original effective date was July 1, 2011, but states did not all have a process to review and appropriately act on complaints concerning the institution including enforcing applicable state laws. Time was needed for states to develop those structures. Similarly, today, states will need to make decisions and implementation strategies to then inform institutions about state consumer protection laws in each state. There will also be the need to engage state licensing boards in conversations to address transparency of state educational prerequisites.

Implications on States and Students Should the NPRM Language Regarding Programs Leading to a License and Affecting Reciprocity Become Final as Written

State Agencies

Federal compliance is inextricably tied to actions of the states, and, for institutions to then implement compliance strategies. Higher education agencies and state licensing boards will be holding the keys as to whether an institution can determine if it “satisfies” state educational prerequisites for a license and “complies” with state consumer protection laws related to closure, recruitment, and misrepresentation.

We hope that ED will review and consider the implications and less than ideal implementation strategies as shared by organizations representing state oversight:

  • SHEEO Report August 2023:A Dream Derailed? College Closures Research and Policy Implications, Report Three- Investigating the Causal Effects of College Closures of Student Protection Authorization Policies on Student Outcomes After College Closure
    • The report includes the following statement on page 6: “The association between student protection authorization policies and enrollment after closure is mixed. Tuition recovery and surety bond policies tend to have no positive correlation with enrollment and are, in fact, associated with low reenrollment rates among students who experienced a closure (treatment students). Student records and teach-out plan policies have a strong positive correlation with reenrollment that lessens over time.”
    • The State Authorization Longitudinal Dataset used to determine the states with consumer protection laws underscores the wide variation of state laws. It should be noted that the dataset does not include whether the state has the authority to enforce its state consumer protection law on out-of-state postsecondary institutions that do not have a physical presence in the state.
  • NASASPS Public Comment to the May 2023 NPRM The National Association of State Administrators and Supervisors of Private Schools (NASASPS) is a national organization of state regulators.
    • NASASPS President, Cathie Maeyart, on behalf of NASASPS indicates that it is “critical” that the proposed regulation that requires institutions to comply with state consumer protection laws related to closure, recruitment, and misrepresentation where the student is located be by self-certification for the following three reasons:
      • State bandwidth for regulators to respond to institutions’ questions and limited authority to provide compliance verification.
      • Wide state variation of regulations state to state and may depend on the type of institution.
      • Any required documentation to affirm compliance by the institution would mean multiple regulatory agencies within a state may need to be consulted.
  • NASDTEC Comment Provided by Jimmy Adams, Executive Director, August 2023. The National Association of State Directors of Teacher Education and Certification (NASDTEC) is a national organization of state departments of education and professional standards boards:

When considering the proposed rule changes by the USDOE, state Departments of Education and Standards Boards or Commissions (Licensing Agencies), foresee numerous requests from Educator Preparation Providers (EPP) asking for specific requirements for teacher licensure in each state. While that may seem like a simple request, states have multiple licenses with varying and different requirements. These differences occur in how each state defines the three components of a license: 1) content; 2) grade range; and 3) student population (exceptional and general).

Licensing Agencies have processes by which they approve EPPs to operate within their individual states, ensuring that educator licensing requirements are met. These approvals require multiple documents to be submitted by the EPP, reviewed by Licensing Agency staff, and ultimately approved by a Board. The amount of work required to ensure an EPP meets the licensing requirements and continues to meet them, is extensive. If these proposed changes are put into place that work has the potential of exponential growth. Educator Preparation Providers (EPP) will want to know if their multiple programs meet academic and other requirements for their students who are ultimately licensed in another state, essentially requiring approval of all the EPPs’ teaching programs. Licensing agencies have neither the staff nor the budget to meet the amount of work these proposed changes will require.

text box: If the proposed changes are intended to identify poor actors in the realm of licensure preparation, then the proposed changes seem to be punishing the large number of institutions who do the right thing every year without mishap and licensing boards/commissions who should have input on these changes.

This will also be an added burden on the EPP, who would have to maintain accurate and annually updated licensing information for all students who plan to teach in another state. This will be a strain on each EPPs staffing and budget. One EPP pointed out that the primary duties of these staff potentially “include: 1) institutional recommendation/verification letter responsibilities; 2) policy investigations of all 50 states plus territories; 3) publishing and updating this information annually; 4) communicating with all 50 states plus territories to ensure published information accuracy; 5) communicating with students, internal policymakers, national associations; and 6) overseeing a data systems to organize this information.” That may sound like an exacerbated interpretation of responsibilities to a person outside of licensing, but I am not sure it is that far from the truth.

Most states already have policies in place that allow a person trained in another state to obtain a license by qualifying or receiving a license in the state in which they were prepared.

If the proposed changes are intended to identify poor actors in the realm of licensure preparation, then the proposed changes seem to be punishing the large number of institutions who do the right thing every year without mishap and licensing boards/commissions who should have input on these changes.

