Post-secondary education serves as a cornerstone for personal development and plays a large role in shaping an individual’s career path. Such an education provides the opportunity to increase a student’s understanding of their chosen field and to develop important skills for their daily personal and work life. Experiential and practical experiences associated with a course or program helps keep students engaged, connects learning objectives to their real-world.
I’m excited today to welcome guest authors Meg Barnes and Sital Sigh from the University of Mississippi to discuss an opportunity their students have “preview the real world of work” in a virtual way.
Enjoy the read,
Lindsey Downs, WCET
How can educators prepare students for meaningful and rigorous work?
As educators, we encourage students to engage in a spectrum of experiences to test drive real-life roles and build resilient and transferable skills that are needed in the workplace. These experiences can include:
experiential education,
work-integrated learning,
collaborative problem-solving,
critical thinking in the classroom, and,
relevant learning materials with real-world applications and practical problems.
This case study offers an innovative educational method and a glimpse into digital learning by students previewing the world of work.
Partnering for Real World Experience: University of Mississippi + Forage
Forage is a technology startup that connects students with Fortune 500 companies and other organizations. The connection between students and those companies is a completely virtual experience. Students have the chance to see behind the curtain of the best companies around the world through free and self-paced virtual job simulations. With over 125+ employers and 290+ job simulations, Forage helps highlight the growing global desire to embrace flexible work arrangements and a shift in how in-field and relevant experiences are offered, and how companies attract, train, and hire the best talent.
Benefits
With the profound shifts in how employers and employees approach working environments, educators must continually consider ways to prepare college students in more meaningful and practical ways.
Employers seek resilient hires
Research conducted by the National Association of Colleges and Employers (NACE) found that college students hoping to attract the attention of employers should emphasize problem-solving skills, followed closely by teamwork (Gray & Koncz, 2023).
Reprinted from Job Outlook 2023 with the permission of the National Association of Colleges and Employers, copyright holder.
“Increasingly, employers are more concerned about competencies and skills. So, candidates who can demonstrate experience, knowledge, and ability through their resume and applications will have the competitive edge.”
– NACE President & Chief Executive Officer Shawn VanDerziel
Real-world relevance boosts student confidence
Research shows that relevant education and job experiences influence students’ perceptions of their competence and potential. In particular, relevant or in-field work experience may enhance or bolster a student’s perceptions of self-confidence (Knouse, 1994).
Work experiences spur deeper, more engaged student learning
After students gain work experience, critical reflection is often optimized. Growing research promotes the approach that students need to develop, articulate, and showcase their skills, competencies, and capabilities (Jackson & Edgar, 2019).
The optimum engagement point is after students have had some work experiences, providing students with specific experiences to share, compare, reconcile, and critically consider how their educational goals help them achieve knowledge and skills for work. These educational experiences after a work experience promote career readiness and self-direction (Billett, 2015).
Instead of just being taught, students receive post-experience feedback and guidance from educators as an opportunity to personalize and invest in their education and its application in the real world. This approach also enhances employability upon graduation (Billett et al., 2018).
After reviewing the research, we asked those who are the most impacted by this topic on a daily basis – our students. Here’s what they said:
“After completing the Forage experience, I have identified several skills that need development to prepare me f“The Forage virtual experience helped me understand that I thrive in a fast-paced, challenging environment.”or success in the workforce during my time at UM. I aim to enhance my analytical skills, ensuring I can assess the environmental and social implications of business decisions. “I recognize the importance of effective communication in conveying the value of sustainable practices to various stakeholders. I also intend to actively seek opportunities for hands-on experiences, such as internships or research projects, where I can apply theoretical knowledge to real-world sustainability challenges.”
– Seth Walz-Jones, Student at the University of Mississippi, Second Year Student in Business 101 course, December 2023
The intersection of campus and industry
Gaining momentum in test-driving careers and empowering students to explore their career trajectories, university partners have collaborated with educators to promote “preskilling” (Monfared, 2022, para 7). Industries and organizations may develop the opportunities and intersect with campuses in offering workplace-specific training for college students relevant to a specific field or industry. These collaborative partnerships focus on building and strengthening learning through:
On-campus employment,
Internships,
Micro-internships,
Practicums,
Preceptorships,
Project-based studies,
Simulations.
As an emerging innovative method, online projects and digital platforms have grown as a trend, with students and industries communicating online while geographically dispersed (Kay et al., 2019)
Work-integrated learning through simulations is “focused on the student completing authentic, relevant actual tasks for an organization through a remote connection to the workplace/community” (Wood et al., 2020, p. 333).
“The Forage virtual experience helped me understand that I thrive in a fast-paced, challenging environment.”
– Matison Kerby, student at the University of Mississippi, Third Year Student in Business 101 course, December 2023
Insights from the University of Mississippi
The Forage adds to the toolbox of educational opportunities.
Forage embraces work-integrated learning with virtual and simulated experiences developed by employers and delivered to students through educational institutions (Cerimagic et al., 2022). These virtual experiences are designed to prepare students for actual work assignments and showcase the students’ capabilities and relevant industry skills. The modules can be delivered and packaged within a curriculum, as a supplemental activity for professional development, or as a micro-opportunity.
“As an instructor in business communication and a professional at the Mississippi Small Business Development Center, I’ve found The Forage virtual experience to be a transformative educational tool. It bridges the gap between theoretical learning and real-world application, enriching students’ understanding of the business world. This platform not only complements academic learning but also equips students with essential problem-solving skills and critical thinking skills needed in today’s dynamic business environment.”
– Derek Stephens, Assistant State Director, Mississippi SBDC & Adjunct Instructor of Management
From Forage’s virtual simulated experiences, students build confidence, bolster career readiness, and strengthen practical skills:
75% of students surveyed at the University of Mississippi reported being more confident in their understanding of the day-to-day realities of work,
65% of students are more likely to apply for a role at that company, and,
78% reported gaining practical skills through the experience.
These Forage virtual simulations and data reflect an encouraging inclination for students after completing relevant projects. The post-reflective movements of self-direction and career readiness in Billett’s research surfaced in the Forage simulations with post-experience reflections. Incorporating The Forage virtual simulations into student learning is an example of promising digital learning that can augment a student’s skillset, self-confidence, and career planning.
Image creation: Sigh, Bellassai, & Barnes
References
Billett, S. (2015). Integrating practice-based experiences with higher education. Professional and Practice-Based Learning, 13, 1-26. https://doi.org/10.1007/978-94-017-7230-3_1
Billett, S., Cain, M., & Le, A. H. (2018). Augmenting higher education students’ work experiences: Preferred purposes and processes. Studies in Higher Education (Dorchester-on-Thames), 43(7), 1279-1294. https://doi.org/10.1080/03075079.2016.1250073
Cerimagic, S., Arthars, N., Eden, D., and Grunfeld, J. (2022). Bridging education to employment through virtual experience placement. Ascilite Publications. E22215. https://doi.org/10.17442/apubs.2022.215
Jackson, D. A., & Edgar, S. (2019). Encouraging students to draw on work experiences when articulating achievements and capabilities to enhance employability. Australian Journal of Career Development, 28(1), 39-50. https://doi-org.umiss.idm.oclc.org/10.1177/1038416218790571
Kay, J., Ferns, S., Russell, L., Smith, J., & Winchester-Seeto, T. (2019). The Emerging Future: Innovative Models of Work-Integrated Learning. International Journal of Work-Integrated Learning, 20(4), 401-413.
Knouse, S. B. (1994). Impressions on the resume: The effects of applicant education, experience, and impression management. Journal of Business and Psychology, 9(1), 33-45.
Monfared, Y. (2022, February 8). How you can solve the skills gap. The Forage Talent Resource Center. https://employers.theforage.com/post/how-you-can-solve-the-skills-gap
Wood, Y. I., Zegwaard, K. E., & Fox-Turnbull. W. (2020). Conventional, remote, virtual and simulated work-integrated learning: A meta-analysis of existing practice. International Journal of Work-Integrated Learning, 21(4), 331-354.
While I feel that the pandemic brought the impact of mental and physical health on daily life more into focus, it’s still hard for us to balance wellness with work. I love my work, but this is a daily struggle for me. Throw some health challenges into the mix, and suddenly that juggling act gets way trickier. For those dealing with series health issues or some form of a disability, keeping up with job responsibilities plus family and other life responsibilities, is just a lot. I’m so thankful for the support my team has offered me during times of challenge, and appreciate hearing from our guest author today about some ideas for supporting others in the workplace. Thank you Jenny for sharing this insight and your lessons learned from supporting institutional staff.
Enjoy the read,
Lindsey Downs, WCET
Scenes from a Faculty Office
As I was sitting in her office discussing plans to sub for her upcoming classes, my friend and colleague paused a moment and said, “Hold on, I forgot I need to call my nurse back. She called while I was in my last class.”
Rachel (pseudonym) was having yet another surgery, and I was covering all her classes for her while she was in the early stages of recovery. Rachel was a full-time tenured professor, and I was a young part-time instructor, so I had not only the time but frankly also the need for some extra income, and I enjoyed subbing for my colleagues. As the “baby” of the department, I was by far the youngest and least experienced of all my colleagues, so subbing was a great resource to introduce me to fellow faculty and gain exposure to a wide range of teaching practices and content. Unfortunately, the need for a sub often meant that an instructor was sick, injured, or recovering from a health event.
Rachel got off the phone with the nurse and explained some more of the details of her upcoming surgery to me. When I had met her a few years ago, she had been recovering from a different kind of surgery: I vividly remember her trying to navigate corridors and elevators with her foot in a boot on one of those motorized vehicles that keep your leg extended out behind you like a superhero in a permanent dash in a comic book square.
As Rachel continued, she paused again and said she needed to call and cancel her physical therapy appointment. Then she needed to call and schedule a hydrotherapy appointment for her chronic pain. Then she called her therapist to make an appointment because, frankly, this was a lot. Still, Rachel acted like this was just another day in her life. Because that’s exactly what it was.
Disability Unmasked
Rachel is far from the only woman with disabilities teaching at a college or university. Women suffer from more disabilities than men in a variety of ways. According to the National Institutes of Health, women surpass men for invisible disabilities of all kinds: “Many common chronic conditions are not female-specific but occur at substantially higher rates in women compared to men. Women constitute nearly 80% of the population affected by autoimmune disease and bear a disproportionately high morbidity associated with this spectrum of conditions. Other disorders, such as depression, are thought to be disproportionately high among women for a combination of innate factors (e.g., fluctuations in hormones), as well as social factors (e.g., high rates of exposure to intimate partner violence).”
As if hormones, domestic violence, autoimmune, and chronic issues were not enough to contend with as invisible barriers, neurodivergent women also present differently than men. This means that while some facets of invisibility are unintentional, some women engage in “masking” or the “unconscious or conscious effort to hide and cover one’s own self from the world, as an attempt to accommodate others and coexist” (Nurenberg 8). Thus, women often must navigate not only their own disabilities but also decisions about their visibility within the workplace.
So why are women faculty with disabilities of concern? According to Lauren Lindstrom, Assistant Professor and Senior Research Associate at the University of Oregon, Eugene, “Low expectations for individuals with disabilities, lack of family support, and disability discrimination may further limit employment options for women with disabilities preparing to either enter the workforce or make a career change. Thus the ‘choice’ of a job is by default a selection from a narrow range of options.”
One of the most viable options for women has been to teach at the college level. Tenured faculty not only benefited from job security and health benefits but also limited time requiring them to go into work: teach classes, hold office hours, attend meetings, and you’re set. A tenured teaching position is by no means a part-time job, but its requirements to be on campus might be very part-time, or even nonexistent given the advent of online teaching.
Lessons Learned and Key Takeaways
Five years ago, I moved from teaching into administration, specifically in faculty development. In supporting women faculty with disabilities during this time (including during a pandemic), their unique needs became clear to me in ways I had not considered before. Here are some suggestions for how you can support your female faculty working with disabilities at your institution.
Choice: As stated earlier, choice is an important factor in a career, but once in a career, chosen profession, or position, choice remains integral. I have seen many administrators try to steer female faculty with disabilities into online teaching positions. Yes, teaching online only is a viable option for some, but for others, it is not their ideal. Some women faculty need the community and camaraderie of interacting with their students and colleagues in person. That engagement might be the highlight of their day. Having intentional conversations with your faculty about their options, their choices, and their needs is essential.
Ongoing Support: After a major health event such as cancer, an automobile accident, or a high-risk pregnancy, it is unrealistic to expect things to go “back to normal.” People change. Physical trauma can leave permanent disabilities, and trauma, anxiety, and post-partum depression are all invisible disabilities affecting women in higher percentages than men. After one faculty friend and colleague of mine was in the hospital for life-threatening gynecological complications, she had to return to the classroom to teach multiple students who worked at the local hospital and had been part of her care team. Catching up on teaching and grading duties, navigating new permanent disabilities, and dealing with a source of environmental anxiety took an extreme toll on her. Ongoing support in the form of co-teachers, graduate assistants, counseling, routine check-ins, and flexibility in workload and workplace can go a long way to retaining valued faculty.
When supporting your female faculty with disabilities, remember that while you should do everything that you can to reasonably accommodate them and retain them at your institution, this might not always be possible. I have seen fantastic female faculty leave tenured positions because they could not access adequate healthcare for their disabilities near their institutions, forcing them to relocate to areas where there were more opportunities for accessible healthcare to meet their specific needs. A professor’s health situation might make any kind of employment unreasonable or untenable at any moment. However, supporting female faculty with disabilities in our institutions not only helps them achieve their personal and professional goals but also aids us in embracing diversity in all forms and retaining a stronger workforce.
Here we go again! Significant changes to postsecondary distance education operations emerged from the U.S. Department of Education’s (Department) Winter 2024 negotiated rulemaking discussion. The proposed changes could be huge and we suggest you read or scroll through this post to see what might affect you and your students. For example, state authorization reciprocity could be greatly limited, distance education programs could be required to take attendance in every course, and all “inclusive access” programs from publishers could be eliminated.
In early January, the Department convened a set of “negotiators” to consider regulatory changes as authorized by Title IV of the Higher Education Act of 1965, as amended. Negotiated rulemaking is a multi-step process that the Department may use to develop regulations to implement federal law. For our purposes, the Department is developing regulations to address process and compliance for institutions to participate in Title IV HEA Programs.
Today, we will share an overview of the Department’s rulemaking process and provide analysis of the issues in this new rulemaking that affect institutions serving students through digital technologies and interstate distance education. We will also share next steps for you to participate in this process and how to follow the progress of this rulemaking.
Below, we’ve listed the six issue areas for this rulemaking plus the sub-issues being discussed, which we are watching closely. We have also added links to “Issue Papers,” including red-lined proposed regulatory changes that emerged during week one of the three week negotiated rulemaking process. The issue papers were publicly released by the Department to frame the discussions by the negotiators. Those who have followed rulemaking over the last ten or so years may find a bit of déjà vu in some of these proposals.
Public representation on agency decision-making bodies
Substantive Changes and other reporting requirements
Recognition of State Agencies for the Approval of Nursing Programs
Issue # 6 – Federal TRIO Programs – being reviewed first by the Department designated subcommittee.
You may be asking, weren’t several final regulations from a rulemaking just released by the Department? If so, yes, you are correct, the Department released important final regulations on such issues as Financial Value Transparency and Gainful Employment and Certification Procedures that include regulations affecting the institution’s ability to serve students in programs leading to a license or certification. Those regulations, plus more, will be effective July 1, 2024.
Rulemaking Process Overview
The Department must follow the many steps in the federal rulemaking process directed by the Administrative Procedures Act (APA). The process takes considerable time. The soonest a rule from this rulemaking could be effective would be July 1, 2025. To be effective in 2025, the Department must complete several steps. Some of these steps have already been completed.
Completed:
Federal Register announcement of intent to hold the rulemaking on designated issues and opportunity for public comment.
Nominations to create a rulemaking committee for which the Department chooses the negotiators to represent constituencies affected by designated issues.
To be completed:
Meeting of the rulemaking committee over several months to negotiate language to develop or modify regulations on the designated issues.
Consensus-seeking meeting among the negotiators. Consensus is defined as no dissent from any committee members on the regulatory language. If there is no consensus, the Department is free to write the regulatory language.