The state higher education agencies will have to consider the following:

  1. Do state higher education agencies have the capacity to enforce and affirm compliance with designated laws related to closure and recruitment? (States can already enforce state laws on misrepresentation – SARA Policy Section 4.4(e)).
    • What do state higher education agencies do without capacity to address all out-of-state institutions serving students by distance education in their state? (ex. Texas currently oversees 135 SARA participating institutions. According to NC-SARA data about interstate enrollments, the new proposed regulations could increase state oversight to 1,493 out-of-state institutions that serve students located in Texas).
    • What do institutions do about states without capacity?
  2. How will the state higher education agencies determine applicable laws related to closure and recruitment?
  3. How will states observe the federal regulation when the state expressly limits the authority of oversight of out-of-state institutions to certain sectors or bases authority on the institution maintaining a physical presence?
  4. How will states acknowledge the federal regulation if they choose not to enforce state laws on institutions that participate in reciprocity?
  5. Does the state need to make changes to its state laws and regulations and how much time will that process take?

The state licensing boards will have to consider the following:

  1. Does the state licensing board have an interest in affirming satisfaction with education prerequisites? What if they don’t wish to?
  2. Do state licensing boards have the capacity to affirm satisfaction with educational prerequisites?
    • What do state licensing boards do if they lack capacity?
    • What do institutions do about states without capacity?

Students

We are concerned that the guardrails ED intends to create to protect students are ultimately going to have unintended consequences of creating additional barriers for students.

  1. These barriers will inhibit students’ ability to choose institutions and programs thus putting limitations on career options.
  2. Students could find themselves unable to afford to enroll in a professional licensure program because the institution does not meet requirements where the student is located. This is especially frustrating when a student plans to move to a state after completion of the program to seek employment based upon workforce needs or lives near a state line and will cross state lines to work in another state.
  3. Ultimately, we are concerned that the students will be caught up in the confusion as states and institutions figure out how to implement and comply with this regulation.

Conclusion and Recommendation for Institutions

WCET and SAN hope that ED will give serious consideration to the points that we have raised. We especially hope that ED recognizes the important interactive relationship with states that these regulations hold.

For further context to understand the specifics of these issues we offer the following resources:

Meanwhile, we urge institutions not to be complacent. Consider planning now for changes that include the following and are ultimately best practices regardless of the ultimate decision of ED:

  • Clearly document your institutional process for determination of student location as directed by currently effective regulation 34 CFR 600.9(c)(2) that became effective July 1, 2020.
  • Create good tracking mechanisms to know where your out-of-state students are located whether participating in an online course or experiential learning (internships & clinicals).
  • Continue to pursue clarifications of state educational prerequisites where your students are located.
  • Communicate clearly with state licensing boards in your home states to share the need for access to well-defined and specified educational requirements in the state which if done by all institutions will ultimately encourage state licensing boards nationwide to be more transparent, thus benefiting everyone nationally.

You can also review all documentation on the rulemaking process via the SAN website. From the home page of the SAN website, navigate under Quick Links to access links to pages dedicated to rulemaking information.

Continue to look to SAN and WCET as we follow this and other ED activities and announcements. We will continue to update you as things develop!


Categories
Practice

Safeguarding Data Privacy for Students and Staff

August is Data Protection, Privacy, and Student Agency month here at WCET. This month we’ve set our focus for events and resources on the importance of cybersecurity and data protection. Today’s post, from WCET’s own Rosa Calabrese, zeros in on the importance of ensuring data security and privacy for our students and staff.

Continuing this theme, we’ll be releasing (exclusively to our members) a WCET Closer Look on these topics plus hosting a WCET member-only Closer Conversation later this month (Protecting Privacy in a Digital World, August 25,12:00 PM – 1:00 PM MT).

Enjoy the read,

Lindsey Downs, WCET


Privacy and Information Security

I recently graduated from a master’s program where I completed an MS in Technology, Cybersecurity, and Policy. To share elements of what I learned during my program, I authored several other posts for Frontiers about important aspects of cybersecurity, such as bias in technology, information security, passwords, and phishing.

In this post, I want to dig into the topic of data privacy, which is both closely linked to, and distinctly separate from, many other topics around information security. Data that is breached (an all too common event in higher education today) because it is not adequately secured can pose major privacy issues for people whose data winds up on the dark web. However, privacy risks also emerge when excessive data is collected, when individual data is identifiable, and when data is shared between multiple parties without the permission of the individual (even if the data is not breached).

Privacy is a concept that exists outside of technology. It was discussed well before the invention of modern tech and the practice of big data collection. For example, before data collection became what it is today, privacy existed in the sense that citizens could keep their lives private from the government. However, there were perhaps fewer risks in those days, and fewer ways that privacy could be violated.

Today, privacy is more important and less accessible than ever before because of the way that our lives are tracked online through the websites we use, the information we voluntarily put online, our geolocations, and all the other data that is collected, traded, and sold between multiple corporate and government entities. 

Privacy and Why it Matters

Have you even been told (or even said yourself) that we shouldn’t mind that our information is tracked or huge amounts of data are collected because we have nothing to hide? Why does it matter if your information is tracked and collected?