Proposed regulations must be released either from consensus language or written by the Department and subject to public comment.
The Department must review and respond to public comments to inform them of the development of final regulations.
The Department must release final regulations by November 1, for the regulations to be effective the following July 1.
Failure to meet the November 1 deadline will cause the effective date of the regulations to be delayed until the next year to align with the next financial aid year.
The rulemaking committee will complete its meetings in March 2024. The Department has expressed its desire to release final language prior to November 1, 2024, in order for the new regulations to be effective July 1, 2025.
Issue Analysis
Issue #1 – Cash Management
Proposal: Eliminate Including Books and Supplies in Tuition and Fees.
Current regulations allow institutions to include (under certain conditions) the cost of books and/or supplies in tuition and fees. Career institutions use it to ensure everyone has the same tools. Publishers created “inclusive” and “equitable” access programs whereby the price of the textbook and resources are reduced for every student and it is ensured that every student has access to the textbook.
The Department allows for such contracts if the student is given a way to opt-out. Student, consumer, and OER groups have objected to the difficulty for students to remove themselves from these programs.
The Department is concerned that institutions have not been transparent about how a student can opt out so that they can assess if less expensive options are available elsewhere.
What Is Proposed by the Department?
The Department proposes to eliminate the provision allowing institutions to include the cost of books and supplies as part of tuition and fees in most cases. The practice would still be allowed if an institution could demonstrate a “compelling health or safety reason, or if the institution is the only option for students to access the books or supplies.”
Our Analysis
Inclusive access has grown as the publishers have found it to be an attractive solution that lowers textbook costs and increases their revenues. We agree there have been abuses, but let’s address them. If the Department is worried about institutions not properly notifying students (which are required by regulation), could this be resolved by addressing those infractions or strengthening those provisions?
Some institutions charge a student fee (a fraction of the price of one textbook) to cover the cost of creating, supporting, and maintaining low-cost textbooks. Kansas State University’s Open/Alternative Textbook Initiative is an example. We worry the proposed language could unintentionally harm these beneficial programs. The Department should ensure that fees to support such programs are acceptable.
Finally, if adopted, institutions will need a substantial amount of time to implement this proposal. They will need to consider new textbook alternatives in every course, adjust business processes, and address contractual obligations.
Issue #2 – State Authorization
Proposal A: Complaint Process for a State Authorization Reciprocity Agreement
The Department expressed concern that states are not informed of complaints subject to a reciprocity agreement from students located in their state about institutions located in another state.
The Department indicates that without this information the state where a student is located cannot monitor if their students are protected by the reciprocity agreement.
Additionally, they maintain that information must be reported publicly and at least annually about the number and type of complaints that occur from participating institutions in member states.
This reporting is expressed by the Department as necessary for the state to receive information that could affect the state’s decision about renewing its state’s membership in the reciprocity agreement.
What is Proposed by the Department?
The Department proposes that a state authorization reciprocity agreement must include a process for communicating information received on student complaints subject to the reciprocity agreement to the State where the student is located at the time of initial enrollment. Additionally, the reciprocity agreement must require that complaints including the number and type of complaints received by States subject to the reciprocity agreement must be made public at least annually.
Our Analysis
It is important to first note that the Department is developing regulations to address reciprocity agreements for state authorization more broadly, should more agreements be available in the future. The Department is not only addressing SARA, which is the only currently active reciprocity agreement for state authorization.
That being said, the proposal by the Department appears to affirm processes already in place by SARA. The exceptions include, first, reporting of “type” of complaint which we are aware is being currently developed by SARA. Second, the Department proposed language about informing the state where the student is “located at the time of initial enrollment.” We believe that this language is very limiting because it is possible that a student may no longer be located in the state of initial enrollment.
The responsibility of the determination of location in the event of a change reported by the student is already required in federal regulation. Finally, because reciprocity is a state-to-state agreement, we question the ability of the Department to dictate the terms of such an agreement.
Proposal B: Governance for a state authorization reciprocity agreement
What Is the Problem Identified by the Department?
The Department expressed that the governing board for a state authorization reciprocity agreement that includes members who are not state representatives could stifle the states from the ability to improve consumer protections for participating institutions.
What is Proposed by the Department?
The initial proposed language by the Department indicated that the governing board must consist of “solely” of state representatives. However, while the preceding sentence indicated “solely” representatives of states, the Department proposed a lengthy list of who may not be a public member of the governing board, including current or former employees of institutions, trade associations/member organizations, accrediting agencies, or the Department.
The Department expressed the need for consideration of a minimum number or percentage of representatives from non-state representatives to the governing board.
Our Analysis
We concur with the idea that the vast majority of members of a board governing reciprocity should be state representatives tasked with administering the implementation of a state-to-state agreement. However, we disagree that a federal agency has the authority to regulate the composition of a board of an organization for which states are members.
Additionally, we maintain that the proposed language about groups that may not serve is unnecessarily prescriptive. The long list of barred groups includes stakeholders who are appropriate for the development of sound policy. Further, the language indicates “former employee” without a time frame or context. Implementation of this language would allow very few members of the public with any expertise in higher education, distance education, or institutional oversight to serve as members to the board.
Proposal C: State exemptions from state authorization based upon accreditation or being in operation for at least 20 years.
What Is the Problem Identified by the Department?
The Department is questioning whether a state’s determination of state authorization of an institution where the institution is located is adequate for purposes of Title IV if the state minimally considers accreditation as sufficient or waives institutional approval for institutions in operation for more than 20 years.
The Department considers that state exemptions are weakening the program integrity triad, making students and taxpayers vulnerable.
What is Proposed by the Department?
The Department has not offered proposed language, yet, but is interested in developing language based upon the review and discussion focused on three questions:
How can the Department ensure that state authorization is serving its intended purpose in the regulatory triad?
In what instances are exemptions from the state approval requirement appropriate or warranted? Is accreditation and/or length of time in operation sufficient for an exemption from the state approval requirement?
What factors should the Department consider as necessary for state authorization?
Our Analysis
States have various structures and reasoning for the oversight of activities in their state. The Department and groups of states may want to consider collaborating to address any suggested changes. We recommend the Department start by reaching out to NASASPS (a national organization of state regulators). Determinations of state oversight requirements are an issue of state authority.
The Department should consider that mandating new state requirements in federal regulation for state authorization of institutions where the institutions are located would be time-consuming for states to undertake and could require state legislation to make changes to existing state structure. Note the federal regulation released as final in October 2010 that required a state to have a process to review and appropriately act on complaints was delayed by the Department in its enforcement date for 4 ½ years finally becoming enforceable July 1, 2015, to allow time for states to develop their complaint processes.
Negotiator Submitted Proposal: Modification of the Definition of State Authorization Reciprocity Agreement
What is the Problem Identified by the Negotiator?
In week 1, a negotiator submitted what the Department referred to as the Fast Proposal. This proposal identifies the perceived problem that the federal definition of a state authorization reciprocity agreement prevents student consumer protection from the state where the student is located, as that state is a member to the reciprocity agreement and is subject to the policies of the agreement. The problem expressed is that although the state where the student is located may enforce laws of general applicability such as those related to fraud, misrepresentation, and criminal activity, the state cannot enforce education-specific consumer protection laws on participating institutions for complaints subject to the reciprocity agreement. The proposer maintains that the few states with strong consumer protection laws should retain their authority to enforce that state’s consumer protection laws.
History of the Definition
The federal definition of a state authorization reciprocity agreement has an interesting history. The language was written by the Department and did not come from consensus language of a negotiated rulemaking. The regulation, along with several state authorization-related regulations, were released as final in mid-December 2016, which missed the November 1 deadline to be effective the following July. Therefore, it was not effective until July 1, 2018.
In early 2017, Department officials communicated with Russ Poulin about their intent to clarify widespread “misconceptions.” Poulin and others had indicated an ambiguity or limitation to reciprocity related to the enforceability of education-specific state laws when an institution participates in reciprocity. The Department sought to dispel that misconception which was then affirmed in a letter by then Under-Secretary to the U.S. Department of Education, Ted Mitchell. The Trump administration began just a few days later and delayed this regulation before it became effective. The regulation eventually became effective on May 26, 2019, after a U.S. District Court ruling vacated the delay. On October 31, 2023 new final regulations were released including the currently effective definition of state authorization reciprocity agreement that clarified the language of the definition and was subject to immediate implementation at the discretion of the institution.
What is Proposed by the Negotiator?
The negotiator proposes modifying the definition of a state authorization reciprocity agreement to directly indicate that a state subject to a reciprocity agreement isnotprohibitedfrom enforcing its own education-specific state laws in addition to general purpose laws for which states may already enforce. It is suggested that reciprocity could still exist for the purpose of a single application and fee.
Our Analysis
Frankly, this proposal dismantles reciprocity. There would no longer be a coherent structure to protect students nationwide with uniform student protections regardless of where the student is located. Neither would there be consistent oversight of institutions in the states where they are located and hold a legal obligation to meet any requirements of that state to be authorized. Nor would institutions be part of an organized structure to facilitate their uniform compliance management to implement requirements to support students.
The proposal fails to share that only a few states maintain strong consumer protection laws and chose to join the current reciprocity agreement. The proposal does not share that many states have none or little oversight of out-of-state institutions with no physical presence in the state.
Finally, dismantling of these elements of reciprocity will leave more students without protections than providing protections in those few states with stronger consumer protections. The data of the institutions overseen in each state and numbers serving students in other states is available on the NC-SARA website: https://nc-sara.org/data-dashboards.
Issue #3 – Distance Education
Proposal A: Create a “Virtual Location” for Distance Education
The Department identifies two problems that they are addressing with this proposal:
Collecting data on distance education. They wish to collect more data on distance education to inform students with program-level data in the College Scorecard and to compare the outcomes of students in similar programs using different modalities.
Program Closure. The Department would be enabled to protect students if an institution closes its entire distance education operations.
What Is Proposed by the Department?
Currently, the Department defines three types of locations: the main campus, a branch campus, and an “additional location.” The latter is currently a place where 1) more than 50% of a program is offered or 2) a place of incarceration. The Department proposes a third version of “additional location:”
“(3) A virtual location through which the institution offers 100 percent of an educational program through distance education or correspondence courses, notwithstanding requirements for students to complete on-campus or residential periods of 90 days or less.
Our Analysis
The Department will be able to assist students if an institution closes all its distance learning programs. We support students being able to avail themselves of the benefits as if the entire institution closed.
We have long supported collecting more distance education data. However, definitions are important or statistical comparisons will be compromised due to institutions unwittingly classifying the same programs differently. As we wrote last year, the Department has FOUR different definitions of distance education and this could add a fifth. We are interested in consolidating these definitions. Additionally, guidance will be needed on what programs are in or out of whatever definition they use.
Just last week, Inside Higher Ed published “Online Education Completion Lags Behind Face-to-Face Instruction.” Missing from the article was this important statement in the report (p. 25): “A disproportionate share of exclusively online students face time- or location-based constraints that can make them less likely to graduate from college—regardless of medium of instruction. This suggests that readers should exercise caution when interpreting our results, as some of the observed effects outlined in the present study may be due to selection.”
Proposal B: Clock Hour (Programs and Asynchronous Distance Education)
A quick background is needed.
Most institutions disburse financial aid based on credit hours. Some institutions (mostly those in career programs) disburse aid based upon the actual time the student spends in instruction. This proposal does not apply to credit hour programs.
What Is the Problem Identified by the Department?
The Department voiced no issue with synchronous clock hour programs, but has concerns about asynchronous distance education courses.
In those courses, students are to interact “with technology that can monitor and document the amount of time that the student participates in the activity.”
The Department has had trouble tracking asynchronous programs and is aware of non-compliance with the monitoring requirements.
What Is Proposed by the Department?
The Department proposes removing “the allowance for clock-hour programs provided via distance education to be offered through asynchronous learning.”
Our Analysis
We have asked members for input on this one and contacted the American Association of Community Colleges. Thus far we have not heard opposition to the change. Let us know if you have specific successful examples that would be affected. We are concerned that this is the second issue in which the Department merely removes an option for which the accounting is difficult.
The Department seeks to “increase the accuracy of R2T4 calculations for (distance) students, simplify the Department’s requirements by using available information already collected by an institution, and limit instances of inaccurate calculations and the gaming of R2T4 provisions by schools. Taking action and/or working with a student who has not been attending during a scheduled period for 14 days promotes good stewardship of Federal dollars as well as potentially assisting students during hardships.”
What Is Proposed by the Department?
In order to “increase the accuracy of calculations in distance education programs, the Department proposes to require institutions to take attendance in such education programs for R2T4 purposes, which would require schools to use actual attendance data to determine a student’s withdrawal date for students enrolled entirely in online programs.” In brief,institutions would need to take attendance in all courses in distance education programs. Additionally, this also triggers a requirement that students be dropped from a class if they have not attended for 14 days.
Our Analysis
The Department says, “students in distance education programs may not formally withdraw since they are not on campus.” But, on-campus students also withdraw without notice.
For students who withdraw from distance programs, the current practice is to capture the “last day of attendance.” A mere login is not sufficient, as evidence of an academically-related activity (e.g., exam taken, paper submitted, participation in a discussion) is required. For details, see the Federal Student Aid Handbook, Volume 5 on withdrawals, p. 52.
The 14 day drop requirement poses new challenges. When we posted this question to WCET members, some said that they have adult students (some in the military) who necessarily stop out for a few weeks, yet they successfully complete the course.
The Department says taking attendance will “Increase accuracy and simplicity of performing R2T4 calculations.” If the Department seeks to simplify, then forcing additional work on every faculty member is not simplifying. Currently, institutions track the last academically-related activity for the few students who drop without notice. The Department’s proposal would require additional attendance records for every student. Adding to the complexity is the need for new procedures for collecting attendance for asynchronous programs. How would that be done? Again, far from simple.
We object to this proposal.
Proposal B: Modules (Course Shorter than a Full Term)
Modules are courses shorter than a full semester or quarter. Problems arise in calculating the amount of aid to return when a student withdraws when enrolled in a module. Financial aid rules typically assume the student is enrolled in a course that spans the entire term.
What Is the Problem Identified by the Department?
The Department says that as “part of the 2019 negotiated rulemaking, the Department adopted a withdrawal exemption for programs offered in modules…Unfortunately, the module exemption has added complexity and confusion…It has also required significant guidance to explain how to determine whether a student qualifies for the exemption.”
What Is Proposed by the Department?
The Department says that to “simplify the calculations, the Department proposes to eliminate the withdrawal exemption…Under the proposed regulations those students would now be considered withdrawn unless they meet another withdrawal exemption, resulting in more money being returned to the Department and students not exhausting their aid eligibility as quickly.”
Our Analysis
It appears that the Department tried one approach and it proved to be more complicated than beneficial for aid officers and students. The change appears to be beneficial to both. If your institution makes extensive use of modules, it may be worth reviewing the proposed change with your financial aid officer.
Issue # 3- Accreditation and Red-line Document
Proposal A – Public representation on agency decision-making bodies
Similar to the governance proposal for a state authorization reciprocity agreement, the Department wishes to exclude certain entities from participation as a public member to an “agency decision-making body” for accrediting agencies.
The Department believes that these exclusions will reduce potential conflicts of interest and ensure that the public members are independent of the entities that the agency has accredited.
What is Proposed by the Department?
Like for the governance of a board for a reciprocity agreement, the Department is very specific as to who should be considered as a representative of the public. Former employees are added to the currently effective regulations barring institution and trade association current employees.
Our Analysis
The structure offered by the Department in the proposed language regarding representatives of the public is overly prescriptive. Like the previous discussion about the board for a reciprocity agreement, the language indicates “former employee” without a time frame or context. We are concerned about the ability to find appropriate representatives under this highly prescriptive structure.
Proposal B Substantive Changes and other reporting requirements
What Is the Problem Identified by the Department?
In order to ensure consistency and quality, the Department maintains that there is a need to revise substantive change requirements that focus on changes of greatest risk that may impact an institution’s resources and capacity in order to protect students.
What is Proposed by the Department?
This is a lengthy regulation with many subsections. Here are the three items that we believe SAN and WCET members will want to be aware of, and includes the following in regard to a substantive change:
Requiring agencies to visit and approve all “additional locations” of an institution.