Three security cameras on a building.
Photo by Arno Senoner on Unsplash

This argument seems to be losing some popularity as the risks become clearer and the enormous number of threat actors becomes apparent. However, apathy resulting from helplessness in the face of large data collection and few privacy regulations is still quite common.

Essentially, with an infinite number of potential actors and an ever-changing view of what information is meaningful and why it matters, the need for privacy is only becoming more important. Government regulations and policing practices create privacy risks that may disproportionately impact some groups of people, such as immigrants, individuals seeking transgender healthcare, or people accessing abortions. While some privacy risks are greater outside of higher education, many of the risks of privacy are equally important within this industry and pose a significant threat to students. Higher education officials must do their best to support and protect students from experiencing harm due to a failure to protect privacy now or in the future. It is our responsibility to protect our students’ data, but also to teach students how to care for their own privacy.

Institutions are obligated by law to meet certain data protection standards, such as those related to FERPA and HIPAA. As relevant, institutions sometimes need to meet locational privacy policies as well, such as GDPR (when students in the EU are being served).

However, beyond the requirements stated in law, there is much more that institutions can do to support their students, promote privacy for all, and ultimately foster institutional trust.

Data Points, Data Processing

To understand data privacy, it is first important to understand the types of data that can be collected, as some data is more sensitive than others.

Personally identifiable information, or PII, is information that can identify individuals. PII includes social security numbers, of course, but also includes things like names, addresses, birth dates, email addresses, phone numbers, and biometric data. Data that does not need to be connected specifically to an individual can be collected without PII and be anonymized to maintain privacy.

Another important element of privacy relates to how data is processed. Multiple data sources about an individual are often tied together or compiled in a way that creates a large treasure trove of data on each person. On the web, this can be done through cookie trackers, for example, which tie together an individual’s browsing data from many places. Institutions can also compile many data sources on an individual, especially if students are required to use many different systems that are all tied to them through their institutional email or student ID.

When PII gets into the mix of compiled data then even less sensitive and specific data points can become identifiable to an individual as well. As a result, data collection becomes riskier for the individual as more pieces of data about them are collected and compiled together. Even if one data point, like say an assignment grade or a username on an elearning platform, is not personally identifiable, it could become personally identifiable if it is tied to other data that includes PII.

A final important topic around data collection is the question of when and how data is destroyed (“Destroyed” being the more adequate term that “deleted” as data that is deleted can sometimes be recovered, so sensitive data must be completely destroyed to absolutely prevent future access). There are several important questions to ask about institutional policies around the destruction of data, such as:

  • How long after a student has graduated, transferred, or left an institution is their data destroyed?
  • What data continues to be kept after a student has left and for what purpose?
  • Could the data that remains after a student has left be anonymized? (This might be useful if past student data were used to inform algorithms or institutional statistics but don’t need to be associated with an individual anymore).
  • What are your institutional or organizations policies and procedures for record retention?

Privacy Threats

"PRIVATE" sign on a door.
Photo by Dayne Topkin on Unsplash

Students, staff, and faculty alike can face many harms when their data is not kept adequately private. While institutional data often revolves around students, employees such as faculty and staff can be vulnerable to data collection and as a result, privacy threats, that come from their employment data. One of the most obvious risks to all people at an institution is that their data (including PII) could be breached in a cyberattack, and that their personal information subsequently arrives on the dark web, creating continuous potential problems related to identity theft. However, private corporations, government entities, law enforcement, other higher education institutions, and potential employers can all play roles in creating harm for students and employees whose data is not protected.

Harms against the individual that emerge from loss of privacy can include loss of employment opportunities, loss of money, or legal repercussions. Alternatively, individuals may experience poor mental health or compromised relationships. The harms can be mild or severe; and they can potentially follow individuals for years. Once privacy is lost, there is little that can be done to repair the damage that has been done.

Privacy First

There are a lot of data already being collected and stored by institutions. In some ways, it can feel like the situation is already out of control. However, there are many things that institutions can and should be doing to repair their management of data privacy if it is not already under control:

  • Audit current systems of data collection, processing, and retention to figure out how data is being handled presently.
  • Create guidelines for handling data privacy in the future, including how to manage data that has already been collected that prioritizes a privacy-first model. No need to start from scratch; you can draw inspiration from preexisting privacy frameworks such as the one created by NIST.
  • Provide information for students, faculty, and staff to read through and consent to about how data is collected, processed, and destroyed. (For example, individuals could be required to either opt-in (ideal) or opt-out of data collection after they have read about how data is handled.)
  • Create guides for the evaluation and adoption of third-party systems that will handle student data to ensure that external tools preserve data privacy.
  • Plan to audit data practices again in the future, check back with individuals, and modify policies as needed. Privacy is constantly a work in progress!
  • If funds are available, hire individuals to privacy related positions to guide privacy efforts.

Ultimately, individuals need to have more authority over their own data, how it is used, and when it is destroyed. Protecting this right can be advantageous to institutions of higher education as well because doing so will promote trust and create ongoing secure relationships between current and former individuals with the institutions themselves.