Institutions would be required to seek a substantive change approval for their first distance education as well as at the 50 percent threshold. Additionally, an institution would need approval for additional programs at any level by an institution that has not previously offered programs at that level.
Elimination of exceptions for the agencies to delegate certain substantive change approval decisions to agency staff.
Our Analysis
Regarding the expansion of agency visits, we do believe that the Department must clarify the intention to include all locations defined in federal regulation as “additional locations.”
Note that there is also new proposed language addressed in Issue #3, Distance Education to include “virtual location” among the list of “additional locations.” If the Department truly means to include all “additional locations,” this could be a significant burden to accreditation agencies. If the “virtual location” provision is added, we are not sure what a visit to such a location would entail.
We concur with the new regulations to approve distance education on an institution’s first offering and at the threshold where 50% of the program is offered at a distance. This is a great improvement over the current standard of reviewing every program that is offered “in whole or in part” at a distance.” It appears that with the continued development of more offerings by distance education, the current standard through guidance is unnecessarily broad and could include nearly every program at an institution. We welcome the proposal.
The Department appears to seek the determinations of the agency decision-making body in all matters of substantive change rather than to delegate certain decisions to agency staff, as is the current practice. We do not see a rationale by the Department specific to this concern. The current regulation was developed through rulemaking that came to a consensus. One wonders why we need to revise a regulation that came from consensus and became effective July 1, 2020. One could consider that the currently effective regulation that allows agency staff to approve some requests is prudent as it provides for the accreditation agency to act more swiftly to address certain substantive changes.
Proposal C: Recognition of State Agencies for the Approval of Nursing Programs
What is the Problem that the Department Has Identified?
The Department wishes to codify existing practices and recognition of procedures of state agencies that provide the approval of nurse education. Currently, these agencies are subject to the Department.
What is Proposed by the Department?
The Department wishes to provide into Federal regulations, at proposed Part 604, the framework for oversight and accountability for the Secretary’s recognition of State agencies for the approval of nurse education.
The basis of the rules are found in outdated statute found here:1969 Federal Register Notice (pgs. 58-59) here: FR-1969-01-16.pdf (govinfo.gov)1.
Our Analysis
This is an extensive new section to the CFR to oversee these state agencies. It is reported that only five states would be subject to these regulations as they have chosen to be subject to the approval of the Department. The alternate negotiator for this rulemaking indicated that in the next year only three states would be subject to the approval of the Department. This is an extensive new section to the CFR to oversee these state boards of nursing. There is more to learn about the intent and applicability of these proposed regulations to state boards of nursing.
Conclusion
We know this is a lot to take in, especially on top of determining processes to implement new final regulations released last October that will become effective July 1, 2024.
However, it is important for you to know the potential impact of rules that could come from this new rulemaking, as these may affect your institutions and students.
Please stay tuned to WCET Frontiers for additional information and guidance, but you can also follow and participate in the process directly.
Register to stream the committee meetings in February and March. (cvent registration link will be provided on the Department’s website shortly before the February 5-8 meeting week).
Provide public testimony – 3 minute statement opportunities are offered during the last 30 minutes of each committee meeting. The timeslots fill quickly. Email negreghearing@ed.gov with your name and name of organization to reserve a spot.
Communicate with your senior leadership and government relations offices at your institution.
On accreditation topics, consider reaching out to your accreditor to seek information on the potential impact.
Communicate with your state legislators and/or Congressional Representatives or Senators depending on the issue area.
Share your concerns for your students and institutional processes with Cheryl Dowd (cdowd@wiche.edu) and/or Russ Poulin (rpoulin@wiche.edu). We will compile your comments to address. Please use the word Rulemaking at the beginning of your email subject line to help us identify your input.
We fully support the need for safeguards for students and for protecting the integrity of Title IV HEA programs. We hope that this rulemaking process will provide balanced, rational, and long-lasting regulations that consider the impact on all constituencies and provide clear regulations that are narrowly tailored to address specifically identified concerns.
Look for more from SAN & WCET as the rulemaking progresses!
In Hanna-Barbera’s 1962-63 space age cartoon, The Jetsons, Jetson’s son Elroy is enrolled in Little Dipper School with a robotic teacher, Miss Brainmocker. In this depiction, there is not a human teacher in sight, just robotic Miss Brainmocker.
It’s safe to say, that in the future there is either no Department of Education or a Department that has made its peace with the role of technology-assisted instruction, or at least the role of artificial intelligence. As more and more faculty are experimenting with AI in their classes, institutions need to be increasingly careful that they are in compliance with federal regulations governing regular and substantive interaction (RSI) and Title IV financial aid eligibility.
In a nutshell, however, RSI is one of the key sets of requirements that institutions are required to meet if their students are going to be eligible to receive Title IV federal financial aid. Found in 34 CFR 600.2, regular and substantive interaction is a key component in the federal definition of distance education. This definition of distance education is quoted below:
Distance education: Education that uses one or more of the technologies listed in paragraphs (1)(i) through (1)(iv) of this definition to deliver instruction to students who are separated from the instructor or instructors, and to support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.
The technologies that may be used to offer distance education include —
The internet;
One-way and two-way transmissions through open broadcast, closed circuit, cable,microwave, broadband lines, fiber optics, satellite, or wireless communications devices;
Audio conferencing; or
Other media used in a course in conjunction with any of the technologies listed inparagraphs (1)(i) through (1)(iii) of this definition.
For purposes of this definition, an instructor is an individual responsible for delivering course content and who meets the qualifications for instruction established by the institution’s accrediting agency.
For purposes of this definition, substantive interaction is engaging students in teaching, learning, and assessment, consistent with the content under discussion, and also includes at least two of the following—
Providing direct instruction;
Assessing or providing feedback on a student’s coursework;
Providing information or responding to questions about the content of a course or competency;
Facilitating a group discussion regarding the content of a course or competency; or,
Other instructional activities approved by the institution’s or program’s accrediting agency.
An institution ensures regular interaction between a student and an instructor or instructors by, prior to the student’s completion of a course or competency—
Providing the opportunity for substantive interactions with the student on a predictable and regular basis commensurate with the length of time and the amount ofcontent in the course or competency; and
Monitoring the student’s academic engagement and success and ensuring that aninstructor is responsible for promptly and proactively engaging in substantiveinteraction with the student when needed, on the basis of such monitoring, or uponrequest by the student.
Why is it important for institutions to adhere to this definition of distance education and include both regular and substantive interaction? Failure to do so comes with dire consequences like:
large fines from the Department of Education,
being required to refund federal financial aid dollars to the government, and,
(in egregious cases) the loss of Title IV financial aid eligibility.
What Does This Mean for Artificial Intelligence?
Keen observers will note that the first part of the definition of distance education references interactions between instructor(s) and students: “support regular and substantive interaction between the students and the instructor or instructors, either synchronously or asynchronously.”
Photo by Antoni Shkraba: https://www.pexels.com/photo/woman-talking-to-a-person-on-laptop-6266980/
For our purposes, the modality (either synchronous or asynchronous) of the learning is inconsequential; what matters is who is primarily involved in the delivery of instruction. In the Supplementary Information accompanying the final regulations released by the Department of Education in 2020, the Department takes pains to address the role of artificial intelligence and other technology-mediated instruction. At the time, the Department wrote,
“Only individuals responsible for delivering course content and who meet the qualifications for instruction established by an institution’s accrediting agency can fulfill the requirements for regular and substantive interaction with students. The Department does not prohibit other forms of substantive interaction that do not involve qualified instructors, but under the statutory definition such interaction cannot meet the requirements in the definition of ‘distance education.’”
The Department went on to write (emphasis added),
“Interaction with artificial intelligence, adaptive learning systems, or other forms of interactive computer-assisted instructional tools quality as types of ‘academic engagement,’ but in this limited context those forms of engagement do not meet the statutory requirements for regular and substantive interaction between students and instructors… [T]he definition currently requires regular and substantive interaction between students and instructors; substantive interactions with machines or other forms of technology that do not involve in [an] instructor would, therefore, not qualify.”
Thus, as one can see, the Department is clear that it is not allowable for artificial intelligence to be used to supplant rather than augment an instructor for courses eligible for federal financial aid.
What should you do if you are worried about the use of AI in your courses?
First and foremost, you need to make sure that your institution has a clear RSI policy and that all distance education faculty receive training on that policy. Document that this training has been completed.
Second, you should review your existing RSI policy to make sure that you directly address the role of AI in your courses and take steps to ensure instructors understand how they can and can’t leverage AI in meeting the Department of Education’s definition of distance education and regular and substantive interaction. Institutions may need to be explicit that artificial intelligence cannot substitute for instructor interactions with students.
In the release of those 2020 regulations, the Department was careful to not ban the use of artificial intelligence in the classroom and even suggested that such technologies might improve student-instructor interactions. But the Department has also been careful to clearly state that AI and related technologies can in no way substitute for the instructor.
One can’t help but wonder how a Jetson’s era Department of Education would interpret Little Dipper School’s reliance on Miss Brainmocker and whether or not Elroy and his classmates are receiving a quality education. Is anyone writing a Jetson’s spinoff show yet? Perhaps they will cover that story there.
In the realm of excellence, there are those who go above and beyond to achieve greatness. Their dedication, passion, and outstanding contributions set them apart, and it is important to honor those contributions with prestigious awards. Today, the State Authorization Network (SAN), a division of WCET – the WICHE Cooperative for Educational Technologies, not only celebrates our peers and their successes, but we unveil the secrets that have led them to their award-winning achievements. Join us as we announce the five remarkable compliance processes that have earned our esteemed accolades.
Even as compliance processes, policies, and procedures designed to comply with state and federal laws are unique to and contingent upon an institution’s specific activities, much can be gleaned through shared knowledge between peers and professionals in the field. Thus, it is in that very spirit of sharing and collaborating that SAN’s annual SANsational Award was borne.
About the SANsational Awards
Since 2015, SAN, a division of the WCET has recognized that innovation and creativity drive progress in the world of distance education compliance.
In that spirit, the SAN team annually honors these contributions by celebrating these outstanding distance education compliance practices. SAN realized early on that not only are these practices vital for meeting the contemporary needs of distance education regulations and requirements, but also essential for inspiring future breakthroughs.
SAN presents its annual SANsational awards to colleagues and their respective institutions that demonstrate diligence when creating innovative and sustainable processes designed to manage state and federal regulatory compliance for out-of-state activities.
This year, nominations were accepted in the following categories:
LicensurePrograms: Notifications and disclosures for professional licensure program status in each state.
Location: How the institution identifies where their students are located while taking online courses, doing internships/practicums etc., and to meet Federal regulations (34 CFR 600.9(c)(iii) & 34 CFR 668.43(c))? How does the institution report this information?
Compliance Innovations: Institution policy, tools, compliance teams, or other inventive or novel compliance management practices.
The SANsational Award Process
SAN offers members the opportunity to submit a self-nomination form that describes the solution they intend to address. The submissions are reviewed by an Awards Committee made up of respected compliance professionals. The committee evaluates the submissions in four areas:
That the solution meets the requirements and the needs of state and/or federal regulations, SARA policy, the institution, and students.
That the submission demonstrates a clear, comprehensive, and practical solution to meet compliance requirements.
The project exhibits the capability to be adapted or replicated as a model for others.
The project addresses the specific focus of the category chosen. Candidates should carefully choose the category for which they submit their self-nomination.
We would ’d like to extend our sincere gratitude to this year’s Awards Committee, each of whom carefully reviewed and considered all submissions and for providing guidance and leadership when selecting our 2023 award recipients:
Jeannie Yockey-Fine, General Counsel, NC-SARA who carefully reviewed and considered each award nomination.
And the winners are…
This year, SAN presented awards for five stellar project submissions. The recipients for 2023 are:
The Chicago School (Licensure Programs and Location),
Post University (Licensure Programs),
Sinclair Community College (Location), and,
The University of Louisville (Compliance Innovations).
Noted below are additional details about each institution and their respective projects.
Winner: The Chicago School, Los Angeles, California
Category: Licensure Programs
Project Title: The Licensure Story: When Obstacles & Challenges Lead to Wins
SAN is proud to announce that The Chicago School, a leader in providing programs and concentrations that focus on fostering a global understanding of growing fields, is a 2023 winner of the SANsational Award for the category of Licensure Programs.
(The Chicago School’s team-left to right) Miguel Valenzuela, Director, Accreditation Licensure, & State Authorization; Melea Fields, Associate Vice President/ALO, Accreditation, Licensure & State Authorizations; Rebecca Zacarias, Licensure and Administrative Support, Accreditation, Licensure, & State Authorizations
The Chicago School is a non-profit private institution with a national presence, offering over thirty graduate and undergraduate programs in professional fields such as psychology, business, health services, education, counseling, and more. These programs are offered in online/distance modality as well as on-ground.
To ensure compliance with the licensure disclosure requirements set forth by the Federal Government, The Chicago School’s Office of Accreditation, Licensure, & State Authorization (ALSA) team developed a process that determines and tracks where its programs’ offerings lead to professional licensure eligibility.
To bolster their compliance efforts, in 2019, The Chicago School’s ALSA team established an annual licensure audit. This process provides a detailed review of each state’s licensing laws and regulations as published on the state’s licensing board websites. The ALSA thoroughly reviews the laws and regulations to identify each state’s educational standards for licensure and whether the program requires individual approval from a state professional licensing board. Each of the state’s professional licensure requirements is placed into a database. Through this process, information related to existing licensure regulations and any changes is tracked and archived.
Once the research process is completed, the database is sent to the Program Chair to solicit appropriate feedback. As the program’s expert, the Program Chair works collaboratively with ALSA by reviewing the information provided and determining whether the program’s curriculum meets or does not meet licensure requirements, or whether a determination has not been made.
Upon completion of the review process, the ALSA works with the Legal Affairs office to approve all licensure disclosure changes to ensure federal/state compliance. This collaborative process has proven to be monumental in accurately tracking state licensure eligibility for The Chicago School’s programs.
SAN extends a hearty congratulations to this team!
Winner: Post University (Waterbury, Connecticut)
Category: Licensure Programs
Project Title: Personalized Licensure Advising and Disclosure
Members of the Post University team from left to right Alex Larsson, Accreditation Specialist; Melissa Pilloise, Accreditation Specialist; Christine Adamczyk, Accreditation Specialist; Michelle Hubbell, Director of Military and Graduate Admissions; Shawn Fields, Associate Director of Accreditation; Jana Walser-Smith (State Authorization Network); Sandra Wilson, Co-Provost; Jeremi Bauer, Co-Provost.
Innovation, creativity, and commitment continue to drive progress in the field of distance education compliance. As such, the associates at Post University embody this very ideal.
SAN is proud to award Post University the SANsational Award for its groundbreaking approach to advising and providing necessary disclosures to its students.
The associates at Post University believe that personalized guidance, unwavering motivation, robust support, and student-centered education are the catalysts that allow students to achieve their individual academic and career goals. Post University programs shape workforce-ready, socially responsible leaders through learning experiences offered in and out of the classroom. These experiences are designed to promote the exchange of knowledge, expand thinking, and refine practical and professional skills. Founded in 1890 and serving students online or in person from a 58-acre campus in Waterbury, Connecticut, last year’s unique student headcount included over 31,000 students.
Knowing that a simple posting of whether an enrollment could fulfill the educational requirements for licensure in each state required by federal regulations did not fully express Post’s tenet of Post Makes it Personal®, the Accreditation Department developed a program to advise students at each stage of the licensure process.
At Post, students are provided with personalized credentialing advising before, during, and after their enrollments by a small team of credentialing specialists. Starting with the graduate counseling enrollments in 2020, and extending to the accounting, nurse practitioner, and teaching English language learner enrollments in 2021, over 4,500 potential students and thousands more active students have been reached regarding licensure.
As a result of these efforts, students have expressed a great reduction in stress and anxiety, knowing that they have a plan to reach their professional goals before they even begin class and a partner in navigating the complicated path to licensure.
SAN salutes Post University for providing a model that provides personalized service and a commitment to student success!
The Chicago School – Los Angeles, California
Category: Location
Winning Project: Embracing Purposeful Engagement for a California Institution
The SAN team presented a second award to the team at The Chicago School for their work in the Location category. Their initiative, Embracing Purposeful Engagement for a California Institution, provides a comprehensive approach to understanding, tracking, and documenting student location.
In response to the need to track student locations for non-State Authorization Reciprocity Agreements (SARA) participating institutions, The Chicago School’s Office of Accreditation, Licensure, & State Authorization (ALSA), has developed and implemented processes to facilitate compliance with all state authorization activities. In conjunction with state authorization compliance, The Chicago School worked to create a solid and comprehensive process to determine, track, and monitor students declared state of residency and states of licensure to ensure students are well informed.
(The Chicago School’s team-left to right) Miguel Valenzuela, Director, Accreditation Licensure, & State Authorization; Melea Fields, Associate Vice President/ALO, Accreditation, Licensure & State Authorizations; Rebecca Zacarias, Licensure and Administrative Support, Accreditation, Licensure, & State Authorizations
The process and procedures of The Chicago School’s locations disclosure process follows an internal tracking, audit, and annual gap analysis of all authorized programs and states. Specifically, immediately upon beginning the admission process, students are asked to disclose not only their state of residence but any state they intend to be licensed in after completion of the program.
Students are then immediately notified (via an automated pop-up linked to the ALSA team’s audits) if their program does not meet licensure requirements for the state they chose. If a student continues the enrollment process, they are then counseled by a program expert and asked to acknowledge the information provided on licensure for their state(s).
Additionally, this team has built an automated notice into the student portal if they make an address change. This immediately informs the student if the new state fails to meet any licensure requirements. Should students identify a state the program is not eligible, they are routed to a counselor to further obtain acknowledgment. This process also satisfies the individualized notification federal mandate (34 CFR 668.43(c)) that requires institutions to notify students within 14 calendar days if a determination is made that the institution’s curriculum does not meet state educational requirements where the student is located.
This project has made significant strides in ensuring that The Chicago School’s students are kept abreast of any changes in state licensure requirements thus facilitating matriculation and completion. Well done Chicago School!
Sinclair Community College – Dayton, Ohio
Category: Location
Winning Project: Professional License Disclosures
The team at Sinclair Community College earned recognition for its exceptional contribution to the field with its student location tracking project.
Founded in 1887, Sinclair is the nation’s oldest continually operating community college. The institution features more than 30,000 students at its main campus, four regional centers, as well as online. Since 1979, Sinclair has offered robust, student-centered distance education and eLearning-infused opportunities for all learners based on Quality Matters design principles.
The Sinclair team pictured from left to right) Cheryl Dowd, (State Authorization Network); Chris Prokes, Program Director, eLearning Strategy and Innovation; Brittany Barrett, Compliance Coordinator; Amanda Owen, Manager of Distance Education, and eLearning Compliance.
For 136 years, Sinclair has heeded the credo of founder David Sinclair to “Find the need and endeavor to meet it”. Accordingly, the Sinclair team continually strives to maintain focus on quality and innovation, sustainability, accessibility, and community alignment to provide the Miami Valley region with the highest standard in educational opportunities. As a result, Sinclair consistently ranks among the top community colleges in America and a top choice for students.
The impetus for this project is rooted in Sinclair’s identification of the need to formulate a response to the out-of-state disclosure requirement (34 CFR §668.43 (c)). The regulation requires institutions to provide direct disclosure notifications to students in programs that lead to professional licensure or certification.
Sinclair’s first step was to collect a list of all programs that lead to professional licensure and create a database that identified if the program satisfies education requirements by state. Then, by cross-referencing student records to determine student location, the database automatically triggers an email with personalized direct disclosure information to students, keeping the college’s actions in compliance with regulations.
Collaboration was key to this project’s success, as multiple offices across campus participated in the creation and delivery of the Professional License Disclosures Database. Leadership from the Provost’s Office, the eLearning Compliance Department and the Research, Analytics, and Reporting Office (RAR) were critical in the development and success of the project. Through such collaboration, a resilient system was created to maintain compliance, deliver necessary information to students, and keep detailed records for internal and external reporting.
It is the hope of the Sinclair team that their Professional License Disclosures Database may serve as a blueprint for other institutions to create an efficient system to fulfill the obligations for compliance with out-of-state disclosure requirements. Congratulations to the entire team at Sinclair!
University of Louisville – Louisville, Kentucky
Category: Compliance Innovations
Winning Project: Elevating the Importance of Academic Compliance: A Paired Approach to Change
Located in Kentucky’s largest metropolitan area, UofL is a public research university with 12 academic schools and colleges and serves as home to more than 23,000 students.
(The UofL team pictured from left to right) Kelvin Thompson, Vice Provost for Online Strategy & Teaching Innovation; Kathryn Kerensky (State Authorization Network); Jennifer Hurwitz, Distance Education Compliance Manager; Kristen Brown, Associate Director Online Learning.
The UofL is proud to be recognized among the nation’s best institutions for African American, LatinX and LGBT+ students. The institution has also been designated as a Military Friendly school, and is a producer of top scholars, including more Fulbright Scholars since 2003 than all other Kentucky public institutions combined.
The UofL is committed to ensuring access to higher education for all, including increasing the availability of financial aid for low-income and first-generation college students and providing additional support and resources for underrepresented populations.
This project emerged from the fact that institutional size and organizational structure can often impact viable solutions to state authorization and related academic compliance challenges. This is especially true at large, decentralized universities where campus units grapple with a multitude of conflicting priorities; thus, securing buy-in can be a painfully slow process.
Furthermore, certain job titles, such as ‘distance education compliance manager,’ might inadvertently lead colleagues to assume that specific compliance concerns do not pertain to them. This, in turn, may cause key stakeholders to question the prioritization of academic compliance, especially when they fail to observe any immediate signs of Title IV eligibility being in jeopardy or that potential fines and sanctions could be levied against the institution.
In a context like this, developing a strategic approach for elevating the importance of academic compliance can be critical for achieving desired outcomes. By identifying where the key stakeholders already were and leveraging two existing university leadership meetings to build trust and to maintain awareness of academic compliance issues, the distance education compliance manager carved out space for academic compliance awareness to spread.
The UofL team assures all that, “This compliance innovation is simple, easy to adapt for any institution, and time is the only expense.” Well done to all at the UofL!
Learn more about the 2023 Winners!
The SAN team offers our congratulations to each of the SANsational Award Winners! We are proud of your accomplishments and extend our gratitude for your willingness to share your ideas and processes with those of us in the field! It also goes without saying how much the SAN team enjoyed our visits to each of these campuses when presenting their SANsational award in person.
For additional details on these fascinating projects visit the SANsational Webpage. There, you will find recorded presentations from each of our winners detailing their processes, challenges, and outcomes. Please note that the recorded presentations are each approximately 20 minutes in length.
Your team too could be winners! Mark your calendars for the 2024 award selection process which will begin in the summer.
For more information about the activities, events, and resources provided by the State Authorization Network (SAN), please visit the SAN Website or contact the SAN team at san-info@wiche.edu.
ChatGPT recently turned one and what a wild, first year it has been. Over the last twelve months, institutions have scrambled to not only better understand generative Artificial Intelligence (AI) and its impact on teaching and learning, but also to determine the best ways to provide guardrails and guidance for faculty, staff, and students. Many institutions have struggled to develop institutional-level policies.
In a spring survey administered by WCET, only eight percent of respondents reported that their institution had developed and/or implemented at least one AI-related policy.
WCET has developed an AI policy and practice framework to help institutions identify the policy areas that they need to address and develop policies and guidelines for those areas.
The Framework
In 2023, Cecilia Ka Yuk Chan conducted research on perceptions and implications of text generative AI technologies in order to develop an AI policy for higher education. Based on the findings, she proposed an AI Ecological Education Policy Framework to address “the multifaceted implications of AI integration in university teaching and learning.”The WCET framework adapts Chan’s framework and categorizes institutional AI policy needs in three areas:
Governance,
Operations, and,
Pedagogy.
Undergirding all three areas of our policy and practice framework is the ethical and responsible use of AI. All policy decisions at colleges and universities should be grounded in ethical considerations of AI. Doing so ensures the most effective and responsible use of, and teaching about, these technologies. And it is often institutional administrators who lead this work. Not developing and implementing AI policies within the context of ethical considerations opens up the institution – and thus its leaders – to, at best, inefficient use of resources that often include funds from taxpayers, and, at worst, serious breaches of privacy, security, transparency, and equity.
Governance
This dimension emphasizes the governance considerations surrounding AI usage in higher education. Governance refers to the senior management at an institution, including such positions and roles as Chancellor/President, Chief Academic Officer, Chief Information Office, Vice President for Student Services, VP for Institutional Research/Effectiveness, and others depending on the campus context. Governance may also encompass managers such as Deans and Chairs of academic discipline units. Members of senior leadership will be the initiators for the Governance dimension of the framework. As they hold decision-making authority, they should set the tone for effective and innovative AI use across campus and ensure that all AI policies and practices support the mission and goals of the institution and foster an equitable and inclusive environment.
Here we highlight six areas of responsibility:
Data governance.
Data governance refers to an institution’s policies and processes that ensure that effective and responsible management, including security, exists throughout the complete lifecycle of the data, and data controls are implemented that support business objectives.
Evaluation of AI use across the institution.
Campus administrators should also oversee (working in concert with such units as Institutional Research and Information Technology) the evaluation of the effectiveness of AI in every use. The information and data collected should be harnessed for continuous improvement of AI planning, policies, and practices. By regularly collecting feedback from all users, including students, colleges and universities can make informed decisions about how to improve AI implementation. Evaluating the effectiveness of AI tools in enhancing learning outcomes is also vital to determine their value and make adjustments as needed.
Promoting and monitoring faculty and staff usage of AI, including research.
Where appropriate, institutional governance should work to encourage campus personnel, including faculty, and students to utilize AI technologies. It may be important to continue to emphasize that, even in AI use, faculty remain centered as the subject matter experts and that AI technologies can support their ongoing role as SMEs. Along with this, though, comes the responsibility of monitoring that use – including while conducting research – to ensure that it is ethical, effective, and appropriate.
Inclusive, equitable access.
Ensuring equitable access to AI technologies is crucial for fostering an inclusive learning environment. Universities should work to provide the appropriate technologies and support to all students, faculty, administrators, and staff, regardless of their background or access to technology. By promoting equal access to AI technologies, universities can help level the playing field and ensure that all students and staff have the opportunity to benefit from the advantages offered by AI integration. Not doing so widens the digital divide.
Intellectual property.
Leaders at institutions will need to consider how intellectual property, including research, course materials, and student-produced work, is defined and, where needed, protected when created using AI, either fully or in part. However, these policies must be developed in accordance with U.S. and international copyright laws (which are scrambling to keep up with the new technologies) and, thus, likely should involve collaboration with the institution’s legal counsel.
AI use and promotion, tenure, & re-appointment practices.
Institutional leaders should also consider how works produced using AI are considered in promotion, tenure, and reappointment of faculty. These processes can be used to reward and incentivize innovative research and teaching, but they also should guard against plagiarism of content in portfolios and dossiers.
Operations
This dimension assists in the understanding and implementation of AI across the institution and includes staff in key areas such as Academic Affairs, Information Technology, and Centers for Teaching & Learning Effectiveness/Excellence. Here we highlight three areas of responsibility:
Professional development (training & support).
Training and support on AI technologies should be offered to all who use or may use AI, including administrators, staff, faculty, and students. Effective training and support can go a long way to mitigate and alleviate often extensive (and legitimate) concerns about integrating AI into work, instruction, and learning. Investing in training, support, and resources can help educators, their students, and others feel more confident and capable in navigating the complexities and ever-changing landscape of AI technologies.
Developing and maintaining infrastructure for AI.
The responsibility for developing and maintaining an institution’s AI infrastructure will likely fall primarily to Information Technology in consultation with other units to determine needs and evaluate costs and efficacy of tools.
Review and recommend AI implementation to improve operational practices.
All operational units should be engaged in scanning the landscape of AI to review and recommend platforms and tools that can enhance the efficiency and effectiveness of the institution’s operations, whether for student services and support, instruction and learning, admissions, recruitment and marketing, staff workflows, and resource planning, among others.
Pedagogy
This dimension emphasizes the practical implementation of AI to support instruction and learning in the classroom. Faculty are the initiators of this dimension, working closely with those in Operations to actualize policy and planning from the Governance level while always considering ethical dimensions. Instructors are ultimately responsible for designing and implementing curricula, activities, and assessments that utilize AI technologies. They will need to gain some expertise to determine how AI can best support and enhance students’ learning experiences while assisting learners in understanding the implications for academic integrity. Here we highlight seven areas of responsibility:
Academic integrity.
Generative AI has raised concerns that students will misuse technologies to plagiarize. The more clear and consistent policies are, the more likely students will understand and follow them, reducing the chances of misuse. Policies and guidelines may range from those that ban the use of AI in the classroom altogether, to those that allow and even encourage use. Policies regarding appropriate attribution and acknowledgment of AI technologies used to create assignments and other products of learning are crucial as well. There may be an institutional policy regarding this; if not, faculty should develop their own.
Assessment practices.
Assessing the effectiveness of learning is a hallmark of education; however, it has been historically fraught and intertwined with ensuring academic integrity. The increasing ubiquity of Generative AI has further complicated these practices, necessitating reconsideration of assessment methods to balance the benefits of AI with the need to maintain academic integrity.
Clear communication to students regarding AI expectations.
Faculty should clearly state in the syllabus how students will be expected to use AI in the class and should also verbally communicate those expectations on the first day of class. Being clear about how a faculty member will leverage AI in the course allows students to make informed decisions about whether to stay in the course.
Developing student AI competencies and skills/workforce preparation.
The increasing ubiquity of Generative AI in the workplace calls for a new digital literacy. This need makes it imperative for institutions to prepare students for this complex technological working landscape, equipping them with skills and knowledge to successfully navigate not only the current landscape, but a rapidly evolving one as well. Therefore, not only should faculty teach at least basic skills students need to integrate AI into their work, but also evaluate when it is appropriate to use AI, how to evaluate the tools, and to understand their role in professional settings.
Understanding algorithmic bias.
Instructors should make students aware of the possibility of discrimination being programmed into AI, since fallible humans must be a part of the process to develop inputs used (with the recognition that humans may themselves perpetuate discriminatory practices through the data).
Regular & Substantive Interaction.
The use of AI to augment or even replace certain instructional and related support practices, such as information delivery, responding to questions, assessment, tutoring, and personalized learning and guidance, could have a significant impact on norms and expectations around interactions between students and instructors. Institutions should ensure that they address the extent to which faculty are allowed to automate instruction through the use of artificial intelligence and the aspects of instruction that can leverage artificial intelligence. For most institutions, this will mean revising existing policies on regular and substantive interaction.
Learner accessibility.
It is important to consider the ways in which some generative AI tools might not be accessible for all students with disabilities and learning challenges in general, while others may support accessibility, including for users of assistive technology. All learners using assistive technology must be able to meaningfully engage and independently interact with AI interfaces and outputs.
Putting aside fears of AI surpassing human intelligence and achieving singularity – a hypothetical future point in time at which technological growth becomes uncontrollable and irreversible – legitimate concerns remain a year after the appearance of ChatGPT, including in education.
Issues surrounding academic integrity, the quality of knowledge produced by AI tools, the replacement of instructors by AI, mitigating a new “digital divide,” and how to prepare students for an AI-infused workforce, among others, are real.
Institutions continue to grapple with security and privacy, equity and access, and other challenges that these technologies present.
Upcoming WCET Resource Addressing AI in Higher Ed
In his Substack AI + Education = Simplified, Lance Eaton suggests that the all-too-common reinvention of wheels in higher education – “the thing that contributes to institutions being so slow” – is stymieing effective use of AI in the sector. WCET is committed to addressing this challenge by bringing institutions together to share knowledge and providing resources to support the community. One of the resources that we are most excited about is the development of our AI Policy and Practice Toolkit which we will release later this month. This WCET members-only resource builds out our AI Policy and Practice Framework and includes sample policies and/or guidelines for each of the outlined areas.
If your institution is not a WCET member, you can join now. WCET is offering a discounted membership rate through the end of the year of 35% off new memberships in celebration of our 35thanniversary. You can find more information about it here. And if you are wondering if your institution is a member of WCET, you can access a list of members here.
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.
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